English ESIA Study for Repackaging & Storage of Obsolete Pesticides In

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Public Disclosure Authorized

ENVIRONMENTAL SOCIAL IMPACT ASSESSMENT STUDY FOR STORAGE SITES OF OBSOLETE PESTICIDES IN NORTH DELATA PROVINCE (BEHEIRA AND ALEXANDRIA) AND SITE 44 IN ADABEYA PORT, SUEZ

Presented By: Dr. Samia Massoud Mohamed Accredited Environmental Consultant

Public Disclosure Authorized Presented To: Sustainable Persistent Organic Pollutants (POPs) Management Project (SPMP)

Issued on: February, 2020

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Table of Contents 1. THE EXECUTIVE SUMMARY ...... 11 1.1 Project Background ...... 11 1.2 Project activities, Objectives and Justification: ...... 11 1.2.1 The General Approach of ESIA ...... 12 1.2.2 Environmental Legislation and Institutional Framework...... 12 1.2.3 Project Activities Overview ...... 14 1.3 Methodolgy of ESIA ...... 11 1.3.1 Data Collection and Consultations ...... 12 1.3.2 Development of Environmental and Social Management Plan (ESMP) ...... 12 1.3.3 Roles and Respnsibilties for the Implementation of the ESMP ...... 12 1.4 Description of the Project Areas ...... 11 1.4.1 Site (18) Nubareya City, Beheira Governorate ...... 12 1.4.2 Site (23) Nubareya City, Beheira Governorate ...... 12 1.4.3 Site (48) Alexandria port, Alexandria Governorate ...... 12 1.4.4 Site (44) Suez port, Suez Governorate ...... 12 1.5 Assessment of Potential Impacts (Positive & Negative) ...... 20 1.6 Proposed Mitigation Measures and Environmental and Social Management Plan ...... 21 1.7 Analysis of Alternatives ...... 30 1.8 Public Participation and Consultation ...... 30 1.9 Conclusion and Recommendations ...... 32 2. LEGAL AND INSTITUTIONAL FRAMEWORK ...... 33 2.1 National Policies, Strategies and Programs...... 33 2.1.1 The National Implementation Plan (NIP) for Stockholm Convention on POPs ...... 33 2.1.2 The Overall Environmental law Framework of Egypt ...... 34 2.1.3 Hazardous Waste Regulations ...... 37 2.1.4 Pesticides Specific Regulations ...... 39 2.1.5 Environmental Impact Assessment ...... 40 2.1.6 Law 48/1982 regulations, amended executive regulations with decree 92/2013 ...... 46 2.1.7 Law 93/1962 regulations, amended decree 44/2000 for discharging to public sewer ...... 47 2.1.8 Law 4/1994 amended by executive regulation no.1095/2011 for discharging to Sea, Annex (10) ...... 47 2.1.9 Archaeological Resources ...... 47 2.2 Worldbank Environmental And Social Precautionary Policies For ESIA ...... 47 2.2.1 Worldbank Environmental Assessment (EA) Strategy ...... 48

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 2.2.2 Worldbank Environmental Health & Safety Guidelines (EHSG) according to IFC ...... 51 2.3 International Conventions and Agreements ...... 53 2.4 Responsibilties ...... 55 3. SITES DESCRIPTION ...... 57 Introduction ...... 57 3.1 Beheira Governorate ...... 57 3.1.1 Topography ...... 58 3.1.2 Geomorphological Features ...... 59 3.1.3 Hydrogeology ...... 59 3.1.4 Geological Sedimentary ...... 61 3.1.5 Soil Characteristics ...... 62 3.1.6 Climatic Conditions ...... 62 3.1.7 Land use ...... 64 3.1.8 Social Features ...... 65 3.1.9 Economic Features ...... 67 3.1.10 Ecology of the study area (Flora & Fauna) ...... 68 3.1.11 Project locations – Site (18) & Site (23) ...... 69 ❖ Site (18) – Nubareya city , Beheira Governorate ...... 69 Site Surrounding ...... 71 ❖ Site (23) – Nubareya city , Beheira Governorate ...... 73 Site Surrounding ...... 74 3.2 Alexandria Governorate ...... 77 3.2.1 Topography ...... 77 3.2.2 Geomorphological Features ...... 78 3.2.3 Hydrogeology ...... 78 3.2.4 Geological Sedimentary ...... 79 3.2.5 Soil Characteristics ...... 80 3.2.6 Climatic Conditions ...... 80 3.2.7 Land use ...... 82 3.2.8 Social Features ...... 82 3.2.9 Economic Features ...... 84 3.2.10 Ecology of the study area (Flora & Fauna) ...... 84 3.2.11 Project locations – Site (48) ...... 85 ❖ Site (48) – Alexandria port , Alexandria Governorate ...... 85

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Site Surrounding ...... 86 3.3 Suez Governorate ...... 88 3.3.1 Topography ...... 89 3.3.2 Geomorphological Features ...... 91 3.3.3 Hydrogeology ...... 91 3.3.4 Geological Sedimentary ...... 12 3.3.5 Soil Characteristics ...... 93 3.3.6 Climatic Conditions ...... 93 3.3.7 Land use ...... 95 3.3.8 Social Features ...... 95 3.3.9 Economic Features ...... 99 3.3.10 Ecology of the study area (Flora & Fauna) ...... 99 3.3.11 Project locations – Site (44) ...... 12 ❖ Site (44) – Adabeya port , Suez Governorate ...... 12 Site Surrounding ...... 12 3.4 Earthquakes ...... 11 3.5 Terrestrial Biological Environment ...... 11 3.6 Baseline Measurements ...... 11 3.6.1 Sampling & Analysis Regime ...... 12 3.6.2 Air Quality Sampling & Analysis ...... 106 3.6.3 Soil Quality Sampling & Analysis ...... 111 3.6.4 Water Quality Sampling & Analysis ...... 115 3.7 Sampling Procedures ...... 120 3.7.1 Soil Samples ...... 120 3.7.2 Sample Identification ...... 121 3.7.3 Sample Labels ...... 121 3.7.4 Sample Chain of Custody ...... 121 3.7.5 Sample Shipment and Packaging ...... 122 3.7.6 Decontamination ...... 122 3.7.7 Laboratory Analysis ...... 122 3.8 Quality Control Procedures ...... 123 3.8.1 Field Quality Control ...... 123 3.8.2 Laboratory Quality Control ...... 123 3.8.3 Analysis Plan ...... 125

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3.8.4 Workers Protection ...... 125 4. IMPACT IDENTIFICATION AND MITIGATION QUANTITATIVE RISK ASSESSMENT STUDY ...... 127 Introduction ...... 127 4.1 Risk Assessment Steps ...... 128 4.2 Risk Assessment Matrices of Entailed Operations at Behiera Agriculture Directorate site (23) 166 4.2.1 Entering the Store Risk Analysis ...... 166 4.2.2 Handling the POPs Risk Analysis ...... 169 4.2.3 Repackaging of POPs Risk Analysis ...... 173 4.2.4 Removal of Repacked OPs Risk Analysis ...... 177 4.2.5 Loading OPs to Trucks Risk Analysis ...... 181 C- Summary of Hazard Mitigation for all project stages on health & environment at Behiera Agriculture Directorate site (23) ...... 188 4.3 Environmental Social Management Plan with Mitigation Measures ...... 194 4.4 Roles & Responsibilties for the Implementation of the (ESMP) ...... 201 4.5 Decontamination Plan for the Sites under Study after removing OPs ...... 201 4.6 Grievance Redress Mechanism (GRM) ...... 203 4.7 Signs and Guidance Panels ...... 205 5. ONSITE...... 207 5.1 Onsite & Storage Conditions ...... 207 Site (18)- Nubareya city ...... 207 Site (23)- Nubareya city ...... 208 Site (48) at Alexandria port ...... 208 Site (44) at Adabeya port ...... 209 5.2 Methodolgy of Work ...... 209 5.2.1 Inventory of Types & Quantities of OPs stored inside the Sites under Study ...... 210 5.2.2 Mointoring the Environmental Sitiuation Inside & Outside the Stores ...... 213 5.2.3 Repackaging & Handling of Obsolete Pesticides ...... 213 5.2.4 Loading of repacked of Obsolete Pesticides & Transportation Stage ...... 217 5.3 Road Transport ...... 218 6. OCCUPATIONAL & PUBLIC HEALTH ...... 220 6.1 Exposure and Effects of Pesticides ...... 220 6.2 Effects of the clean-up (removal of Ops) on the quality of the environment ...... 221 6.3 Emergency Respose Plan ...... 222 6.3.1 Preface ...... 222 5

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 6.3.2 Objectives of the Emergency Plan at the Proposed Sites ...... 223 6.3.3 Potential Emergencies during implementation of the Proposed Project ...... 223 6.3.4 Fire Handling Procedures ...... 224 6.4 Requirements of Emergency Plan ...... 225 7. PROJECT ALTERNATIVES ...... 227 7.1 "Without Project" Alternative: ...... 227 7.2 "Repacking And Safe Disposal Of Ops In The Sites Of North Delta Province (Nubareya & Alexandria) & Adabeya Port in Suez" Alternative ...... 228 7.2.1 Incountry Disposal ...... 228 7.2.2 Disposal of OPs outside Egypt (Export to a disposal Facility in Europe) ...... 230 7.3 Methods of Collection, Repackaging and Storage ...... 231 7.4 Costs ...... 229 8. PUBLIC CONSULTATION SESSIONS ...... 232 8.1 Public Consultation Session of North Delta Region sites: ...... Error! Bookmark not defined. 8.1.1 Invitations to consultation session of North Delta Region sites ...... 233 8.1.2 Proceeding the public consultation session of North Delta Region sites ...... 235 Women contribution in the public consultation session ...... 241 8.2 Public Consultation Session of site (44) at Adabeya port: ...... 250 8.2.1 Invitations to consultation session of site (44) , Adabeya port: ...... 250 8.2.2 Proceeding the public consultation session of site (44), Adabeya port: ...... 250 Women contribution in the public consultation session ...... 253 ANNEXES: ...... 263

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez List of Figures

Figure 1-1: The Surrounding area for site (18) ...... 17 Figure 1-2: The Surrounding area for site (23) ...... 18 Figure 1-3: The Surrounding area for site (48) ...... 19 Figure 1-4: The Surrounding area for site (44) ...... 19 Figure 3-1: Adminstrative boarders of project governorates ...... 57 Figure 3-2: New Nubareya City location within Beheira Governorate...... 58 Figure 3-3: Topography Map of Beheira Governorate ...... 59 Figure 3-4: Wells locations near to sites (18) & (23) ...... 60 Figure 3-5: Contour Map of the underground water near sites (18) & (23) ...... 60 Figure 3-6: Geological map for Nubareya City ...... 61 Figure 3-7: Wind rose diagram for Beheira Governorate, 2019...... 64 Figure 3-8: Google Map showing the location of site (18)...... 69 Figure 3-9: Real Photos for three of the six OPs stores at site (18) from inside & outside...... 70 Figure 3-10: The Surrounding area for site (18)...... 71 Figure 3-11: Real photo for residential buildings from Norh direction ...... 71 Figure 3-12: Real photo for Entertainment mall from East direction ...... 71 Figure 3-13: Real photo for main street & residential buildings from West direction ...... 72 Figure 3-14: Google Map showing the distance between the nearest surface water source and main roads to site (18)...... 72 Figure 3-15: Google Map showing the location of site (23)...... 73 Figure 3-16: Real Photos for site (23) from inside & outside...... 74 Figure 3-17: The Surrounding area for site (23) ...... 75 Figure 3-18: Main street from South direction ...... 75 Figure 3-19: Main street from East direction ...... 75 Figure 3-20: Cultivated area from West direction ...... 75 Figure 3-21: Google Map showing the distance between the nearest surface water source and main roads to site (23) ...... 76 Figure 3-22: Google Map showing the location of Alexandria Sea Port...... 77 Figure 3-23: Topography Map of Alexandria Governorate ...... 78 Figure 3-24: Main aquifers in Alexandria Governorate ...... 79 Figure 3-25: Geological map for Alexandria Governorate ...... 79 Figure 3-26: Wind rose diagram for Alexandria Governorate, 2019...... 82 Figure 3-27: Google Map showing the location of site (48)...... 85 Figure 3-28: The Surrounding area for site (48) ...... 86 Figure 3-29: Schools from the East direction outside the port ...... 86 Figure 3-30: Adminstrative buildings from the North direction inside the port ...... 86 Figure 3-31: Private warehouses from South direction outside the port ...... 87 Figure 3-32: Harbour from the West inside the port ...... 87 Figure 3-33: Google Map showing the distance between the nearest surface water source and main roads to site (48) ...... 88 Figure 3-34: Adminstrative divisions of Suez and its surrroundings ...... 88 Figure 3-35: Google Map showing the location of Adabeya port...... 89 Figure 3-36: landforms of the Northwestern part of the Gulf of Suez...... 90 Figure 3-37: Topography Map of Suez Governorate ...... 90 Figure 3-38: Main aquifers in the study area (Site 44) ...... 91 Figure 3-39: Geological map for the study area (Site 44)...... 92 7

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Figure 3-40: Soil classification in Suez Governorate ...... 93 Figure 3-41: Wind direction (degrees) & Speed (km/h) for prevealing wind,2019...... 94 Figure 3-42: Google Map showing the location of site (44)...... 100 Figure 3-43: Real Photos for site (44) from inside & outside...... 101 Figure 3-44: The Surrounding area for site (44)...... 102 Figure 3-45: Map showing the surrounding area for site (44)...... 103 Figure 3-46: Seismic activity belt...... 104 Figure 3-47: Project areas in relation to protected area in Egypt ...... 104 Figure 3-48: Air bags used for collection of air samples...... 106 Figure 3-49: GC-MS used in the analysis of air samples...... 107 Figure 3-50: Real photo for a soil sample...... 111 Figure 3-51: HPLC-MS-MS used in the analysis of soil and water samples...... 111 Figure 3-52: Real photo for water samples...... 116 Figure 3-53: Personal Protective equipment (level B) ...... 126 Figure 4-1: Personal Protective equipment (level D) ...... 202 Figure 4-2: Waring sing to be placed in each site before strating decontamination plan ...... 202 Figure 5-1: Real photos from site (18) showing the storage conditions for OPs ...... 207 Figure 5-2: Real photos from site (23) showing the storage conditions for OPs ...... 208 Figure 5-3: Real photos from site (48) showing the storage conditions for OPs ...... 208 Figure 5-4: Real photos from site (44) showing the storage conditions for OPs ...... 209 Figure 5-5: Packages used in repackaging of OPs ...... 215 Figure 5-6: Placing warning signs on pesticides containers ...... 215 Figure 5-7: Plastic sheet distributed inside the container of OPs ...... 216 Figure 5-8: Obselete pesticide packages strapped inside the container ...... 216 Figure 5-9: Crane loading pesticides containers on the truck ...... 217 Figure 8-1: Invitation to the public consultation session of North delta region site on the project’s website ...... 235

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez List of Tables

Table 1-1: POPs Obsolete Pesticides – Environmental and Social Management Plan ...... 22 Table 1-2: POPs Obsolete Pesticides – Mointoring before, during and after implementing the project ...... 29 Table 2-1: Summary of legal requirements for hazardous waste management ...... 37 Table 3-1: legend of geological formation in Nubareya area, Egypt ...... 61 Table 3-2: Monthly and yearly average temperaturtes in Beheira Governorate during the period between 1999 until 2013 ...... 63 Table 3-3: Monthly and yearly average relative hummidity in Beheira Governorate during the period between 1999 until 2013 ...... 63 Table 3-4: Monthly and yearly average rain rates in Beheira Governorate during the period between 1999 until 2013 ...... 63 Table 3-5: Monthly and yearly average wind speed in Beheira Governorate during the period between 1999 until 2013 ...... 64 Table 3-6: Different age groups in Beheira Governorate ...... 65 Table 3-7: Manpower and unemployment distribution in Beheira Governorate ...... 65 Table 3-8: Energy supplies in Beheira Governorate ...... 67 Table 3-9: Main crops in Beheira Governorate,2005 ...... 68 Table 3-10: Description of site (18)- Nubareya city- Beheira Governorate ...... 69 Table 3-11: Description of site (23)- Nubareya city- Beheira Governorate ...... 73 Table 3-12: Legend of Geological formation in Alexandria, Egypt ...... 80 Table 3-13: Monthly and yearly average temperaturtes in Alexandria Governorate during the period between 1999 until 2013 ...... 80 Table 3-14: Monthly and yearly average relative hummidity in Alexandria Governorate during the period between 1999 until 2013 ...... 81 Table 3-15: Monthly and yearly average rainy days in Alexandria Governorate during the period between 1999 until 2013 ...... 81 Table 3-16: Population and % of different age groups in Alexandria Governorate ...... 81 Table 3-17: Description of site (48) , Alexandria port, Alexandria Governorate ...... 82 Table 3-18: legend for the study area site (44) showing different geological sedimentary ...... 85 Table 3-19: Monthly and yearly average temperaturtes in Suez Governorate , 2014 ...... 92 Table 3-20: Monthly and yearly average relative hummidity in Suez Governorate, 2014 ...... 94 Table 3-21: Monthly and yearly average rainfall days in Suez Governorate , 2014 ...... 94 Table 3-22: Population features in Suez Governorate , 2010 ...... 95 Table 3-23: Age distribution in Suez Governorate, 2010 ...... 95 Table 3-24: Labor force in Suez Governorate, 2010 ...... 96 Table 3-25: Literacy in Suez Governorate, 2010 ...... 96 Table 3-26: Health infrastructure in Suez Governorate, 2010 ...... 97 Table 3-27: Drinking water supply in Suez Governorate, 2010 ...... 98 Table 3-28: Domestic sewage service in Suez Governorate, 2010 ...... 98 Table 3-29: Energy supply service in Suez Governorate, 2010 ...... 98 Table 3-30: Description of site (44) , Adabeya port, Suez Governorate ...... 100 Table 3-31: Sampling regime in the sites under study ...... 105 Table 3-32: Analysis results of air samples collected from site (18), Nubareya city-Beheira Governorate 107 Table 3-33: Analysis results of air samples collected from site (23), Nubareya city-Beheira Governorate 108 Table 3-34: Analysis results of air samples collected from site (48), Alexandria Governorate ...... 109 Table 3-35: Analysis results of air samples collected from site (44), Adabeya port-Suez Governorate .... 110 Table 3-36: Analysis results of soil samples collected from site (18), Nubareya city-Beheira Governorate112 9

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Table 3-37: Analysis results of soil samples collected from site (23), Nubareya city-Beheira Governorate 113 Table 3-38: Analysis results of soil samples collected from site (48), Alexandria Governorate...... 114 Table 3-39: Analysis results of soil samples collected from site (44), Adabeya port-Suez Governorate ... 115 Table 3-40: Analysis results of water samples collected from site(18),Nubareya city-Beheira Governorate116 Table 3-41:Analysis results of water samples collected from site (23),Nubareya city-Beheira Governorate117 Table 3-42: Analysis results of water samples collected from site (48), Alexandria Governorate 119 Table 3-43: Analysis results of water samples collected from site (44), Adabeya port-Suez Governorate 120 Table 4-1: Hazard of each OP at Beheira Agriculture Directorate site (23) ...... 128 Table 4-2: Mitigation measuresrequired when dealing with each material at Beheira Agriculture Directorate site (23) ...... 140 Table 4-3: Risk identification checklist at Beheira Agriculture Directorate site (23) ...... 163 Table 4-4: Severity scoring guideline ...... 164 Table 4-5: Probability scoring guideline ...... 165 Table 4-6: Risk Matrix...... 165 Table 5-1: Types & Quantities of extermly and highly hazardous obsolete pesticides stored in site (18) . 210 Table 5-2: Types & Quantities of extermly and highly hazardous obsolete pesticides stored in site (23) . 212 Table 5-3: Types & Quantities of extermly and highly hazardous obsolete pesticides stored in site (48) . 212 Table 5-4: Types & Quantities of extermly and highly hazardous obsolete pesticides stored in site (44) . 212 Table 5-5: Distribution of track statement carbon copies and the entity that will be sent to ...... 219 Table 8-1:Names and information of the attendees at the first consultation session ...... 236 Table 8-2: Names and information of the attendees at the second consultation session ...... 251

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 1. THE EXECUTIVE SUMMARY

1.1 PROJECT BACKGROUND

The Egyptian Government obtained a grant from the Global Environmental Facility "GEF" managed by the World Bank to finance the implementation of Sustainable Persistent Organic Pollutants (POPs) Management Project (SPMP). The project is implemented at the partnership of the Egyptian Environmental Affairs Agency (EEAA) according to the Grant Agreement. The Ministry of Agriculture and land Reclamation (MALR) and the Egyptian Ports Authority are the main stakeholders and beneficiaries of this project.

The main objectives of the SPMP project is the identification, classification, prioritization and repackaging as well as safe disposal of the obsolete pesticides (OPs) by incineration either abroad or locally in cement kilns at four sites located in Alexandria, Beheira and Suez governorates. Alexandria (one site (site 48) Alexandria Port), Beheira (two sites in Nubareya (site (18) and (site (23)) and Suez Governorate (one site (site (44)) Adabeya Port).

TAUW (an international consulting company) has been hired in 2017 by SPMP Project to perform the scope of assessment, identification, classification and prioritization, based on POPs content, environmental health assessment, treatment options and costs of high- risk pesticides stored in North Delta Province (Alexandria Governorate & Beheira Governorate) and Adabeya port, Suez Governorate1. While, a specialized international company will be hired to repackage the Obsolete Pesticides (OPs) in safe manner prior transferring by an authorized company for final safe disposal (destruction abroad or in cement kilns in Egypt).

This report covers a full Environmental and Social Impact Assessment (ESIA) study for the impacts associated with repackaging and handling of Obsolete Pesticides from the above mentioned sites as per the guidelines of EEAA and World Bank.

The ESIA study has been prepared by specialized and professional consultants in Egypt.

1.2 PROJECT ACTIVITIES, OBJECTIVES AND JUSTIFICATION: The objective of the project is to prepare Arabic and English ESIA studies for the impacts associated with "repackaging and handling of Obsolete Pesticides from Alexandria port (site 48), Beheira (Nubareya sites (18) & (23)) and Suez Governorate (site (44) Adabeya port). Also, the study includes sites characterization and baseline studies.

1TOR of ESIA Study for identification, classification and prioritization, based on POP content and environmental-health risk of high-risk pesticides stockpiles, at Alexandria and North Delta Province, Egypt. Sustainable Persistent Organic Pollutants (POPs) Management Project (SPMP), June 2019. 11

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez The study was carried out as per the World Bank and EEAA guidelines for ESIA studies.

According to EEAA requirements the study falls within the (C) category which requires preparation of full ESIA study that entails a public hearing session at each site.

1.2.1 The General Approach of ESIA:

Environmental and Social Impact Assessment (ESIA) process is a systematic examination of consequences of the proposed project, aiming to prevent, reduce or mitigate negative impacts on the environment, natural resources, health and social elements as well as capitalize on positive impacts of the project.

The purpose of ESIA is to ensure the protection and conservation of the environment and natural resources including human health aspects.

Environmental and Social Impact Assessment (ESIA) is a comprehensive document of a project's potential environmental and social risks and impacts.

As ESIA is usually prepared for projects that are likely to generate significant environmental or social impacts.

The key process element of ESIA generally consists of:-

• Initial screening of the project and scoping of the assessment process. • Analysis of project's alternatives. • Stakeholder identification and gathering of environmental and social baseline date. • Impact identification, prediction and analysis. • Analysis of potential environmental and social impacts and evaluation of residual impacts. • Generation of mitigation or management measures and actions (ESMP). • Incorporates the results of the public consultation. • Documentation of the assessment process.

1.2.2 Environmental Legislation and Institutional Framework:

Environmental issues in Egypt are governed by several regulatory requirements and policies in accordance with Egyptian laws. The national policies, strategies, acts and the institutional framework as well as international conventions and treaties that underpin the management of Obsolete Pesticides were taken into account in developing this ESIA.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez The following are some of the key policies that are relevant to ESIA: Egyptian Environmental law 4/1994 amended by law no. 9/2009, Environmental impact assessment executive regulations, Hazardous Wastes Regulations, law 48/1982 Regulations, law 48/1982 amended executive regulations with decree 92/2013, law 93/1962 amended by decree 44/2000 for discharging to public sewer, Agricultural laws & Ministerial Decrees related to pesticides decree 630/2007, Ministry of Manpower law (law 137/1981).

In addition, the World Bank Environmental policies that are applied to this activity, particularly, OP 4.01 on "Environmental Assessment" as well as World Bank Environmental Health and Safety Guidelines (EHSG) are included in this chapter.

The World Bank Environmental Assessment Strategy in which the Bank adopted Operational Directive (OD) 4.00, “Annex (A): Environmental Assessment.” (EA) became standard procedure for Bank financed investment projects. In 1991 the directive was amended as OD 4.01. It is in the process of conversion to an Operational Policy, OP 4.01. EA is designed to be a flexible process that makes environmental considerations an integral part of project preparation and allows environmental issues to be addressed in a timely and cost-effective way during project preparation and implementation. The primary responsibility for the EA process lies with the borrower. The Bank’s role is to advise the borrower throughout the process, to confirm that practice and quality are consistent with EA requirements, and to ensure that the process feeds effectively into project preparation and implementation.

In addition to policy and legal instruments, some regional conventions were taken into account: Bamaco convention on the ban of the import into Africa and the control of trans- boundary movement & management of hazardous wastes within Africa, it was signed by Egypt in 30/1/1991, entered into force in 12/5/1994 and ratified in 15/5/2004.

The international conventions that were taken into account include the Basel Convention for the Control of Trans boundary Movements of Hazardous Waste and their Disposal (1989), The Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade (Egypt did not ratify this convention till now); and the Stockholm Convention (2001) on Persistent Organic Pollutants (POPs)2.

2 Environmental and Social Impact Assessment (ESIA) for the Disposal of Obsolete Pesticide Stockpile in Al- Adabeya Port, Suez - Egypt. Alexandria University 2014. 13

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 1.2.3 Project Activities Overview:

The total amount of Obsolete Pesticides (OPs) in the four sites selected for this study, site (48) in Alexandria port, sites (18) & (23) in Nubareya city and site (44) in Adabeya port is about 94.118 tons. These sites have been in use for many years which may adversely affect human health and the surrounding environment as some of them are located in close-by residential areas. These OPs should be removed and disposed in a safe manner as soon as possible to reduce the risks that arise from these pesticides.

The project will support the identification of all high risk stored Obsolete Pesticides (OPs) involving the handling and repackaging of these hazardous pesticides.

This proposed project involves the handling and packaging of these hazardous stockpiled pesticides. While the transporting and disposal, as well as the remediation of the site contamination, if required, activities are not included in this study, upon the agreement with the Sustainable Persistent Organic Pollutants (POPs) Management Project (SPMP).

The main aim of the ESIA is to put a decision-making tool for environmentally sound management of obsolete pesticides stockpiles existing in North Delta Province (Alexandria and Beheira Governorates) and Suez Governorate.

1.3 METHODOLOGY OF THE ESIA:

1.3.1 Data Collection and Consultations:

Data collection and baseline data provide the foundation for predicting the impacts of project, designing appropriate mitigation measures and Environmental & Social monitoring plan. Data collection was carried out including literature review, desk research, project document, extensive consultations with the Sustainable Persistent Organic Pollutants (POPs) Management Project (SPMP) and other stakeholders and from information collected during site visits and baseline studies.

A reputable certified Laboratory analysed all site indoor and outdoor different samples of each site including air, soil and water samples.

The consultant was reviewing all previous qualitative and quantitative data in addition to the results of the baseline measurements to prepare the impact interaction matrices in order identify, prioritize and develop mitigation plans.

The following activities were undertaken in preparing the ESIA:

• Baseline survey including the following : - Data related to the obsolete pesticides in the sites under study. - Causes of accumulation as identified by previous studies and stakeholders - Previous waste management related to pesticide disposal initiatives. 14

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez - Socioeconomic survey to define people's living standards. - Community land, assets, cultural property, ecosystem services and affected persons. - Review of policies, legal and institutional framework, included national waste management legislation, EIA guidelines and regulations, World Bank environmental assessment strategy and other related regional and international conventions. • Visiting the selected sites including comprehensive discussions with officially responsible persons. • Environmental sampling and analysis (related to air, soil and surface water near by the sites). • Hydrogeological and weathering studies for each site. • Public consultation sessions. • Analyses of alternatives, several options were discussed to the project for the disposal of obsolete pesticides and wastes contaminated with pesticides either inside or outside Egypt3.

1.3.2 Development of Environmental and Social Management Plan (ESMP):

The Environmental and Social Management Plan (ESMP) including mitigation measures and institutional arrangements are described to ensure that undue or reasonably avoided adverse impacts of the project are prevented or minimized and all the positive benefits of the project are enhanced and all the mitigation measures are clearly defined and implemented through all the stages of the project.

The ESMP includes formulation of the mitigation measures for each risk category. This will also include establishing performance indicators for monitoring the implementation of the mitigation measures.

The ESMP is considered to be a tool that will allow the Sustainable Persistent Organic Pollutants (POPs) Management Project (SPMP) teams to identify the risks associated with their proposed safeguarding and disposal strategy and present the mitigation measures which will be adopted to minimize the potential impact of those risks on human health and the environment.

3 Persistent Organic Pollutant Disposal Technology for the Global Environment Facility, Scientific and Technical Advisory Panel (STAP) of the Global Environment Facility (GEF) by Richard J. Cooke (Man-West Environmental Group Ltd.) and William F. 15 Carroll. November 2011.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 1.3.3 Roles and Responsibilities for the Implementation of the ESMP:

• Contractor responsibilities: The contractor who is going to remove the OPs from the sites under study shall: - Submit a health and safety plan including all mitigation measures delineated in the ESIA study. - Appoint an Environmental Expert to be responsible for execution of the ESMP and the Mitigation Measures including the Health and Safety Plan and to monitor the on-site compliance with the ESMP. - Responsible to purchase all required PPE and tools required for the implementation of the ESMP.

• PMU responsibilities: The PMU shall appoint a Project Manager of adequate experience in similar projects to supervise all operations including the implementation of the ESMP and Mitigation Measures. A periodic report shall be submitted to the PMU for review and assuring the compliance.

1.4 Description of the Project Areas: Four different sites were covered in four different areas. Two of them are located in Nubareya City, Beheira Governorate, one site is located in Alexandria port, Alexandria Governorate and one site is located inside Adabeya port, Suez Governorate.

A Quantitative Risk Assessment (QRA) for the sites subject to this study was conducted; it includes the effect of these sites on community and surrounding environment in order to determine the best mitigation measures required to reduce the associated risk during operations. These measures were represented to attendees of the surrounding local community representatives during the public consultation sessions to take their opinion of in implementing these measures. Also, the benefits of this project were mentioned as obsolete pesticides and POPs will be repackaged and disposed in a controlled and environmentally sound manner. Therefore the potential impacts of this activity will be negligible after implementation of mitigation measures (as illustrated in the QRA – Residual Risk Evaluation).

1.4.1 Site (18) Nubareya City, Beheira Governorate:

This site belongs to the Directorate of Agriculture for the New Lands in Nubareya – Ministry of Agriculture and Land Reclamation (MALR). Site (18) contains about 44 tons of obsolete pesticides stored since 2011. The site is a large complex which is currently used as a garage & warehouse for some equipment. The site is surrounded by a brick wall and has large metallic gate for car entry and exit, in the complex there are six stores each

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez has an area of 30 m2 where OPs are stored since 2011. This site is surrounded by a residential area from North, East and West directions as shown in figure (1-1).

This site is located near a residential area but it is fenced and entrance to and exit from this site is controlled. Therefore, the procedures and impacts related to the repackaging activity will be under control. (Reference to residual risk evaluation –QRA study).

Figure (1-1): The surrounding area for site (18), Nubareya City, Beheira Governorate

1.4.2 Site (23) Nubareya City, Beheira Governorate:

This site also belongs to the Directorate of Agriculture for the New Lands in Nubareya– the Ministry of Agriculture and Land Reclamation. This site contains about 5.5 tons of obsolete pesticides including those transferred from sites (24) and (25) which are also located in Nubareya.

The area of this site is about 12 m2 and is mainly surrounded with agriculture land as shown in figure (1-2).

The location of this site is relatively away from the residential area but it lies near an agricultural area. Also, it is fenced and entrance to and exit from this site is controlled.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Therefore, the procedures and impacts related to the repackaging activity will be under control. (Reference to residual risk evaluation –QRA study).

Figure (1-2): The surrounding area for site (23), Nubareya City, Beheira Governorate

1.4.3 Site (48) Alexandria Port, Alexandria Governorate

This site (Al-Halk & Al-Bayou Building) is located in the Eastern area inside Alexandria Port. The building consists of a ground and four upper floors each with 2850 m2 area, obsolete pesticides are stored randomly in the first and third floors with a total amount of

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 7 tons. They are stored directly on concrete floor with other various goods. The ventilation is provided only through open windows in each floor.

Al-Halak & Al-Bayoua Building is considered the boundary between Alexandria port and the surrounding area, from the Eastern side there are two schools located outside the port boundary at about 15-20 meters far from the building as shown in figure (1-3).

This site is relatively away from the residential area.

Figure (1-3): The surrounding area for site (48), Alexandria Port, Alexandria Governorate

1.4.4 Site (44) Suez Port, Suez Governorate:

This site is a 40 cubic foot container located in the container storage yard in Adabeya Port, Suez Governorate and it is away from any residential areas. This container contains

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez about 7.3 tons of obsolete pesticides stored since 2008, a pungent odor resulted from opening the container during the site visit. Site (44) is mainly bordered by various storage areas which are located inside the port as shown in figure (1-4).

Figure (1-4): The surrounding area for site (44), Adabeya Port, Suez Governorate

A Quantitative Risk Assessment (QRA) for the sites subject to this study was conducted, it includes the effect of these sites on community and surrounding environment in order to determine the best mitigation measures required to reduce the associated risk during operations. These measures were represented to attendees of the surrounding local community representatives during the public consultation sessions to take their opinion of in implementing these measures. Also, the benefits of this project were mentioned as obsolete pesticides and POPs will be repackaged and disposed in a controlled and environmentally sound manner. Therefore the potential impacts of this activity will be negligible after implementation of mitigation measures (as illustrated in the QRA – Residual Risk Evaluation).

1.5 Assessment of Potential Impacts (Positive and Negative):

Potential direct and indirect of environmental and social impacts during handling and repackaging of the obsolete pesticides are identified to analyze the interaction between the various project stages and the environmental, social and economic components.

The main impacts of the project will be on workers’ health due to inhalation of gases that are released from the obsolete pesticides leaked from the deteriorated bags and the

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez pungent smell when the door of the container is opened. These impacts will affect the workers in case of non-compliance with the implementation of safety procedures and in case of non-commitment to wear the recommended personal protective equipment (PPE).

The surrounding environment (Plants, animals, air quality and ground water) may be also negatively affected during handling and repackaging of obsolete pesticides in case of non- compliance with the implementation of mitigation measures. Human public health may be negatively affected in case of fire or emergency situations.

The sites survey results indicated that the site workers and supervisors are the only persons who have direct exposure to any risks associated with the stored obsolete pesticides. The current care takers and site workers mentioned that they encounter a pungent pesticides smell whenever they come closer to the doors of the stores or container.

The project will have several positive impacts which can be summarized as follows:

• Safe disposal of obsolete pesticides by implementation of the proper management procedures according to the International and Egyptian environmental laws and regulations shall relief the area and the surrounding from the associated risk of the OPs existence. • Eliminate health effects of the exposure to obsolete pesticides especially in the workplace at each site. • Improve workers security at work environment after removing the OPs. • Improve the work conditions at the site, reduce the occupational health hazards on workers at the sites and reduce any effect on public health in residential areas around the sites.

1.6 Proposed Mitigation Measures and Environmental and Social Management Plan: The Environmental and Social Management Plan (ESMP) is a tool used to ensure that any negative impacts generated during different phases of the proposed project are prevented or minimized and that all positive benefits of the project are enhanced. ESMP covered all aspects related to the handling and repackaging until final disposal options local/ international) of the obsolete pesticides including compliance with relevant national and international regulations.

Several mitigation measures are recommended to be implemented during each stage of the project and after completing the project to minimize or eliminate any possible adverse

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez impact on the workers’ health or surrounding environment to comply with the environmental laws and regulations in order to ensure the sustainability of the project.

The Environmental and Social Management Plan (ESMP) is shown in the following table (1-1).

An integrated monitoring plan has been suggested to check the benefits resulting from implementing the mitigation measures and address any new problems which may occur during implementation. Plans for monitoring have been included in the ESMP showing the assigned responsibilities for monitoring activities and can be summarized in table (1- 2).

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Table (1-1): POPs Obsolete Pesticides – Environmental and Social Management Plan Phase Targets Mitigation Measures Institutional Responsibility • Inform the residents in the areas surrounding the sites under study in advance on not to be close to the sites during project implementation .

• Establish temporary guidelines agreed with local agricultural - Project Management unit authorities and community in sites (18 & 23) at Nubareya city to Protect public health prohibit planting of vegetables or livestock garaging around the - Agricultural directorates for people in the sites during project implementation. Before surrounding area • Place barriers and warning signs around the sites indicating not - Egyptian Environmental Starting outside the site trespassing zones. Affairs Agency Project Phases (residential and service • Keep public and routine workers around the site under study aware - Local health facilities units) and routine with all possible health hazards upon exposure to these pesticides workers in site and how to minimize the risk and their quick response procedures in case of accidents (fire or spillage) during project implementation.

And how to file a complaint in case of exposure to bad offensive order or any other environmental problem during project. • Provide first aid measures and medical care services to deal with injuries resulting from exposure to pesticides.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Phase Targets Mitigation Measures Institutional Responsibility

• Fencing the proposed sites with hazard tape. • Place warning signs to keep non responsible people away from the sites. • The site should be equipped with water showers or water tabs to use for washing in case of exposure of any workers to pesticides. In case of unavailability of water source on site a tank contains between 200- - Project Management unit 500 liter of water should be then available on site. - Site • Protection of • Remove any obstacles that prevent entrance and exist of the sites. Agricultural directorates • Prepare evacuation plan and emergency response plan for each site. prepar workers in the - Egyptian Environmental • Place spillage barriers to prevent spreading of pesticides in case of ation proposed sites. Affairs Agency before spillage. starting • Protection of • Work zones should be covered from top with heavy duty plastic - Local health facilities sheets as a ceiling to prevent dispersing dust or vapors of pesticide the surrounding project to the surrounding air during repackaging also, floors should be - Contractor environment & equipped with barriers to prevent pesticides spreading in case of implem - Firefighting department. entatio public health. spillage. n stages • Availability on site of absorbing materials suitable to absorb any spilled liquid pesticides. • Each site should be equipped with fire protection and firefighting equipment such as powder and CO2 Extinguishers alarm device and sand pickets. • Each site should have first aid kits required for use in case of emergency and accidents. • Presence of personal protective equipment and respiratory makes.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Phase Targets Mitigation Measures Institutional Responsibility • The specialized team who will conduct the verification stage should wear PPE (level B). - Egyptian Environmental • Availability of first aid kits in each site. Affairs Agency. • Notify project's workers with the nearest hospital or medical clinic. • Inform the neighboring community and routine workers present in - Contractor. the sites with the start date of this stage and ask them to keep away from the sites locations. - Local health facilities. - Trained team from • Review the EEAA. conditions of the - POPs Project officer. Verific existing pesticide ation - Hazmat officer (in case containers to decide phase the sites are located in which of them needs ports). repackaging. - Port police (in case the sites are located in ports). - Maritime transport officer (in case the sites are located in ports). - Port authority (in case the sites are located in ports).

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Phase Targets Mitigation Measures Institutional Responsibility • Train project workers on type of hazard expected from exposure to pesticides, how to use properly the personal protective equipment and safe handling of pesticides during packaging. - Egyptian Environmental Affairs Agency. • Explain to workers detailed procedures which should be followed during repackaging which will include: - Contractor. - Site preparation before work start. - Dividing the site into zones depending on the degree of hazard. - Local health facilities. - Methods of repackaging of obsolete pesticides. - Trained team from - Post labels including all required information about the EEAA. pesticides to be repackaged and prepare records for the • Protect health and pesticides to be disposed. - POPs Project officer. safety of workers - Use of personal protective devices and respiratory masks. - Ensures workers uniform to be kept at site and decontaminated - Hazmat officer (in case Repackagi during repackaging. after finishing the work. the sites are located in ng stage ports). • Conduct medical examination before and during the implementation stage (monthly) and after completion of the project, they will - Port police (in case the include: sites are located in ports). - Chest X- Ray. - Blood pressure monitoring. - Maritime transport - Complete blood analysis. officer (in case the sites - Sugar analysis. are located in ports). - Liver and lungs function. - Skin examination. - Port authority (in case • Inform the project workers with the nearest hospital or medical the sites are located in clinic in the surrounding area to go to in case of emergency. ports). • Inform the project workers with the potential risks due to exposure to obsolete pesticides and train them how to use PPE and how to apply safe handling methods during repackaging phase.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Give the workers a detailed explanation about the procedures that should be followed during repackaging phase which includes the following: - Preparation of the sites before starting the project. - Divide each site into 3 zones depending on the degree of hazard (dirty zone, intermediate zone & clean zone). - How to apply safe handling methods during repackaging stage. - Place labels showing information about repackaged pesticides and prepare registers for the pesticides stockpiles that will be disposed. - How to use PPE and respiratory masks. - Keep the workers clothes clean and not contaminated with pesticides. • Conduct regular medical checks for workers before, during project implementation stage (on monthly basis) and after completion of the project, they will include: ▪ Chest X- Ray. ▪ Blood pressure monitoring. ▪ Complete blood analysis. ▪ Sugar analysis. ▪ Liver and lungs function. ▪ Skin examination. • Inform the project workers with the nearest hospital or medical clinic in the surrounding area to go to in case of emergency. • Prevent • All repackaging works to be implemented at the designated and - Egyptian Environmental volatilization, wind protected area (well paved or lined platforms, under temporary Affairs Agency. dispersion, spillage water proof roof, with spills- leakage barriers ) and only within the - Contractor. and leaks during perimeters of sites. - Local health facilities. repackaging and • Limit works under strong winds and rain fall conditions. - Trained team from EEAA.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez loading and prevent • Collect and pack all wastes and used contaminated supporting - POPs Project officer. contamination of materials in double containment. - Hazmat officer (in case the approved packaging • Decontaminate all equipment and double parts to be used in other sites are located in ports). materials. site before transportation. - Port police (in case the • Avoid surface contamination of approved packing materials, sites are located in ports). equipment (lifting, pumping …etc.). - Maritime transport officer • Keep the repacked bags stock & barrels out of contaminated areas and put them on wooden pallets. (in case the sites are located in ports). - Port authority (in case the sites are located in ports). Loading of • Prevent spillage or • Training of workers on safe loading and handling procedures. - Egyptian Environmental pesticides on spreading of • The following procedures will be conducted in case of loading Affairs Agency. trucks pesticides to the repackaged OPs in containers: - Contractor. surrounding area. - Local health facilities. • Avoid fires and ▪ Cover the floor of each container with PVC sheet then put a 15 - Trained team from EEAA. accidents. mm thickness of absorbent layer (sand). - POPs Project officer. ▪ Jumbo bags and drums will be laid on two levels on wooden - Hazmat officer (in case the pallets inside the containers. ▪ Strap the barrels & jumbo bags to be balanced inside the sites are located in ports). container. - Port police (in case the sites are located in ports). - Maritime transport officer (in case the sites are located in ports).

- Port authority (in case the sites are located in ports).

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Avoid accidents • Trucks should be well maintained and equipped with all safety Egyptian Environmental during devices (fire extinguishers, first aid kits, PPE, absorbent materials... Affairs Agency. transportation. etc.). - Contractor. • Avoid spills or • Place warring sign on the trucks to indicate the hazardous effect and - Local health facilities. spread of pesticides how to deal with it in case of emergency. - Trained team from EEAA. to the surrounding • The size of trucks should be suitable for the quantity of pesticides to - Project Management unit. environment. be transported. Transpor- • Protect the • Check safety of trucks prior loading. - Traffic police. tation and surrounding • Truck drivers should be aware of first aid, firefighting and how to - Hazmat officer (in case the temporary environment from deal with pesticides in case of emergency. sites are located in ports). storage in the negative impacts • In the case of transport within the ports: The truck speed should not - Port police (in case the of pesticides. ports exceed 40 km/h, with choosing the shortest and most suitable route. sites are located in ports). • The floor of the storage area shall be made of a chemical-resistant - Maritime transport officer material. (in case the sites are • The storage area should be free from any flammable materials and located in ports). away from any electrical cables. - Port authority (in case the • The storage area should be close to the health and safety facilities in the port. sites are located in ports). • Training the workers on the safe handling and transporting procedures.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Table (1-2): POPs Obsolete Pesticides – Monitoring before, during and after implementing the project:

How When Parameter Why Cost Responsibility Where Is the parameter Is the parameter Phase To be to be monitored/ to be monitored – Is the parameter to Is the parameter monitored type of frequency of be monitored to be monitored? Install Operate Install Operate monitoring measurement or (optional)? equipment continuous? ● Soil quality ● Soil (in the vicinity ●Chemical analysis ● Before start of ● To establish baselines ● Contractor, ●Contractor, ● Air quality of pesticide stores) ●Medical works. against which impacts ●Centre of ● Surface ● Air (inside & examination and can be measured Preventive Medicine ●Centre of water outside warehouse) blood tests ● Environmental Preventive ● Water (near the Inspection Medicine Before Project ● Health status warehouse) ●Environmental Implementation of workers ● Health monitoring Inspection ● Health status (at working place and of vulnerable near the warehouse) public groups

● Air quality at ● Air monitoring ● Chemical ● Air quality (weekly) ● To check on potential ● Contractor, ● Contractor, working place (inside and near the analysis ● Occupational health environmental ● Centre of ● Centre of ● Health status pesticide stores). ● Medical (monthly) dissipation of Preventive Medicine Preventive Medicine During Project of workers and ● Health monitoring examination and ● on-site inspection pesticides. ● Environmental ● Environmental (at working place) blood tests (weekly) ● To ensure the Inspection Inspection conformity of Implementation ● Onsite inspection occupational health are works applied. ● To ensure compliance with safety rules. ● Soil quality ● Soil (in the vicinity ● Chemical ● Annually (at least ● To ensure compliance ● PMU ● PMU After Project ● Air quality of pesticide stores) analysis twice after with safety rules. ● Air (inside & evacuation) Implementation ● Surface water outside warehouse) (Decommission) ● Water (near the

warehouse)

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez A detailed quantitative Risk assessment study (QRA) has been prepared for each site including the interaction matrix of the impact analysis. The study was conducted by a specialized consultant, the results of the study is shown in section (4) of this report. The ESIA study also included an emergency plan and occupational health and safety procedures to respond and mitigate any possible incident or impact on workers, society and surrounding environment as shown in section (4). The plan will also include how to evacuate the sites in emergency situations and take all necessary measures to secure the safety of workers facilities and property as well as the surrounding environment. Workers will be trained to implement the plan and react in case of emergency.

1.7 Analysis of Alternatives:

Several alternatives have been proposed for safe handling and disposal of obsolete pesticides in the study. These alternatives have been extensively discussed with the stakeholders during the public consultation sessions besides the discussions that took place during the project preparation. One of these alternatives is incinerating the obsolete pesticides in local cement kilns, which perform such process in Egypt according to the National and International requirements and possess the permits from EEAA for such activity as they have the pollution control equipment which is required to deal with gaseous emissions released during incineration processes. The second alternative is the trans-shipment of the obsolete pesticides to another country for final destruction as this method is the most widely used in developing countries. Other alternatives have been discussed such as: chemical treatment, landfilling …etc. However, incineration either in local cement kilns or by trans-shipment to another country for final destruction are the two preferable methods for ultimate safe disposal of obsolete pesticides.

1.8 Public Participation and Consultation:

A series of specific consultation meetings were held among the scope of this study; these meetings included:

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Several meeting were held at the four project sites in order to know the current situation in each site such as: its location, quantity & types of the stored pesticides, the storage period…etc. And to know the opinions of the nearby residents of each site and the general workers in the ports about the presence of these pesticide stores located in their surrounding area as well as their opinions towards implementing this project. • A public hearing was held at each site (4 hearings) after preparing the study draft; the details of each session are included next.

During each of these sessions, representatives from Sustainable Persistent Organic Pollutants Management Project (SPMP), site officials (administration staff, site guards, environmental & safety officials at the sites), Regional branches offices of EEAA and residents from the surrounding . Also, Site visits were conducted in each site separately.

Thre Public consultation sessions were held for the project “Repackaging of obsolete pesticides stored on sites under study as follows:

• The first session: A public consultation session for the sites of the North Delta region (Beheira and Alexandria) was held on 24/12/ 2019 at the Hilton Ramada - Sidi Beshr - Alexandria Governorate.

• The second session: A public consultation session for sites (18 and 23) located in the Agricultural Directorate Compound of Noubareya - Beheira Governorate was held on 27/2/2020 at the site. • The third session: A public consultation session for site (44) located in Adabeya port - Suez governorate was held on 19/2/2020 at Adabeya port in Suez Governorate. Further details of the public consultation sessions are described in section (8) of this study.

The main issues discussed during both public consultation sessions were: • Project introduction explaining the project activities, especially the safeguard during the OPs handling • Expected time to execute the project to avoid more negative impacts on workers, public health and surrounding environment resulting from storage of obsolete pesticides. • Commitment to implement all the mitigation measures and requirements necessary to protect workers, public health and the surrounding environment as well as occupational health and safety procedures during implementation of the project phases. • Conducting training programs for officers responsible for dealing with obsolete pesticides issues to get sufficient awareness about its harmful effects on environment and public health. 32

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Determine the types of obsolete pesticides that can be disposed by incineration in the local cement kilns. • The measures that should be followed if any spills occurred during the repackaging process. • The alternatives of the disposal options and recommended ones. • Study the possible reuse of some OPs in other purposes (e.g as insecticide in desert areas of Mosquitos and other insects). The project management invited participant via: • Sending faxes to the invitees (attached are the sent faxes) • Email for each invitee in the project contact list • Telephone calls to all concerned people for attending the consultation session • Follow up through phone calls to confirm attendance. In the first consultation session; the invitations covered NGOs & Community Service (faxes attached) as detailed herein:

• NGOs in Alexandria and Behaira Governorates; they were entrusted to announce the details of the meeting to the societies of concern and to they were tasked with mobilizing the community to attend the session; This was followed up with him via phone calls. • National Council for Women (Alexandria Branch) • Ex – Governor of Behaira Governorate (Mrs/ Engineer Nadia Abdo) ; public figure in the local community • Media representative serving the community (Mrs Omneya Karim)

Women contribution in the session was about 50%; noting three main facts that invited no many women from the surrounding of sites 18 and 23 did not attend, as they are Tribal Arabs their traditions do not allow them to contribute into such activities.

For the second consultation session; the invitations covered NGOs & Community Service (attached) as detailed herein:

• Media and Information Administration – EEAA at Suez Governorate. • The Directorate of Trade and Supply in Suez governorate. • Distance learning hall at Suez Governorate. • Suezbalady Naional Association. • National Council for Women in Suez governorate.

The third and fourth sessions were held on sites at the attendance of people working on site and surrounding communities.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Details of all sessions are included in chapter 8.

1.9 Conclusion and Recommendations:

• The proposed project is considered to be an essential project to protect the workers' health, environment and public health from exposure to hazardous impacts during storage of obsolete pesticides and to comply with the environmental regulations and the international obligations in the framework of the Stockholm convention on POPs.

• By implementing this project, the banned and obsolete pesticides will be repackaged and disposed in an environmentally sound manner by incineration in special incinerators designated for this purpose outside Egypt or by incineration in special cement kilns inside Egypt.

• The potential risks represented by some of the project activities should be carefully considered and effectively managed to comply with international and national legislation related to hazardous wastes and to follow best management practices.

• Contingency and emergency plans should be applied to deal with any spills that might occur during the different phases of the proposed project.

2. LEGAL AND INSTITUIONAL FRAMEWORK:

Handling of hazardous materials and wastes are considered one of the most important environmental problems that are related to the economic, social and legislative aspects. Law No. 4/1994 as amended by Law No. 9/2009 for Environmental Protection and its Regulations have defined a general definition of hazardous materials and waste and obligated any entity concerned with handling the hazardous waste that are prohibited to obtain licenses from the competent administrative authority.

The executive regulations of the environmental Law No. 4/1994 and its amendments by Law No. 9/2009, the environmental and social safeguard policies of the World Bank (Environmental assessment (EA) and Environmental Health and Safety Guidelines (EHSG), in addition to the international legislation of Basel and Stockholm Conventions delineated the requirements for hazardous waste management.

This chapter reviews all laws and regulations applicable to handling, repackaging and disposal of persistent Organic Pollutants (POPs)/Obsolete Pesticides including the ESIA related laws and regulations, in addition to numerous legal instruments dealing with hazardous wastes, chemicals best management. Egypt is also committed to the international conventions, treaties and agreements.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 2.1 National Policies, Strategies and Programs

2.1.1 The National Implementation Plan (NIP) for the Stockholm Convention on Persistent Organic Pollutants.4

Egypt signed the Convention on Persistent Organic Pollutants (POPs) in May 2002, and the Convention entered into force on May 2004. Egypt, as well as other countries, agreed to reduce or eliminate the production, use and/or release of 12 key POPs. Aldrin, Chlordane, DDT, Dieldrin, Endrin, heptachlor, Hexa-chloro-benzene, Mirex, Toxaphene and PCBs beside Dioxins and Furans make the list of those 12 key POPs. The Convention also specifies a scientific review Process that could lead to the addition of other POPs chemicals of global concern. Many of the POPs included in the Stockholm Convention are no longer produced or used in Egypt. None of the intentionally produced pesticides, for example, are now manufactured or registered for use in the country. Egypt is one of the pioneer states, at the regional Arab and African levels, in the field of preparation the National Implementation Plane for Stockholm Convention on POPs.

Egypt has started working on the plane project beginning with July 2003 in fulfilment of the obligation of Stockholm Convention according to Article (7). Preliminary inventories on POPs pesticides, PCBs, unintentionally produced Dioxin and Furans. Consequently, a defined clear overview of these substances (under the convention) throw their life cycle (import, export, transport, distribution and disposal) is given throw the inventories.

The National Pesticides POPs inventory revealed that the country due to the early enactment of Ministerial Decree No. 55/1996 of the Ministry of Trade and Supply and Ministerial Decree No 60/86 of the Ministry of Agriculture has stopped /banned the production/use/export of many organo-chlorine pesticides including all POPs pesticide included in Annex (A) of the Convention. Many other laws and decrees from the Ministries of Environment, Man Power and Immigration, Industry, Health and Population put controls/restriction or outright ban on many hazardous and toxic chemicals. In particular the country’s law 4/1994 amendment with law 9/2009 and its executive’s regulation clearly specifies emission standards for a number of chemicals as part of the air pollution control programme.

2.1.2 The Overall Environmental Law Framework of Egypt5 Egypt has a comprehensive Environmental Framework (law No. 4/1994 dated February, 1994) which addresses the institutional arrangements and mandates for environmental management and protection as well as the substantives rules and principles governing among other items:

• Land pollution control; 35 4 Implementation of the Stockholm Convention, National Implementation Plan - July 2005.Egypt

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Materials and toxic waste; • Air pollution control; • Water pollution control; and • Penalties and the associated enforcement-related provisions.

Law 4/1994 was further implemented through Decree No. 338 dated February 18, 1995 issuing the Executive Regulations of Environment law No. 4/1994. Decree 338 has further clarified the roles of the various institutions involved in environmental management and protection and the processes to develop environmental norms, standards and regulations for water pollution control; air and atmospheric pollution including air quality monitoring; and hazardous substances.

Air pollution related articles:

Article 35 of the law:

The facilities subject to the provisions of this law shall be committed in the exercise of their activities not to emit or leak air pollutants beyond the maximum limits allowed in the laws and decisions in force and what the executive regulations of this law specify.

Article 43 of the law:

The owner of the establishment shall take precautions and measures necessary for the no leakage or emission of air pollutants within the workplace except within the permissible limits determined by the executive regulations of this law, whether due to the nature of the establishment's practice of its activity or faults in the equipment. Occupational safety and health, including the selection of suitable machinery, equipment, materials and fuels, taking into account the duration of exposure to these pollutants and ensuring adequate ventilation, flue installation and other air purification.

Article 44 of the law

The owner of the establishment shall take the necessary measures to maintain the temperature and humidity within the workplace, not exceeding the maximum and the minimum permitted. In the case of the necessity of working in temperatures or humidity outside these limits, he shall ensure the appropriate means of protection for workers of special clothing and other means of protection. The executive regulation of this law shall specify the maximum and minimum temperature and humidity levels, Decree 338/1995 was later amended through Decree 495/2001, dated April 14, 2001 and a 2005 Prime Minister’s Decree 1741 which clarified provisions related to, among other provisions, EIA, oil pollution control, hazardous substances and waste and prohibited discharges. Law No. 4 was later amended by law 9/2009 which included additional provisions on hazardous substances and wastes (Article 33), destruction of solid waste,

5 Arab Republic of Egypt, Safeguards Diagnostic Review For Piloting the Use of Egyptian Systems36 to Address Environmental Issues in the Proposed GEF-Financed Egypt Sustainable Persistent Organic Pollutants (POPs) Management Project (P116230), Equivalence and Acceptability Assessment Report, DRAFT # 5, January 2014. English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez clarification of procedural aspects of the EIA (Article 19 - 21), and certification by the Egyptian Environmental Assessment Agency (EEAA) of environmental consultants and consulting firms (Article 13). After the adoption of law No. 9/ 2009, some provisions of the Decree 338/1995 as amended by Decree 1741/ 2005 are being reviewed and modified with Decree 1095/2011.6

Other sectorial laws which may apply to the handling of pesticides and POPs include: (i) Law 38 of August 28, 1967.

(ii) Law 59 on the Protection Against Risks of Ionizing Radiations and its implementing Regulations on Use of Ionized Radiations on Public Cleanliness.

(iii) Law 53 of September 28, 1966 as amended by law 16/1993 on Agriculture

(iv) Law 66 of August 14, 1974 as amended by law 155/1999 on Road Safety.

❖ Regulations of the Environment Law:

In Article (25), handling hazardous materials and wastes is strictly prohibited only if licensing used by the competent authority set forth in relation to each of these substances and wastes and their uses as follows:

1. Hazardous agricultural materials and wastes, including pesticides and fertilizers - Ministry of Agriculture. 2. Industrial Hazardous Materials and Waste - Ministry of Industry. 3. Hazardous materials and waste for hospitals, pharmaceutical, laboratory and 6 Web site: www.eeaa.gov.eg household insecticides - Ministry of Health. 4. Petroleum Hazardous Materials and Waste - Ministry of Petroleum. 5. Hazardous materials and wastes which are issued by ionizing radiation - Ministry of Electricity - Atomic Energy Authority. 6. Hazardous and explosive materials and wastes - Ministry of the Interior. 7. Other Hazardous Materials and Waste - The competent authority issuing the license shall issue a decision by the competent minister in charge of environmental affairs based on the presentation of the executive head of EEAA. Also, each minister of the ministries mentioned in this article shall issue, within the scope of his competence, in coordination with the Minister of Health and the Environmental Affairs Agency, a schedule of hazardous substances and wastes specifying: a. The quality of the hazardous materials and wastes that fall within the scope of the ministry's jurisdiction and the degree of seriousness of each. 37

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez b. Controls to be taken into account when trading each. c. Method of disposal of empty containers for those materials after circulation. d. Any other controls or conditions the Ministry deems important to add.

2.1.3 Hazardous Waste Regulations.7

Egyptian pollution abetment project (EPAP) published in July 2002."Hazardous Waste Management Manual". The manual encouraging the industrial sector in Egypt to take practical steps towards the proper management of its hazardous waste was deemed necessary. This is with the aim of helping it fulfil its legal obligations, and minimizing the adverse effects of such waste on public health and the environment. In this respect, this manual is prepared to be a user-friendly guide with the overall objective of providing the Egyptian industries with necessary information and basic tools for hazardous waste management. This would offer assistance to the industrial establishments in recognizing hazardous waste management needs, and taking the necessary steps towards addressing these needs. Within this context, one other objective of this manual is to promote the environmental performance of the Egyptian industries by presenting means for self-assessment concerning hazardous waste management. Such means are prepared so as to enable the industries to identify areas of gaps and areas of non-compliance on one hand, as well as opportunities for improvement, on the other. In this regard, the manual addresses the concept of waste minimization, its different options as well as its legal, environmental, and economic benefits.

Summary of Legal requirements for Hazardous Waste Management are as follows:

Table 2-1): Summary of legal requirements for Hazardous Waste Management Legal Requirements Description • Hazardous waste handling licenses must be obtained from the Ministry of Industry. • Industrial establishments must meet the licensing Hazardous waste handling licenses (Article 25, 26,27 - requirements to be granted a trading license. 1 Regulations) • The license shall be issued for a maximum period of five years and can be renewed. • The Entity may cancel the license in cases of violations. Reduce the rate of generation of • The rate of generation of hazardous waste should be 2 hazardous waste at source reduced in quantity and quality. (Article 28.1 - Regulations)

7 Hazardous Waste Management Manual for Industry, Egyptian pollution abetment project (EPAP), July 2002. English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Industrial facilities can use waste reduction options to reduce the rate of hazardous waste generation. • Industrial establishments should have a full Definition and identification of 3 hazardous waste (Article 28.1 - description of the types and quantities of hazardous Executive Regulations) waste generated. • Hazardous waste must be separated from other non- hazardous waste. Hazardous waste separation 4 • Different types of hazardous waste must be (Article 28.8 - Regulations) separated to avoid any undesirable adverse interaction. • Hazardous waste must be stored in designated areas for hazardous waste storage. • Safety requirements for storage areas must be met. Storage of hazardous waste at the • A contingency plan should be available to deal with site of generation 5 potential accidents (Article 28.2-A, B, E- Regulations) • Hazardous waste storage containers shall be made of suitable material and shall be closed to avoid leakage or spillage of waste into the surrounding environment.

Placing warning signs on • Clear signs should be placed on the containers hazardous waste storage indicating the contents of these containers of waste 6 containers. (Article 28.2-C - and know the dangers that may result from dealing Executive Regulations) with them in an unsafe manner. • Hazardous waste must be collected according to a specified schedule to avoid accumulation of waste Hazardous waste collection (Article 28.2-D of the for long periods. 7 Regulations) • If hazardous waste is transported outside the

generating site, it shall be delivered to the authorized hazardous waste transferee only. Treatment of hazardous waste at • In case of treatment of hazardous waste at the site of the site of generation 8 generation, the approval of the EEAA must be (Article 28.1-C - Executive Regulations) adopted on the method of treatment and on the

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez technical specifications of the processing units and the methods of operation.

• Hazardous waste must be transported by a licensed entity only. • Transport vehicles must be equipped with all safety

Hazardous Waste Transport measures. 9 (Article 28.3 - Regulations) • Visible warning signs must be placed on the vehicles to determine the risks of the transported materials. • Drivers must be trained to take necessary action in case of emergency. • The area of the hazardous waste disposal site should be adequate to accommodate waste.

Hazardous Waste Disposal • The disposal site must be equipped with all safety 10 (Article 28.5 - Regulations) requirements. • The site should be surrounded by a brick wall and equipped with more than one entry door. • The facility shall prepare a register of hazardous

Hazardous Waste Register waste with all information on the types and 11 (Article 33 - Regulations) quantities of hazardous wastes generated and disposal methods. • Workers handling hazardous waste should be aware

Training and awareness of the hazards of these wastes. 12 (Article 31 - Regulations) • All relevant personnel must be trained in safe handling of hazardous waste.

2.1.4 Pesticides – Specific Regulations: Concerning pesticides, 2007 was a turning point when the Egyptian Government, The Ministry of Agriculture and Land Reclamation issued the ministerial decree no. 90 of 2007 concerning the regulations of the registration and use of agricultural pesticides in the Arab Republic of Egypt. These regulations were further amended through (i) Decree 630 of 2007, concerning the lists of agricultural pesticide active ingredients that can be registered, reregistered, or banned in the Arab Republic of Egypt , dated May, 2007 and later (ii) Decree 864 of 2008, and (iii) Decree 865, dated June 25, 2009.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez In addition, it includes provisions with respect to the following:

• The applicable regime takes into account the requirements of the U.S. Environmental Protection Agency (USEPA) and/or the European Commission (EC) for the registration of pesticides in Egypt; • The National Commission on Pesticides could add new safe and important pesticide active substances for agricultural production to the List annexed to the Decree No. 30 of 2007; and, • The addition of copper compounds and 41 other active substances to the aforementioned List.

Decree 630 was amended by Decree 864/ 2008 to provide for the following:

(i) Add 16 active materials listed in articles (1) and (2) to Annex (I) of Decree 630/ 2007 on pesticides, which shall be allowed to be registered, imported, circulated and processed in Egypt;

(ii) Entrust the National Commission on Pesticides to issue temporary registration certificates for pesticides;

(iii) Delete carbofuran substance from the Annex I of Decree No.630 of 2007;

(iv) Delete the mark (+) before cyprodinil substance; and

(v) Allow the importation, registration, use, circulation and processing of buminal substance.

Finally, Decree 865/2009 has consolidated the existing provisions and laid down regulations for the registration, renewal of registration and use of agricultural pesticides in Egypt. In addition to this legal and regulatory framework, Egypt has adopted an integrated approach to pest management and developed an implementation program which has been piloted and implemented since 2001 in the major sectors of its agriculture with assistance from FAO and other bilateral donors including Italy. Integrated Pest Management (IPM) seeks to minimize the use of chemical pesticides and is now widely used in Egypt, notably because it is an integrated part of the promotion of export of agricultural products from Egypt to the USA and EU. IPM is now a policy and practice deeply rooted in the agriculture policy framework of Egypt.

2.1.5 Environmental Impact Assessment: On the basis of existing laws and regulations, each prospective POPs-related sub-project must comply with the applicable air emission and wastewater discharge standards and Environmental Impact Assessment (EIA) requirements, prescribed in law 4/1994 (as amended through law 9/2009) and all of its applicable implementing regulations and

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez guidelines including applicable emission/discharge standards. The 2009 EIA Guideline regulations include:

(a) A revised Form “B”;

(b) A detailed description of the EIA report for category “C” projects including:

i. An analysis of alternatives (section 6-4-2-7 of the EIA regulations); ii. Use, as reference, of the Bank’s Pollution Prevention and Abatement Handbook (PPAH) (page 27 of EIA regulations); iii. Requirement for public consultation during scoping and after the preparation of the draft EIA report (section 6.4.3 of the EIA regulations); iv. Disclosure of the EIA report on the EEAA website (section 7 page 36 of the EIA guidelines); and v. Detailed description of the ESMP with associated budget and timing prepared by the proponents (sections 6.4.2.8 page 30 of the EIA regulations)

The current screening Forms for (B) and (C) category projects provide good instruments for screening POPs related subprojects. However, EEAA is advised to further review existing forms to include items specifically related to POPs and Hazardous substances to ensure they are fully covered by proponents. In addition to the existing forms, it is necessary for EEAA to develop and adopt Sector Guidelines (mainly by adapting existing ones issued in 2009) to include specific criteria, processes and standards to be followed in the preparation, review of EIA for POPs projects including hazard risk assessment and guidelines for reviewers. These Guidelines and related checklist will be disclosed on the EEAA website.

Article 19 of the Environment Law 4/1994 and amended by Law 9/2009:

Every natural or legal person, general or private, shall submit the EIA study to the competent administrative authority or the licensing authority prior to the commencement of the project. The study shall be carried out in accordance with the elements, designs, specifications, foundations and quality loads issued by the environment officials in coordination with the competent administrative authorities. And the competent administrative authorities are obliged to provide maps of the industrial zones showing the types of industries allowed according to environmental loads. The executive regulation of this law shall specify the establishments and projects to which the provisions of this article apply.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Article 20 of the Environment Law 4/1994 and amended by Law 9/2009

The competent administrative authorities or the authorizing entity may send the EIA studies referred to in the previous article to the EEAA to provide an opinion on the matter. The Authority may submit proposals to the study provider in the fields of equipment and systems necessary to deal with the negative environmental impacts and ask them to implement them. The EEAA shall provide the competent administrative authority or the donor body with the authority to issue its opinion in respect of this evaluation within a maximum period of thirty Days from the date of receipt or completion of the study or implementation of the proposals. Otherwise, the non-response shall be considered as approval of the evaluation. The project shall commence its activity during the period of the license granted to it to start the activity.

Article 21 of the Environment Law 4/1994 and amended by Law 9/2009

The competent administrative authority may inform the owner of the establishment of the result of the assessment by a written letter with the acknowledgment of arrival. He may object in writing to this result within thirty days from the date of being notified before a committee formed by a decision of the competent minister for environmental affairs. The executive regulations shall determine the terms of reference of this committee and the procedures of the objection and its working procedures.

Article 14 of the Executive Regulations

• A representative from EEAA nominated by the executive head of the agency. • The owner or his representative on behalf of the establishment. • A representative of the competent authority or the donor of the license, if not the competent authority. • Three experts selected for membership of the Committee on the nomination of the Executive Chairman of the Commission. • The committee may form among its members and others subcommittees to study the objections referred to it and submit its report to the committee. It may also seek assistance from those who see it in carrying out its tasks. The committee shall issue its decision within sixty days from the date of receipt of the objection papers.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Article 15 of the Executive Regulations

The Standing Committee for the review referred to in Article (14) of this Regulation shall be competent to consider any objections or objections to the results of the evaluation or to the proposals requested by the EEAA and its opinion on these objections in respect of the controls stipulated in Article (10) of these Regulations. The objection to the EEAA shall be submitted in writing in full of the reasons for the objection and the legal and scientific basis of the owner of the project, and to attach to his objection any documents that he deems objectionable.

Article (19) of the Executive Regulations

The expansion or renovation of an existing establishment shall be subject to the same provisions as provided in Articles 19, 20, 21 and 22 of the said Environment Law. Such expansions or renovations shall change the production pattern of the operating machinery or increase the number of workers beyond the capacity of the workplace or any substantial alterations in the building of the establishment, in particular those related to the ventilation system or changing the work site or otherwise, Harmful effect on the environment or on employees in the establishment. At the request of the EEAA, the competent administrative authority or the licensee may, on its own initiative, revoke the license issued to an enterprise that has not complied with the provisions of Articles 19 and 20 of law 4/1994 or Articles 10 and 12 of the Regulations, The environmental impact of the facility as provided for in those Articles. The contents and procedures for review and approval of an EIA are described in Law 4/1994 as amended through 2009. The EIA, carried out by the project developer, is to be approved by the respective Competent Administrative Authority 8 (CAA) or the licensing authority. A (CAA) cannot issue the license to construct unless the proponent. The CAAs could either be the Governorate within which the project is proposed or a relevant agency or sector ministry (e.g. MALR involved with obsolete pesticides). The CAA will not issue the license to construct unless the operator provides all the necessary permits from the relevant ministries and organizations, which would include a letter of approval by EEAA on either the EIA report.

The letter of EEAA approval is signed by the Chief Executive Officer of the EEAA and the CAA cannot circumvent the EEAA approval as the revised Environment Protection Law of 2009 makes it mandatory that an EIA9 be prepared and approved by the Ministry of the Environment prior to the start-up of the project.

44 8 See Articles 19 to 22 of Law 4 for 1994 for details about CAA’s roles and responsibilities

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez - Licensing Procedures:

The license for hazardous materials and wastes trading may be issued for a maximum period of five years unless there is a need to review the license. The competent administrative authority, as provided for in Article (40) of this regulation, may grant temporary licenses for short periods as required.

The entity or individual wishing to obtain a license to trade hazardous materials and wastes shall submit an application for the following data:

1) The trading of hazardous materials and waste shall include: • Facility Name • Address and Telephone number • Location and area of origin • Contour maps of the site of origin • Ground water level • Safety equipment available in the facility • Insurance information • Program to monitor the environment surrounding areas.

2) The producer of hazardous materials and waste. (Full name, address, telephone and fax number). 3) Full description of the hazardous substances and wastes to be dealt with and the nature and concentration of hazardous elements. 4) Determine the quantity of hazardous materials and waste to be traded annually and describe the method of filling (drums - tanks - Sail).

5) Characterization of the means to be used to store hazardous materials and wastes and storage period each with a commitment to write a clear statement on the packaging to inform the content and the extent of risks and how to act in case of emergency. 6) Clarify the available means of transportation (land, railways, sea, air, inland waters), and determine their routes and timing. 7) A comprehensive statement on the method to be followed in the treatment and disposal of hazardous materials and wastes to be licensed for circulation.

9 According to the current in force legislation and guidelines, an EIA is required to include information on: (a) Description and nature of Project; (b) project title and proponent; (c) location of the project with an outline of the major elements of the surrounding environment which might be affected (Form B and EIA Guidelines require the proponent to submit a map of the area); (d) outline of the Planning and Implementation Program, (e) analysis of any activities involved in the construction/operation which may result in the following: (i) gaseous emissions, (ii) dust, (iii) odour, (iv) noisy operations, (v) night time operations, (vi) liquid effluents/discharges, (vii) traffic generation, (viii) waste and/or by-products generated, (ix) storage/disposal of hazardous goods, (x) disposal of spoiled materials, (xi) visual impact, (xii) risk of accidents resulting in pollution or hazard; (xiii) possible interactions with other projects which should be considered, and (xiv) trans boundary impacts (mentioned in Form B to be filled for Category B Project) and in sectorial guidelines for Category C Project; and (xv) environmental protection measures incorporated in the design and any further environmental implications, including monitoring, beneficial/adverse effects, short45-term/long -term effects, secondary/induced effects, cumulative effects, magnitude and distribution of effects, ability to mitigate adverse environmental consequences via application of the best practical means and best practical environment.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 8) A pledge not to mix hazardous materials and wastes with other types of waste generated by social and productive activities. 9) Ensure that records are maintained that contain a full account of the quantities, types, sources, rates, periods of collection, storage, method of transport and method of processing of the hazardous substances and wastes, with the ease of such data at each request, and not to waste these records five years before the date of commencement. 10) A pledge to take all measures to ensure the proper mobilization of hazardous materials and wastes during the stages of assembly, transport and storage. 11) A detailed description of the emergency plan to face all unexpected circumstances in order to protect the environment and the people. 12) Certificate of previous experience in the field of hazardous materials and waste. 13) Confirmation of the accuracy of the data contained in this document.

- Granting license conditions: 1) Complete all required data and information. 2) Availability of trained personnel for the trading of hazardous materials and waste. 3) Availability of the means, capabilities and systems necessary for the safe trading of these materials. 4) Availability of requirements to address the risks that may result from accidents during trading. 5) The activity to be licensed shall not have adverse effects on the environment and public health.

Since the license is issued for 5 consecutive years and is renewable afterwards, yet, the license donor may revoke or suspend the activity by reasoned decision in the following cases:

1) If the license was issued as a result of submitting incorrect data. 2) If the facility who received the license violates the conditions of the license. 3) If the activity results in environmental impacts that were not anticipated when the license was issued. 4) If developed technology can be applied with easy modifications and lead to the use of a significant improvement in the state of the environment and health of workers. 5) If the opinion of the EEAA concludes that the trading of any such materials and wastes is not proper.

Hence, the donor may request the license applicant to comply with such other conditions as it deems necessary to secure trading in coordination with the EEAA 46

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez and the Ministry of Health. In all cases, an applicant may not trade hazardous materials or waste before obtaining the license, and he shall be in charge of the form prepared for this purpose and the duty to keep it with the trader for submission upon request.

In accordance with the classification of the projects of the EIA guidelines, all projects related to hazardous emission or waste are screened under Category “C” (which would be “A” under the Bank’s OP 4.01 classification for EA purposes. Also as part of the Environment and Social Impact Assessment (ESIA) Report, a risk assessment and emergency plan is required for each project in which the site could pose, inter alia, risks to surrounding populations. The Competent Administrative Authority (CAA) or the licensing authority is required to send a copy of the EIA report prepared by the project proponent to EEAA for its review and approval. The CAA is responsible for not only conveying EEAA’s opinion and comments (approval or rejection) but also responsible for verifying the implementation of EEAA’s recommendations (see Article 20 of Law Number 4 of 1994).

2.1.6 Law 48/1982 Regulations, law 48/1982 amended executive regulations with decree 92/2013: Egyptian Authorities have issued law 48/1982) in order to protect the River Nile and waterways from pollution. According to the law, MPWWR (Ministry of Irrigation, at the time it was issued) is responsible for protecting the quality of Nile water. In this context, the MPWWR issued Decree No. 9/1983 to be the implementer regulations for Law 48/1982.

2.1.7 Law 93/1962 amended by decree no. 44/2000 for discharging wastewater to public sewer.

2.1.8 Law 4/1994 amended by executive regulation no. 1095/2011 for discharging wastewater to sea, Annex (10).

2.1.9 Archaeological Resources:

Egypt is a land where archaeological remains and physical cultural resources are spread all over the country. It has one of the most advance legal frameworks dealing with archaeological finds and protection. Its EIA system provides for assessment of any impact on potential archaeological site. Although POPs known sites are not located on or close to officials, experts and neighbouring communities to establish and verify that any POPs site under the Project is not of archaeological interest. In the event, however, that remains being found any activity will cease and the advice of the Supreme Council of Antiquities would be sought. Appropriate measures would be put in place to protect and/or excavate the remains, including the following procedures: (i) where possible, remains will be protected in-situ; (ii) where identified remains cannot be protected, an 47

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez excavation of the indicated area will be undertaken prior to the commencement of construction activities to record and remove vulnerable remains and features; (iii) any finds of archaeological, historic or cultural significance will be given to the Supreme Council of Antiquities; and, (v) preparation of a Chance Finds Procedure which lays out the steps to be taken if archaeological, historical or cultural remains or finds are discovered during any construction activities. The procedures will clearly set out how the construction team will be briefed so that they are aware of what to look out for and the actions which must be taken should a potential find be uncovered. The incorporation of these precautionary measures into the construction program will ensure that all potential remains of significance are recorded and are accorded the required protection where considered necessary.

2.2 World Bank Environmental and Social Precautionary Policies for ESIA:

In recent years, sustainable development is one of the most important challenges facing many development institutions such as the World Bank. Accordingly, the World Bank has provided many tools for loan and advisory activities and environmental assessment is one of the most important.

The main objective of environmental assessment is to improve the performance of project implementation by reducing or preventing adverse environmental and social impacts that may arise from project implementation.

2.2.1 World Bank Environmental Assessment (EA) Strategy: In 1989, the Bank adopted Operational Directive (OD) 4.00, “Annex A: Environmental Assessment.” EA became standard procedure for Bank financed investment projects. In 1991 the directive was amended as OD 4.01. It is in the process of conversion to an Operational Policy, OP 4.01. EA is designed to be a flexible process that makes environmental considerations an integral part of project preparation and allows environmental issues to be addressed in a timely and cost- effective way during project preparation and implementation. The primary responsibility for the EA process lies with the borrower. The Bank’s role is to advise the borrower throughout the process, to confirm that practice and quality are consistent with EA requirements, and to ensure that the process feeds effectively into project preparation and implementation.

Stage 1: Screening:

To decide the nature and extent of the EA to be carried out, the process begins with screening at the time a project is identified. The project team determines the nature and

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez magnitude of the proposed project’s potential environmental and social impacts and assigns the project to one of three environmental categories.

Category A: a full EA is required. Category A projects are those expected to have “adverse impacts that may be sensitive, irreversible, and diverse” (OD 4.01), with attributes such as direct pollutant discharges large enough to cause degradation of air, water, or soil; large-scale physical disturbance of the site or surroundings; extraction, consumption, or conversion of substantial amounts of forest and other natural resources; measurable modification of hydrologic cycles; use of hazardous materials in more than incidental quantities; and involuntary displacement of people and other significant social disturbances.

Category B: Although a full EA is not required, some environmental analysis is necessary. Category B projects have impacts that are “less significant, not as sensitive, numerous, major or diverse. Few, if any of these impacts are irreversible and remedial measures can be more easily designed” (OD 4.01). Typical Category B projects entail rehabilitation, maintenance, or upgrading rather than new construction.

Category C: No EA or other environmental analysis is required. Category C projects entail negligible or minimal direct disturbance to the physical setting. Typical Category C projects focus on education, family planning, health, and human resource development.

Stage 2: Scoping and Development of Terms of Reference: Once a project is categorized, a scoping process is undertaken to identify key issues and develop the terms of reference (TOR) for the EA. At this stage, it is essential to identify more precisely the likely environmental impacts and to define the project’s area of influence. As part of this process, information about the project and its likely environmental effects is disseminated to local affected communities and nongovernmental organizations (NGOs), followed by consultations with representatives of these groups. The main purpose of these consultations is to focus the EA on issues of concern at the local level

Stage 3: Preparing the Environmental Assessment Report: When a project is classified as Category A, a full scale environmental assessment (EA) is normally undertaken, resulting in an EA report. Category B projects are subject to a more limited EA, the nature and scope of which are determined case by case.

The main components of a full EA report are the following:

Executive summary: A concise discussion of the significant findings of the EA and recommended actions in the project.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Policy, legal and administrative framework: Discussion of the policy, legal, and administrative framework within which the EA is prepared. The environmental requirements of any financiers should be explained.

Project description: A concise description of the project’s geographic, ecological, social, and temporal context, including any offsite investments that may be required by the project, such as dedicated pipelines, access roads, power plants, water supply, housing, and raw material and product storage.

Baseline data: For EA purposes, include an assessment of the study area’s dimensions and a description of relevant physical, biological, and socioeconomic conditions, including any changes anticipated before the project begins, and current and proposed development activities within the project area, even if not directly connected with the project.

Impact assessment: Includes identification and assessment of the positive and negative impacts likely to result from the proposed project. Mitigation measures and any residual negative impacts that cannot be mitigated should be identified. Opportunities for environmental enhancement should be explored. The extent and quality of available data, key gaps in data, and uncertainties associated with predictions should be identified or estimated. Topics that do not require further attention should be specified.

Analysis of alternatives: Assesses investment alternatives from an environmental perspective. This is a key purpose of EA work and the more proactive side of EA— enhancing the design of a project through consideration of alternatives, as opposed to the more defensive task of reducing the adverse impacts of a given design. The Bank’s Operational Directive on Environmental Assessment calls for the systematic comparison of the proposed alternatives for investment design, site, technology, and operations in terms of their potential environmental impacts, capital and recurrent costs, suitability under local conditions, and institutional, training, and monitoring requirements. For each alternative, the environmental costs and benefits should be quantified to the extent possible, economic values should be attached where feasible, and the basis for the selected alternative should be stated.

Mitigation or management plan: The set of measures to be taken during implementation and operation to eliminate or offset adverse environmental impacts or reduce them to acceptable levels. The plan identifies feasible, cost-effective measures and estimates their potential environmental impacts, capital and recurrent costs, and institutional, training, and monitoring requirements. The plan should provide details on proposed work programs and schedules to help ensure that the proposed environmental actions are in phase with construction and other project activities throughout

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez implementation. It should consider compensatory measures if mitigation measures are not feasible or cost-effective.

Environmental monitoring plan: Specifies the type of monitoring, who will do it, how much it will cost, and what other inputs, such as training, are necessary.

Public consultation: Recognized as key to identifying environmental impacts and designing mitigation measures. The Bank’s policy requires consultation with affected groups and local NGOs during at least two stages of the EA process: 1. At the scoping stage, shortly after the EA category has been assigned, 2. Once a draft EA report has been prepared. Consultation throughout EA preparation is also generally encouraged, particularly for projects that affect people’s livelihood and for community-based projects. In projects with major social components, such as those requiring involuntary resettlement or affecting indigenous people, the consultation process should involve active public participation in the EA and project development process, and the social and environmental issues should be closely linked.

Stage 4: EA Review and Project Appraisal Once the draft EA report is complete, the borrower submits it to the Bank for review by environmental specialists. If it is found satisfactory, the Bank project team is authorized to proceed to appraisal of the project. On the appraisal mission, Bank staff members review the Environmental Impact Assessment’s (EIA’s) procedural and substantive elements with the borrower, resolve any outstanding issues, assess the adequacy of the institutions responsible for environmental management in light of the EIA’s findings, ensure that the mitigation plan is adequately budgeted, and determine whether the EIA’s recommendations are properly addressed in project design and economic analysis.

Stage 5: Project Implementation The borrower is responsible for implementing the project according to the agreements derived from the EA process. The Bank supervises the implementation of environmental aspects as part of overall project supervision, using environmental specialists as necessary.

2.2.2 World Bank Environmental, Health and Safety Guidelines (EHSG) (according to International Finance Corporation (IFC)):

❑ Hazardous Materials Management:

In the first chapter, the overall objective of hazardous materials management is to avoid or, when avoidance is not feasible, minimize uncontrolled releases of hazardous

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez materials or accidents (including explosion and fire) during their production, handling, storage and use. This objective can be achieved by: - Establishing hazardous materials management priorities based on hazard analysis of risky operations identified through Social and Environmental Assessment. - Where practicable, avoiding or minimizing the use of hazardous materials. For example, non-hazardous materials have been found to substitute asbestos in building materials, PCBs in electrical equipment, persistent organic pollutants (POPs) in pesticides formulations, and ozone depleting substances in refrigeration systems; - Preventing uncontrolled releases of hazardous materials to the environment or uncontrolled reactions that might result in fire or explosion; - Using engineering controls (containment, automatic alarms, and shut-off systems) commensurate with the nature of hazard; - Implementing management controls (procedures, inspections, communications, training, and drills) to address residual risks that have not been prevented or controlled through engineering measures.

The hazardous Materials Management Plan should address applicable, essential elements of occupational health and safety management, including:

- Job safety analysis to identify specific potential occupational hazards and industrial hygiene surveys, as appropriate, to monitor and verify chemical exposure levels, and compare with applicable occupational exposure standards.

- Hazard communication and training programs to prepare workers to recognize and respond to workplace chemical hazards.

- Provision of suitable personal protection equipment (PPE).

- Monitoring and record-keeping activities, including audit procedures designed to verify and record the effectiveness of prevention and control of exposure to occupational hazards, and maintaining accidents and incident investigation reports on file for a period of at least five years.

❑ Occupational Health and Safety:

The second chapter ensures that employers and supervisors are obligated to implement all reasonable precautions to protect the health and safety of workers. Preventive and protective measures should be introduced according to the following order of priority: - Eliminating the hazard by removing the activity from the work process. - Controlling the hazard at its source through use of engineering controls.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez - Minimizing the hazard through design of safe work systems and administrative or institutional control measures. - Providing appropriate personal protective equipment (PPE) in conjunction with training, use, and maintenance of the PPE.

❑ Transport of Hazardous Materials:

- Projects should have procedures in place that ensure compliance with local laws and international requirements applicable to the transport of hazardous materials. - The procedures for transportation of hazardous materials (Hazmats) should include:

➢ Proper labelling of containers, including the identification and quantity of the contents, hazards, and shipper contact information.

➢ Providing a shipping document (e.g. shipping manifest) that describes the contents of the load.

➢ Ensuring that the volume, nature, integrity and protection of packaging and containers used for transport are appropriate for the type and quantity of hazardous material and modes of transport involved.

➢ Ensuring adequate transport vehicle specifications.

➢ Training employees involved in the transportation of hazardous materials regarding proper shipping procedures and emergency procedures.

➢ Using labelling and placarding (external signs on transport vehicles).

➢ Providing the necessary means for emergency response on call 24 hours/day.

❑ Emergency Preparedness and Response:

It is important to develop procedures and practices for the handling of hazardous materials that allow for quick and efficient responses to accidents that may result in injury or environmental damage. All projects should have an Emergency Preparedness and Response Plan that is commensurate with the risks of the facility and that includes the following basic elements: • Administration (policy, purpose, distribution, definitions, etc) • Organization of emergency areas (command centres, medical stations, etc) • Roles and responsibilities. • Communication systems. • Emergency response procedures. 53

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Emergency resources. • Training and updating. • Checklists (roles & action list and equipment checklist). • Business continuity and contingency.

Community Notification:

If the local community may be at risk from a potential emergency arising at the facility, the company should implement communication measures to alert the community. 2.3 International Conventions and Agreements:

Egypt participates in the United Nations Environment Program (UNEP) and has ratified and or adhered to international environmental conventions with relevance to the POPs issue including: (i) the Convention for the Protection of the Ozone Layer (Vienna Convention) and its Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol),

(ii) the Convention on the Control of Trans boundary Movement of Hazardous Wastes and their Disposal (Basel Convention)10 and (iii) the Stockholm Convention on Persistent Organic Pollutants. As a matter of policy, Egypt supports an approach of coordinated/integrated implementation of the Basel, Rotterdam and Stockholm Conventions11, although it is yet to ratify the Rotterdam Convention.

The above described legal and regulatory framework for POPs management, although fairly well-developed and adequate for addressing the many challenges of POPs management is not consistently applied and enforced. The Acceptability Analysis of Safeguards Diagnostic Review report in 2014 shows clearly that additional actions are needed to make this legal and regulatory framework effective and include (among other measures) the following:

(a) The obligation of periodic registration;

(b) Surveillance and monitoring of POPs related sites and staff working on handling POPs;

(c) The obligation of POPs site and holders to maintain records on nature, quantities, sources, locations, treatment models and transportation models; as well as

(d) The existence of a specific manual to prepare and implement ESIAs.

10Egypt signed the Basel Convention (BC) on the control of Trans-boundary movements of hazardous waste in March, 1989 and ratified it in January, 1993. It has signed in May, 2002 and ratified in May 2003 the Stockholm Convention of the elimination or/and removal of the Persistent Organic Pollutants. Based on information gathered by the World Bank team, Egypt is preparing to adhere to the Rotterdam Convention on the prior informed consent procedure for certain hazardous chemicals and pesticides in international trade which is in force since February 24, 2004 11 The Stockholm Convention was signed by Egypt on May 17, 2002 and ratified on May 2, 2003 54

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez ❖ Basel Convention:

The Basel Convention regulates the trans-boundary movements of hazardous and other wastes and obliges its Parties to ensure that such wastes are managed and disposed of in an environmentally sound manner. Basel Convention proposes and demands export / import/ transit procedures and conditions for hazardous waste.

The Convention controls the Trans-boundary movement of hazardous and other wastes through its provisions for “Prior Informed Consent” (PIC), with a number of steps to be followed by the exporter, importer and any transit State that must be met before any shipment of wastes is permitted, PIC means that imports, transits and exports of wastes that fall under the Basel Convention are only allowed when all concerned Parties have given their consent before the movement is initiated. The procedures form the heart of the Basel Convention control system and are based on three key elements: Notification, Consent and the accompanying Movement Document.

Stockholm Convention Legal Obligations:

Parties to the Stockholm Convention are required to:

• Eliminate the production and use of chemicals listed in Annex (A) of the Convention • Restrict the production and use of chemicals listed in Annex (B) of the Convention • Reduce or eliminate the production of unintentionally-produced POPs listed in Annex (C) of the Convention • Reduce or eliminate releases of POPs from wastes of all chemicals listed in the Convention. • Each Party to the Stockholm Convention should enact enabling legislation and/or administrative procedures to either prohibit or restrict the importation and exportation of POPs in keeping with the obligations of the Convention. • POPs chemicals may be included in a list or schedule of Prohibited and Restricted Imports or Exports, detailing the relevant classification codes/numbers and including a description of the chemical in terms of its proper name and common names as used in trade. • A list of Parties to the Stockholm Convention can be found at the Convention website (www.pOPs.int).

Due to lack of Data regarding the limits of pesticides in soil, water and air in EGYPT we will be using the EPA reference to apply on the region mentioned.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 2.4 Responsibilities: Egyptian Environmental Agency "EEAA": is the authority responsible for: coordination national and sectorial environmental and natural resources management, monitoring and control; environmental inspection and enforcement; environmental standards; implementation of various international obligations; control and compliance enforcement particularly for production, storage, transportation, use, neutralization and burial of toxic and hazardous products and substances and their wastes.

Ministry of Agriculture and Land Reclamation "MALR": monitors and controls compliance with applicable laws, regulations and standards regarding use and management of pesticides and mineral fertilizers; drafts a List of Chemical and Biological Means of Plants Protection and their Growth Stimulations and submits it for the approval by the Republican Inter-agency Council on Testing of Chemical and Biological Means for Plants Protection and their Growth Stimulation.

General Organization for Export and Import Control "GOEIC": Egyptian authority responsible for concurs and control importing, exporting, transportation, use and neutralization of hazardous products and substances, particularly chemical, biological, explosives and flammables.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3. SITES DESCRIPTION

Introduction:

In this chapter, a detailed description for the environmental and social characteristics for the proposed project sites are outlined. There are four sites under study for storage of obsolete pesticides, two sites (18 & 23) are located in New Nubareya City – Beheira Governorate, one site in Alexandria Port, Alexandria Governorate and one site in Adabeya port, Suez Governorate.

The locations of the three governorates are shown on Egypt map, (Figure 3-1).

Figure (3-1): Administrative boarders of project governorates and other Egypt Governorates

3.1 Beheira Governorate: Beheira Governorate is located West of North delta Region and is boarded from North by the Mediterranean Sea, from East by Nile Rashid branch, from West by Alexandria and Matrouh governorates, and from South by Giza governorate. Beheira Governorate is divided administratively into 15 centers (15 cities), 84 village local units and 502 villages distributed in 5980 rural residential communities.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez The area of the governorate is 9,826 Km2, and is surrounded by 6 governorates: Kafr El-Sheikh, Gharbiya, Menoufia, Giza, Matrouh and Alexandria.

Two project sites are located in the New Nubareya City which is located at the Southwest of the Beheira Governorate, as shown in Figure (3-2). The area of the New Nubareya City is 1,816 acres and has a population of approximately 35,000.

Nubaria City

Figure 33-2): New Nubareya City location within Beheira Governorate

3.1.1 Topography: The topography of Beheira Governorate, as shown in figure (3-3), is sloped naturally from South to North and from West to East. The majority of the governorate lands consist of newly formed sedimentary muddy lands from the Nile river silt deposits, while the Northern parts adjacent to the sea coast and lakes formed from marine river deposits.

Details of soil formation in Beheira Governorate are indicated in Annex (1).

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Figure (3-3): Topography Map of Beheira Governorate 3.1.2 Geomorphological Features: The Nile Delta geological formation is due to two opposing processes, the first is the beach progress as a result of the sediments carried by the Nile River and the second is the erosion of sediments and their dispersal due to marine factors.

3.1.3 Hydrogeology: A hydrogeological study was conducted by a specialized consultant for all sites under concern, Full report is attached in Annex (1).

According to this study, the groundwater depth of the wells near sites (18) and (23) is less than 65 m which is designated as shallow wells as shown in figure (3-4).

The same study provides a contour map of the study area, see Figure (3-5), where the ground water depth near sites (18) and (23) is ranging from 12 m to 30 m.

The site authorities confirmed that the underground water depth in the wells at the nearest agricultural area is about 30 meters.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Figure (3-4): Wells locations near to Sites (18) and (23), Nubareya City, Beheira Governorate

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3.1.4 Geologic Sedimentary: The geological structures and description of the geological formation of Nubareya region are shown in Figure (3-6) and table (3-1) respectively.

By plotting the coordinates of sites (18) and (23) on the geological map, it was observed that both sites are located over the Stabilized dunes.

Site 18 & 23

Figure (3-6): The Geological map for Nubareya City, Egypt [The Egyptian Petroleum Corporation].

Table (3-1): Legend of geological formation in Nubareya area, Egypt. Formation Description Sabkha deposits and marsh.

Prenile deposits

Wadi deposits.

Protonile deposits.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Undifferentiated Quaternary deposits. Alluvial fans, wadi deposits, sand, gravel, recent coastal deposits. Stabilized dunes.

Gravel

Sand dunes.

Calcarenite deposits (Alexandria Fm.)

ElHagif Formation.

Gebel El-Ahmar Formation.

Western desert: Gebel Khashab formation (lower miocene). Dark brown continental sand stone locally with pertrified wood. Toward the west grading into moghra Fm.

3.1.5 Soil Characteristics: Soil in Beheira varies between sandy and loamy. The majority of the governorate lands consist of newly formed sedimentary clay soils from the Nile river silt deposits, while the Northern land adjacent to the sea coast and lakes formed from marine river deposits, and the Western and Southwestern lands of the governorate formed from sand carried by wind.

The soil of the project sites in Nubareya is mainly categorized under sandy and medium loamy soil.

3.1.6 Climatic Conditions: Beheira Governorate climate is semi-continental characterized by rainy winter with moderate heat and warm summer (from May to September) with clear sky, high solar radiation and almost no rain.

• Temperature: The monthly and yearly average temperatures during the period between 1999 until 2013 is indicated in table (3-2). The table shows that the minimum average temperature is 13°C in January and the maximum average temperature is 26.9°C in August. The yearly average temperature is 20.5 °C.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Table (3-2): Monthly and Yearly average temperatures (°C) during the period between 1999 until 2013

Jan. Feb. March April May June July Aug. Sep. Oct. Nov. Dec. Avg. 13 13.9 16.1 19 25.4 24.7 26.4 26.9 25.4 22.4 18.5 14.6 20.5

• Relative humidity: The average monthly and yearly relative humidity during the period between 1999 until 2013 is shown in table (3-3). Minimum monthly average relative humidity is 60.4% in April while the maximum average relative humidity is of 70% in December. The yearly average value is 65.8%.

Table (3-3): Monthly and Yearly average relative humidity (%) during the period between 1999 until 2013

Jan. Feb. March April May June July Aug. Sep. Oct. Nov. Dec. Avg. 69.1 65.2 63.3 60.4 60.7 64.8 66.6 67.7 66.2 67 68.5 70 65.8

• Rainfall rates: Nubareya city is characterized by relatively dry climate, and mostly it rains between October and May, as it reaches its maximum rate during December, January and February with values 3.1, 3.8 and 3.1 mm respectively. October and May have the least rainfall rates as it reaches 0.4 mm while no rain is recorded during June, July, August and September.

The yearly average rainfall rate is 1.2 mm. The monthly average and yearly values for rainfall rates during the period between 1999 and 2013 is shown in table (3-4).

Table (3-4): Monthly averages and yearly average rain rates (mm) during the period between 1999 until 2013

Jan. Feb. March April May June July Aug. Sep. Oct. Nov. Dec. Avg. 3.8 3.1 1.6 0.8 0.4 0 0 0 0 0.4 1.5 3.1 1.2

• Wind speed: The average monthly and yearly wind speeds during the period between 1999 until 2013 are shown in table (3-5).

Table (3-5) shows that the maximum monthly-average wind speed is 13.5 km/h in April while the minimum monthly-average wind speed is 9.6 km/h in October.

The yearly average wind speed is 11.8 km/h. 63

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Table (3-5): Monthly and Yearly average wind speed (km/h) during the period between 1999 until 2013

Jan. Feb. March April May June July Aug. Sep. Oct. Nov. Dec. Avg. 11.3 12.4 11.9 13.5 12.5 13.2 13.4 11.4 10.9 9.6 9.8 11.4 11.8

• Wind direction: The wind in this region is relatively calm and the prevailing wind direction in general is to the Northwest, which is moderate and soothing as wind blows from cold and moderate regions towards hot and warm regions.

Figure (3-7) shows the wind rose for Beheira governorate in 2019.

Figure (3-7): Wind rose diagram for Beheira Governorate, 2019

3.1.7 Land Use: The total urban area in Beheira Governorate is estimated to be 405.3 Km2 and the rural area is 87,117.55 Km2. The total inhabited area reaches 163.28 Km2, total area of facilities and graveyards is 128.79 Km2, total area of swamps areas is about 283.09 Km2 and the total cultivated area is about 5215.98 Km2.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

3.1.8 Social features: • Population: The population of Beheira Governorate is about 6,171,613 people. The total number of males is 3,181,812 people while the total number of females is about 2,989,801 people. Table (3-6) shows number and percentage of different age groups in Beheira governorate.

Table (3-6): Different age groups in Beheira Governorate Age group Number %

Less than 15 2,169,645 35.2%

15 – less than 30 2,071,216 33.56%

30 – less than 60 1,710,289 27.71%

More than 60 220,463 3.57%

Total 6,171,613 100%

As for New Nubareya City (the project sites), it has a total population of about 35,000 people, where males represent 52% (equivalent to 18,200 people) while females represent 48% (equivalent to about 16,800 people).

• Manpower: Table (3-7) shows the manpower and unemployment distributions in Beheira Governorate

Table (3-7): Manpower and Unemployment Distribution Unit Value Workforce (over 15 years old) % 38.2 % of working women (over 15 years old) % 30.6 % Professionals % 11.4 % total 18.4 Sector and government employees % Females 12.4 % total 6.8 % Females 13.7 Unemployment rate %Urban 11.8 %Rural % 5.7

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Education: Education data for Beheira Governorate shows a significant improvement, which is evident in the low illiteracy rate and high enrollment in secondary education. For high education, there are two universities located in Damanhour city (El-Azhar University & Damanhour University). There is also one high education institute, several vocational institutes and vocational training centers distributed over the governorate. There are large number of public and private schools starting from playschools to high schools.

In Nubareya City, there are about 16 different educational buildings, classified between nurseries and schools for different age groups, some of them are experimental type schools. Girls high schools are separated from boys high schools.

On a university level, there is a branch of University of Damanhur in Nubareya including Faculty of Education and Faculty of Computers and Information Technology.

• Health: Public health in Beheira Governorate has witnessed an improvement in its level over the years, as the total death rate in Beheira Governorate in 2005 reached about 5.8% of the total population, mainly in Damanhour city.

Regarding the types of disease in Beheira Governorate, in 2005 a total of 1,042 cases of typhoid were recorded, 165 cases tuberculosis and there were 38 confirmed cases of hepatitis C. There is a large number of hospitals in Beheira Governorate, the most important of which are: Damanhur General Hospital, Al-Mabarah Damanhour branch, Rashid General Hosbital, Maburat Al-Mahmoudia, Damanhur Kidney and Edko General Hospital. In addition, there are several number of clinics distributed throughout the governorate.

New Nubareya City has one hospital and 7 health and ambulance service points distributed throughout the city, in addition to a number of medical clinics.

• Drinking water: Beheira Governorate is mainly dependent for its water needs on the Nile River. Artesian wells (groundwater) are also used in some centers such as Abu Al-Matamir, Al-Delanjat, Itai Al-Barud, Shoubrakhit, Kom Hamada, Badr, …etc.

The Capacity of drinking water treatment stations for Nile and well water is about 750,000 m3/day distributed throughout the governorate.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez New Nubareya City is supplied with drinking water through a drinking water purification plant with a capacity of 25000 m3/day. Water is distributed through a network of 128.8 km. Turbid water is used for irrigation through 56 km length network.

• Domestic Sewage: There are 27 sewage treatment plants in the governorate with total design capacity of 344000 m3/day. There are 15 cities and 114 villages are now served by the Domestic Sewage facilities.

New Nubareya City has a domestic sewage treatment plant with a capacity of 6800 m3/day and currently a second phase with additional capacity of 21700 m3/ day is under construction phase. Sewer network with a length of about 66 km is specified for sewage collection.

• Energy: Table (3-8): Energy supplies in Beheira Governorate Location Number of Annual production (million kWh) stations Damanhour 4 3810 Mahmoudiyah 3 1982 Kafr El Dawar 1 1624 Lighting consumption - 2359 Per capita lighting - 450 kWh Total per capita - 655 kWh consumption New Nubareya City has a newly built transformer station with a capacity of 80 MVA which is distributed by 443 km of electricity networks.

3.1.9 Economic features: The location, the area, the good climate and the type of soil makes Beheira governorate is a focus for agricultural, industrial, commercial, tourism and economic activities.

The agricultural sector plays a major role in the national economy, which has an important share to foreign trade.

As a result, the government is interested in strengthening this sector by expansion horizontally to increase the agricultural area and vertically to increase the yields of acres. The main crops cultivated in Beheira Governorate for the year 2005 are shown in figure (3-9).

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Table (3-9): The main crops in Beheira Governorate, 2005 Total Crop Unit Area in acre Acre average production Cotton Qantar 164,115 7.51 1,233,083 Wheat Ardeb 329,542 17.9 5,896,844 Rice Ton 209,153 4.07 851,169 Maize Ardeb 170,743 26.33 4,495,994 Beans Ardeb 93,196 8.5 537,198 Onion Ton 16,608 10.86 180,357 Peanuts Ardeb 59,634 1,706 1,023,510 • Economic features for Nubareya City:

− Nubareya City includes: Residential areas with 2000 residential units in addition to 3 new residential districts, service units, industrial zones, agricultural investment zones where several crOPs are cultivated mainly sugar beet.

− Total current agricultural activities are located in the following areas: Sugar Beet – El-Nahda & Mariout – ElBostan – West of Nubareya – South ElTahrir

− There is a large industrial area in the city including (engineering, electrical, food, wooden and furniture, plastic, paper, textile, chemical, pharmaceutical metal, mechanical and other activities)

3.1.10 Ecology of the study area (Flora & Fauna): The ecology in Beheira Governorate varies due to its large area and multiple environments.

❖ Ecology of in Nubareya city (project sites): • Flora: The two sites under study close to some residential housing, therefore the region contains a limited number of plant species such as ornamental trees - jazurin trees - palm trees and there are some weeds next to site (23).

• Fauna Mammals:

The mammals in the project area are dogs and street cats - some types of night fruit bats - mice - donkeys and horses used for transport and agricultural purposes, and there are some types of livestock such as: cows, buffalos, sheeps and goats in the neighboring agricultural areas.

Birds:

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez There are limited numbers of birds in the region, such as: pigeons - Abu Qardan - chickens - Hodhod - crows - owls - woodpickers. Reptiles and Amphibians: Reptiles in the project area are lepers, lizards and chameleons.

Ecology of Beheira Governorate is mentioned in details in Annex (2)

3.1.11 Project locations- site (18) & site (23):

❖ Site (18), Nubareya City, Beheira Governorate:

This site is located in Nubareya city at the coordinates (30° 40.251 'N, and 30° 4.014' E), it is a compound surrounded by a brick fence and has an iron gate; the site floor is made of concrete. The site is located in residential area. This site belongs to Directorate of Agriculture at Nubareya City and it is currently used as a garage and store for the equipment, it has 6 separate units each 30 m2 where obsolete pesticides are stored. The six units are poorly ventilated. Site description is illustrated in the following table (3-10):

Table (3-10): Description of site (18) - Nubareya City, Beheira Governorate

Site name Nubareya Agriculture Directorate (Workshop, and Garage Stores) Site number 18 Nubareya Agriculture Directorate (Workshop, and Garage Stores), Address Beheira Governorate, Egypt. Coordinates 30° 40.251' N, and 30° 4.014' E Figure (3-8) shows a map that precisely describes the location of site (18).

Figure (3-8): Google Map showing the location of site (18)

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Obsolete pesticides in site (18) are stored inside six units since 2011 where a total of 44 tons OPs are stored. The 6 units include:

• Three stores with wooden doors and tile floor. • Two stores with iron door and tile floor. • One store with metallic door and concrete floor.

The following figure (3-9) shows real photos for three of the six OPs Stores at site (18) from inside and outside.

Figure (3-9): Real photos for three of the six OPs Stores at site (18) from inside and outside

▪ Site (18) - Nubareya City, Beheira Governorate:

Site (18) is located in one of the residential areas of Nubareya City; this site is bordered from North by residential buildings, from East by an entertainment mall, from West by

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez main street & residential buildings and from South by an empty land as shown in the following figure (3-10), (3-11), (3-12) and (3-13).

Figure (3-13): Real photo for main street & residential buildings from West

This site is located near a residential area but it is fenced and entrance to and exit from this site is controlled. Since the site is near a residential area, A quantitative risk assessment (QRA) is conducted for this site in order to analyze the effect of the site on the surrounding environment and public health, to determine the mitigation measures that should be implemented in order to mitigate the negative impacts related to the 71

Figure (3-10): The surrounding area for site (18) English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez repackaging activity (Reference to residual risk evaluation –QRA study) to ensure that the whole project will be conducted in a safe and environmentally sound manner (Annex (3) – QRA Report). The nearest agriculture area to site (18) is about 500 m to the Southern West, while the nearest surface water source (Nasser Canal) is about 3.7 km to the northern west. For the main roads near to site (18), Cairo-Alexandria Desert Road is about 1 km from the eastern direction to the site. Wady Natrun-Alamin Desert Road is about 15 km Southern West from the site as shown in figure (3-14).

Figure (3-14): Google map showing the Distance between the nearest surface water source and main roads to site (18) ❖ Site (23) - Nubareya City, Beheira Governorate: This site is located in Nubareya city at the coordinates (30° 40.472' N, and 30° 4.351' E); and belongs to Directorate of Agriculture at Nubareya city- Ministry of Agriculture and Land Reclamation. It is located near a residential area. Site (23) is one store of 12 m2 with a tile floor and a wooden door, it contains expired pesticides since 1994; besides other OPs transferred from stores (24) and (25) located also in Nubareya city. A total of 5.496 tons are now stored in site (23). The site is poorly ventilated with some spilled OPs noticed outside the store. Site description is illustrated in the following table (3-11).

Table (3-11): Description of site (23) - Nubareya City, Beheira Governorate

Site name Central Agricultural Cooperative Society for Land Reclamation

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Site number 23 Central Agricultural Cooperative Society for Land Reclamation, Address Beheira Governorate, Egypt. Coordinates 30° 40.472' N, and 30° 4.351' E

Figure (3-15) shows a map that precisely describes the location of site (23).

Figure (0-15): Google Map showing the location of site (23)

The following figure (3-16) shows real photos for site (23) from inside and outside.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

 Site Surrounding: Figure (3-16): Real photos for site (23) from inside and outside

▪ Site (23) - Nubareya City, Beheira Governorate:

Site (23) is located in one of the residential areas of Nubareya City; this site is bordered from North by an empty land, from East by a main street, from West by cultivated area and from South by a main street as shown in the following figures (3-17), (3-18), (3- 19) and (3-20).

Figure (3-17): The surrounding area for site (23)

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Figure (3-18): Main Street from Figure (3-19): Main Street from East South

Figure (3-20): Cultivated area from West This site is relatively away from the residential area but it is fenced and entrance and exit from this site is controlled. A quantitative risk assessment (QRA) is conducted for this site in order to analyze the effect of the site on the surrounding environment and public health, and to determine the mitigation measures that should be implemented in order to mitigate the negative impacts related to the repackaging activity (Reference to residual risk evaluation –QRA study) to ensure that the whole project will be conducted in a safe and environmentally sound manner (Annex (3) – QRA Report).

The nearest agricultural area to site (23) is about 350 m to the North, while the nearest surface water source (Nasser Canal) is about 3.5 km to the Northern east side.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez For the main roads near to site (23), Cairo-Alexandria Desert Road is about 250 m from East; Wady Natrun-Alamin Desert Road is about 15.5 km from the South Western side as shown in figure (3-21).

Figure (3-21): Google map showing the Distance between nearest surface water source and main roads to site (23)

Alexandria Governorate: The total area of Alexandria governorate is about 2300 Km. It extends from Gulf of Abu Qir in the East to Burj Al-Arab in the West, and is located on a latitude of 31 North and extends as a coastline of 90 km Northwest of Nile Delta.

Alexandria governorate is bordered from North by the Mediterranean Sea, from South by Lake Mariout, from East by Abu Qir Bay and Edko and from West by Burj El-Arab.

Site (48) is located in one of the buildings in Alexandria Sea Port shown in figure (3- 22). This port has an area of 8.2 Km2. It is the most active port in Egypt, where 60% of Egypt foreign trade is handled.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Figure (3-22): Map showing location of Alexandria Sea Port 3.1.12 Topography: Alexandria Governorate is characterized by the succession of parallel rock strings that extend along the coast and between them there are longitudinal valleys extend in the same direction. The Southern part of the Governorate is characterized by sand formations on a wavy surface as shown in figure (3-23).

Figure (3-23): Topography map of Alexandria Governorate

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3.1.13 Geomorphologic Features:

The geomorphological features indicate that Alexandria is based on a strip of land bordered from North by the Mediterranean Sea and from South by Lake Mariout. This strip of land is a successive series of hills, sand dunes and valleys, one of which lies along Alexandria/ Matrouh Road.

Also, Lake Mariout depression extends from Wadi Mariout until it reaches the Mariout Plains at Al-Amreya and King Mariout. This area rises about 35 meters above sea level which created a distinct climate.

3.1.14 Hydrogeology:

A hydrogeological study was carried out by a specialized consultant, detailed report is attached in Annex (1). The study showed that the wells have depths varying from 17 to 40 m. The main aquifers in Alexandria governorate is shown in figure (3-24).

Figure (3-24): Main Aquifers in Alexandria Governorate 3.1.15 Geologic Sedimentary: The geological structure of Alexandria where layers of Nile Silt, Sabkha deposits and marsh, undifferentiated Quaternary deposits and stabilized dunes formations identified as shown in figure (3-25) & table (3-12) By plotting the coordinates of site (48) on the geological map, it was observed that the site is located over the Nile silt.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Figure (3-25): The Geological map for Alexandria, Egypt [The Egyptian Petroleum Corporation]

Table (3-12): Legends of Geological formation in Alexandria, Egypt Formation Description Nile Silt.

Sabkha deposits and marsh.

Undifferentiated Quaternary deposits. Alluvial fans, wadi deposits, sand, gravel, recent coastal deposits. Stabilized dunes.

3.1.16 Soil Characteristics:

The soil of Alexandria in general is highly calcareous. The soil was originated in four parent materials:

• Alluvial origins: the parent materials are loamy and highly calcareous. • Marine origin: It is Oolitic sand, which forms the beach ridges and inland consolidated dunes. • Aeolian origin: It is covering wide and narrow parts either on the plateau or in the coastal plain. • Lagoons origin: It is found in the depressions between the beach ridges.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3.1.17 Climatic Conditions:

• Temperature:

The climatic conditions in Alexandria governorate are distinguished by a distinct climate for the coasts of Southern Mediterranean countries, which are characterized by mild rainy winters and warm summers where the sky is clear and sun radiation is very high and rainfall is rare.

The maximum average temperature is 26.5°C in August and the minimum average temperature is 13.5°C in January. The yearly average temperature is 20°C, as shown in table (3-13).

Table (3-13): Monthly and Yearly average temperatures (°C) during the period between 1999 until 2013

Jan. Feb. March April May June July Aug. Sep. Oct. Nov. Dec. Avg. 13.5 14.1 15.8 18.3 21.2 24.3 25.9 26.5 25.6 22.5 19.1 15.2 20

• Relative humidity: The relative humidity percentage is almost constant throughout the year, and it ranges between 65-72% as shown in table (3-14).

Table (0-14): Monthly and Yearly average relative humidity (%) during the period between 1999 until 2013

Jan. Feb. March April May June July Aug. Sep. Oct. Nov. Dec. Avg.

70 68 65 65 67 69 72 71 68 68 69 70 68.5

• Rainfall rates: Rainfall rates in Alexandria governorate is maximum in winter between November to March (8.2 – 20.6 mm) while minimum values are reached in summer from June to September (0.0 – 0.5 mm).

The yearly average rainfall rate is 6.7 mm as shown in table (3-15).

Table (0-15): Monthly and Yearly average rainy days during the period between 1999 until 2013 (day)

Jan. Feb. March April May June July Aug. Sep. Oct. Nov. Dec. Avg. 20.6 12.3 8.2 3.1 1.4 0.1 0 0.2 0.5 6.4 11.9 15.6 6.7

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Wind speed and direction: The wind speed in this region is relatively calm, and its speed increases during the stormy days.

The prevailing wind direction is Northwest as shown in the wind rose diagram for Alexandria in 2019 (figure (3-26)).

Figure (0-16): Wind rose diagram for Alexandria, 2019

3.1.18 Land Use:

The total area of Alexandria governorate is about 2300 Km2. The inhabited area is 1675.5 Km2 for the year 2006 including 622.3 Km2 scattered residential areas, 65.4 Km2 covered by utilities and graveyards, 135.3 Km2 swamps and wetlands, 227.8 Km2 agricultural land within the residential belt and 624.7 Km2 agricultural land outside the residential belt.

3.1.19 Social characteristics:

• Population: The population and proportions of different age groups for Alexandria governorate are shown in table (3-16).

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Table (3-16): Population and % of different age groups, Alexandria Governorate Age group Number % Less than 15 1,527,204 29.5% 15 – less than 30 1,779,006 34.5% 30 – less than 60 1,610,952 31.2% More than 60 246,588 4.8% Total 5,163,750 100% Site (48) lies in Alexandria port, Al-Gomrok district, which has a population of about 145,558 people which represents 2.82% of the total population of Alexandria governorate, and it’s ranked the 4th in terms of population.

• Manpower: The labor force in Alexandria reaches about 1,596,200, of whom more than 46,000 employees are working in the food sector and hired by 540 licensed establishments. The survey also showed that 12,782 employee work for 52 other industrial establishments. Unemployment rate in Alexandria Governorate is about 14%, the percentage of unemployed young people between the ages of 20-25 years reaches 49%.

• Education: Number of schools in Alexandria governorate reaches 1700 schools for general and technical education. Regarding high education, there is Alexandria University, which is the second largest university in Egypt. It includes 21 colleges and 3 different high institutes. There are also two branches of the university outside Egypt, one is in South of Sudan and the other is in Chad.

Al-Gomrok district (site (48)) is ranked as 6th highest district in Alexandria in the student density with a percentage of 38.9% as it has 19 nurseries, 39 primary schools, 14 preparatory schools, 9 secondary schools, 5 Azhar schools and two special schools for those who are hearing and visually impaired.

• Health: The average age in Alexandria Governorate in 2004 was about 71.4 years, and it reflects an improvement in the general health if compared to previous years. According to the statistics of the United Nations Population Fund in 2015, the birth rate reached 26.9% while the death rate reached 8.4% to make the net growth rate 18.5%. Several hospitals and medical centers are largely distributed allover Alexandria governorate, as the number of large hospitals reaches 34 hospitals.

Al-Gomrok district includes a public hospital, a specialized hospital, 2 private hospitals, 4 different health units, 9 family planning centers and 127 pharmacies. 82

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Drinking water: Mahmoudia Canal branched from the Nile is the main source of raw drinking water in Alexandria. Alexandria Water Company has several water purification plants in Alexandria to produce good quality drinking water with total capacity of 3.5 million 3 m /day.

• Domestic Sewage: According to the data of the Ministry of Housing, Utilities and Urban Communities, Alexandria Governorate has 20 Domestic Sewage treatment plants with a total capacity of about 1.5 million cubic meters per day. The station in the Eastern side (Smouha region) is the largest station with a capacity of about 850,000 m3/day, followed by the Western station located in western Alexandria (Furn El Jaraya) with a capacity of about 460,000 m3/day.

• Energy: According to the data of the Ministry of Electricity and Energy, the amount of electricity consumed for lighting is 3094 million kilowatts per year while the amount of electricity consumed for industrial use is 5490 million kilowatts per year. Al- Montazah District records the highest energy consumption either for lighting or for other purposes.

3.1.20 Economic features: Alexandria has one of the most important and largest ports in Egypt. About 40% of the volume of industrial activities and 60% of the petroleum activities of Egypt are established in Alexandria. Many other major industries mainly Iron and steel, minerals, petrochemicals, food, spinning and weaving, paper products,... etc. are also present especially in the industrial zones and duty free zones in the governorate. Regarding the agricultural activities, and according to the data of the Directorate of Agriculture in 2006, the total cultivated area is 1,621,000 acres. Most of them are located in Ameria, Burj Elarab and Bangar Alsokar. The most important crOPs in Alexandria are wheat, barley, alfalfa, dry beans, onions, garlic, cotton, summer maize, indigo and rice.

3.1.21 Ecology of the study area (Flora & Fauna): • Flora: Some decorative trees and palm trees are found around the area of site (48).

• Fauna: Coastal Birds: It includes birds that are likely to be found in the Mediterranean region, such as the seagull.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Coastal Desert Birds: They are limited due to the large amounts of rain fall on the Mediterranean desert, which makes it difficult for them to adapt.

The detailed description of the different species of birds found in Alexandria Governorate, is attached in Annex (2) of this study.

Reptiles and Amphibians: Site (48) is located inside a building in Alexandria port, therefore limited number of reptiles on site mainly geckos and small-sized lizards were found.

Details on other types of reptiles and amphibians in Alexandria Governorate are shown in Annex (2) of this study.

3.1.22 Project location Site (48): ❖ Site (48) - Alexandria Port, Alexandria Governorate:

Site (48) is located at the wastes & sold goods building inside Alexandria Port at the coordinates (31° 11.34' N, and 29° 53.01' E). The building is old & made of concrete; it consists of five floors with deteriorated central staircase. Obsolete pesticides are located in designated areas only in the first and third floors of the building with a total quantity of 37 tons are now stored in this site. OPs are stored directly on concrete floor, and ventilation is provided through open windows.

Site description is illustrated in the following table (3-17).

Table (3-17): Description of site (48), Alexandria Port, Alexandria Governorate

Site name wastes & sold goods building Site number 48 Address Alexandria Port, Alexandria Governorate, Egypt. Coordinates 31° 11.34' N, and 29° 53.01' E

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Figure (3-27) shows a map that precisely describes the location of site (48).

Site 48

Figure (3-27): Google Map showing the location of site (48)

Site (48) - Alexandria Port, Alexandria Governorate:

Site (48) is located in the wastes & sold goods building in Alexandria Port. The building is surrounded from North by administrative buildings that belong to the port authority, from South by private warehouses that are not affiliated to the port administration, from East by two schools located outside the port and from West by the Mediterranean Sea at a distance 240 m. The following figures (3-28), (3-29), (3-30), (3-31) and (3-32) show the surrounding area to site (48) in Alexandria port.

Figure (3-28): The surrounding area for site (48) 85

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Figure (3-29): Schools from the Figure (3-30): Administrative buildings East outside the port from the North inside the port

Figure (3-32): Harbour from the West Figure (3-31): Private warehouses from the South outside the port inside the port

This site is relatively away from the residential area. However, a quantitative risk assessment (QRA) is conducted for this site in order to analyze the effect of the site on the surrounding environment and public health, to determine the mitigation measures that should be implemented in order to mitigate the negative impacts related to the repackaging activity (Reference to residual risk evaluation –QRA study) to ensure that the whole project will be conducted in a safe and environmentally sound manner (Annex (3) – QRA Report).

The nearest surface water source to site (48) is the Mediterranean Sea; Mediterranean Sea is about 240 m from the site. For the main roads near to site (48), Cairo-Alexandria Desert Road is about 4.4 Km from the Northern East, Al-Dawly Al-Gaded & Al-Kabary Fast Roads are about 2.7

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Km from the Southern east, the International Coastal Road is about 6.3 Km from the Southern East and the Port harbour from the West as shown in figure (3-33).

Figure (0-33): Google Map showing the Distance between nearest surface water source and main roads to site (48)

Suez Governorate:

Suez governorate is located at the Northern end of Gulf of Suez and it is bordered from North by Ismailia Governorate, from West by Cairo governorate, from South by the Red Sea and from east by North and South Sinai governorates. The following figure (3- 34) shows the location of Suez Governorate.

Figure (0-34): Administrative divisions of Suez and its surroundings 87

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez The total area of Suez Governorate is 10056 Km2, it consists of five districts and its population reaches 700,000 people. There are five ports in Suez governorate including: (Suez Port, Port Tawfik, Sokhna Port, Adabeya Port, Oil basin Port) and the project site is located in Adabeya port.

The project site (44) is located in Adabeya port at Ataka district as shown in the following figure (3-35).

Figure (0-35): Map showing location of Adabeya port

3.1.23 Topography:

Suez Governorate is an area of low relief and poorly-defined drainage lines. The topography is controlled by its geological structure; the topographic highs are also structural highs. The bolder topographic features are made up of Middle Eocene limestone. Site (44) (40 ft3 container) is located in low coastal plain to the East of Ataka mountain. Figures (3-36) & (3-37) show the land forms of Northwestern part of Gulf of Suez and the topography map of Suez governorate.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Figure (0-36): Landforms of the Northwestern part of the Gulf of Suez

Figure (3-37): Topography map of Suez Governorate

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3.1.24 Geomorphologic Features:

Suez Governorate is located in an area characterized by rugged soil. Wide valleys separate Ataka Mountain from Jalala Mountain. These valleys indicate that Egypt was in the past part of the areas that was subjected to a large amount of rain. The Red Sea coast is characterized by a sandy strip that ranges between 8 to 38 Km wide, especially on the western side of the Gulf of Suez.

3.1.25 Hydrogeology:

A hydrogeological study in the location of site (44) was carried out by a specialized consultant, where the detailed report is attached in Annex (1). The study showed that the main aquifer at the study area is the Quaternary Aquifer, and the groundwater of the Quaternary aquifer occurs under free water table condition at depths varying between 9.4 m in the East, and 39.9 m in the Northwest as shown in figure (3-38). It could be concluded from the study that the depth of ground water is varying from 9.4 to 39.9 m.

Site 44

Figure (0-38): The main aquifers in the study area (site (44))

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3.1.26 Geologic Sedimentary:

The hydrogeological study mentioned in Annex (1) includes a study for the geological structures of Adabya Port area, where site (44) is located.

A geological map (figure (3-39) and legend table (3-18)) for the study area indicate the different geologic sedimentary which comprise the following:

Layers of undifferentiated Quaternary deposits, Alluvial fans, wadi deposits, sand, gravel, recent coastal deposits, Hagul Formation, Undifferentiated upper createceous deposits in the Ataqa wadi, Thebes group. Abu rimth formation, Mokattam group, Wadi deposits, Maadi formation, and Gabel el-Ahmar formation are all.

Site 44

Figure (0-39): The Geological map for the study area (Site 44), Egypt [The Egyptian Petroleum Corporation]

Table (3-18): Legend for the study area (site 44) showing different Geologic sedimentary Formation Description Undifferentiated Quaternary deposits. Alluvial fans, wadi deposits, sand, gravel, recent coastal deposits. Hagul Formation.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Undifferentiated upper createceous deposits in the Ataqa wadi. Thebes group. Abu rimth formation.

Mokattam group.

Wadi deposits.

Maadi formation.

Gabel el-Ahmar formation.

3.1.27 Soil Characteristics:

Most of the Suez soils are classified according to what is shown in Figure (3-40) to a red desert characterized by soil salinity. Soils with such characteristics are not suitable for the cultivation of traditional crops known in the Nile River Valley and Delta, especially in the absence of fresh water, while cultivation feeding on rainwater cannot be sustainable due to the lack of continuity of the rainy season, as is the case in the Northern coast.

Figure (3-40): Soil classification in Suez governorate 3.1.28 Climatic Conditions:

• Temperature:

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez The study area has a typical hyper-arid climate, where the monthly average temperature in winter ranged between 14.7 - 22°C during November to May while ranged between 24-28.9°C in summer during June to October as shown in table (3- 19). The yearly average temperature is 22.4°C.

Table (3-19): Monthly and Yearly average temperatures (°C), 2014

Jan. Feb. March April May June July Aug. Sep. Oct. Nov. Dec. Avg. 14.7 16 18 22 25 27.9 28.9 28.9 27 24.2 20.4 15.8 22.4 • Relative humidity:

The relative humidity is ranged between 44% to 56% during winter between November to May while during summer it ranges between 44-55% from June to October as shown in table (3-20). The yearly average relative humidity is 50%.

Table (0-20): Monthly and Yearly average relative humidity (%), 2014

Jan. Feb. March April May June July Aug. Sep. Oct. Nov. Dec. Avg. 55 53 46 42 44 44 50 45 55 55 56 55 50

• Rainfall rates: Rainfall rates in Suez governorate are illustrated in the following table (3-21).

Table (0-21): Monthly and Yearly average rainfall days, 2014

Jan. Feb. March April May June July Aug. Sep. Oct. Nov. Dec. Avg. 3.4 0.8 3.1 1.1 0.7 0 0 0 0 0.8 1.2 1.5 1.05

• Wind speed and direction The prevailing wind direction in Suez Governorate throughout the year is North to Northwest, as shown in Figure (3-41).

Figure 0-41): Wind direction (degrees) & speed (km/h) for prevealing wind, 2019

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3.1.29 Land Use:

Suez governorate area represents about 1.02% of the total area of Egypt. And the inhabited area thereof is only 9171.09 Km2. The area of swamps and uncultivated land is 8938.4 Km2, with very small area of agricultural land about 66 km2. The population area is about 136.69 Km2, and there are 30 Km2 for facilities and landfills. Suez Governorate also has two garbage dumps with an area of 54.6 Km2.

3.1.30 Social characteristics:

• Population: Suez Governorate is ranked the 22nd in terms of population size, with a total population of 607,260. Tables (3-22) & (3-23) show the different population characteristics in the governorate.

Table (3-22): Population features in Suez Governorate, 2010 Item Unit Value Total population 1000 person 607.26

Average number of family Person 4.15 members (2006) Birth rate Born / thousand person 30.30

Mortality rate No of death / thousand person 5.7

Population Natural growth Per thousand persons 24.6 rate Population density in the total One thousand person / Km2 0.07 area

Table (3-23): Age distribution in Suez Governorate Age group % Less than 15 31.07882

15- less than 25 22.0108

25- less than 35 15.72042

35 – less than 65 27.1646

More than 65 2.47

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Manpower: The unemployment rate in Suez Governorate is remarkably high, reaching 15% in 2010, as shown in the table (3-24) which represents different data related to man power.

Table (3-24): Labor force in Suez Governorate, 2010 Labor Parameter Unit Value Total labor force thousand people 175.9 No. of workers in the thousand employees 149.00 governorate No. of unemployed persons in thousand employees 26.90 the governorate The proportion of the % 28.97 workforce Unemployment rate % 15.29

• Education: Suez Governorate is characterized by a low illiteracy rate compared to the Arab Republic of Egypt and occupies the fourth place in terms of the percentage of education. The illiteracy rate in the governorate is 17% for individuals over the age of 10 years. Table (3-25) shows different information about education in the governorate.

Table (3-25): Literacy in Suez governorate, 2010

Education Unit Value No. of targeted illiterates thousand persons 4.06

No. of enrolled in literacy classes thousand persons 6.80

Enrolled (% of targeted illiterates) Person % 167.71

No. of literates thousand persons 3.70 literates (% of enrolled) % 54.35

Illiteracy rate (10 years +) (2006) % 17.14

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Health: The governmental infrastructure and health facilities of the Suez Governorate are not sufficient, especially when considering the rapid increase in population, as table (3-26) illustrates the number of hospitals in Suez Governorate is very low due to the size of its population.

Table (3-26): Health Infrastructure in Suez governorate, 2010 Parameter Unit Value

No. of hospitals of the Ministry of Hospital 0 Health No. of public and central hospitals Hospital 1

No. of specialized hospitals Hospital 3

Hospitals insurance authority Hospital 1

Private sector hospitals Hospital 16

Other hospitals Hospital 2

No of inhabitants/ bed Inhabitant/ bed 434.69

No of working physicians Physician 414

No. of inhabitants/ Physician Inhabitant/ physician 1466.82

No of working nursing staff Nurse 807

No of inhabitants/ nurse Inhabitant/ nurse 752.49

Number of working dentists Dentist 75

Number of Pharmacists employed Pharmacist 72

• Drinking water: Almost all families enjoy a share of clear drinking water table (3-27). And the amount of per capita drinking water supplied more than three times compared to the national average. The drinking water supply is higher than the per capita consumption, which indicates, in large part, the adequacy of the water supply in the governorate. And the per capita water consumption is much higher than the national average and is actually more than 3.5 times higher than the Egyptian average.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Table (3-27): Drinking water supply in Suez governorate, 2010

Parameter Unit Value Drinking water production Thousand m3 / day 675.70

Drinking water consumption Thousand m3/ day 595.00

% Of households with access to % 99.94 water (2006) Per capita water consumption Lit.day/ person 979.81

Per capita water production Lit. day / person 1112.7

• Domestic sewage: Suez Governorate has limited problems related to the adequacy of the sanitation service, as more than 90% of the population of the governorate is connected to the domestic sewage network, as shown in table (3-28) This situation is much better than most of the governorates of Egypt.

Table (3-28): Domestic sewage service in Suez governorate, 2010

Parameter Unit Value Capacity of sanitation Thousand m3 / day 439.3 Per capita sanitation capacity Lit. day / person 723.41 %of household connected to % 90.02 sanitation

• Energy: The electricity supply is very sufficient as indicated by the number of subscribers in the governorate (Table (3-29)). The per capita electricity consumption is higher than the national average. The gas supply service is not as sufficient as the electricity supply because of the number of subscribers is significantly lower than those with electricity.

Table (3-29): Energy supply service in Suez governorate, 2010

Energy Indicator Unit Value Total consumption of electricity Million kWh yearly 1394.05 Electricity consumption for lighting Million kWh yearly 479.24 Electricity consumption for Million kWh yearly 914.81 industrial utilization

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Per capita consumption of kWh yearly/ Person 789.18 electricity for lighting

3.1.31 Economic characteristics:

The industrial sector is considered the main economic sector in the governorate. It includes mining and manufacturing industries. The industries of petroleum products and refining, chemical, cement and food industries (edible oils) are the backbone for the industrial base in Suez. These industries were established in the governorate as a result of the presence of mining resources. As for the traditional agricultural activities, it focuses on hunting and raising poultry and livestock. As for the agriculture itself, it suffers from the deteriorating soil quality, and the lack of fresh water needed to grow vegetables and fruits. As for traditional crops such as cotton and rice, they are almost non-existing in the small agricultural areas located in the Genin district.

3.1.32 Ecology of the study area (Flora & Fauna):

• Flora: There are no plant species in the project area, as the site is one closed container within the container storage yard inside the port. Generally, flora in Suez Governorate vary according to the nature of the soil and the area exposed to water. The dominant types include the following; Juncus Rigidus, Tamaric Nilotica, Nitaria retusa, Limonium Pruinosum, Phoenix Dactylifera, Arthrocnemum Macrostachyum.

• Fauna: Birds: There are a limited number of different birds in the project site, such as different types of seagulls, as well as a small number of birds that are generally found in the Gulf of Suez region, which includes many birds like Honey Buzzard, Black Kite, Egyptian Vulture, Spotted Eagle, Red-Footed Falcon, Lesser Kestrel, Cormorant, Bittern, Cattle Egret, Grey Heron, Greater Flamingo, Curlew, Rock Dove, Cream-Colored Courses, Swallow, Moorhen.

Reptiles and Amphibians: There are no reptiles in the project area, as the site is a one closed container within the container storage yard in the port. As for reptiles that generally exist in Suez governorate, the most common species are Turkish and Pigmy Gecko, Saharan Sand Snake, Horned Viper and lizards.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Mammals: Mammals are rare to be found in the project site, as it is one container within the container storage yard inside the port. Generally, common mammals in the Gulf of Suez area include Spiny Mouse, Hyrax, Stripped Hyena, Fat Sand Rat and Dorcas Gazell.

3.1.33 Project location-Site (44):

▪ Site (44) - Adabeya Port, Suez Governorate:

Site (44) is located at El-Adabeya port at the coordinates (29° 52.905' N, and 32° 28.153' E).

Site (44) is a 40 ft3 container where pesticides are stored; a total of 7.32 tons OPs are now stored in site (44), this container is closed with no ventilation and is located inside an open storage yard inside the Port.

The storage yard where the container located is used for storing the containers of the shipped goods, the floor of the yard consists of concrete.

Site description is illustrated in the following table (3-30).

Table (3-30): Description of site (44), Adabeya Port, Suez governorate

Site name El-Adabeya Port Site number 44 (steel container) Address El-Adabeya Port, Suez Governorate, Egypt. Coordinates 29° 52.905' N, and 32° 28.153' E Figure (3-42) shows a map that precisely describes the location of site (44).

Site (44)

Figure (0-42): Google Map showing the location of site (44) 99

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez The following figure (3-43) shows real photos for site (44) from inside and outside.

Figure (3-43): Real photos for site (44) from inside and outside

100

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez  Sites Surrounding

Site (44) - Adabeya Port- Suez Governorate:

Site (44) is a 40-ft3 container located in an open storage yard inside El-Adabeya Port. This site is bordered from North by another storage yard, from the South by another storage yard, from East by an internal road and from West by railway line & Ain Sokhna / Suez road. Figure (3-44) shows the surrounding area of site (44).

Figure (3-44): The surrounding area for site (44)

This site is away from the residential area. However, a quantitative risk assessment (QRA) is conducted for this site in order to analyze the effect of the site on the surrounding environment and public health, to determine the mitigation measures that should be implemented in order to mitigate the negative impacts related to the repackaging activity (Reference to residual risk evaluation –QRA study) to ensure that the whole project will be conducted in a safe and environmentally sound manner (Annex (3) – QRA Report).

The nearest surface water source to site (44) is the Red sea; it is about 360 m from East. For the main roads near the site is Hurgada/Al-Ismailia road which is about 130 m from West as shown in figure (3-45).

101

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Figure (3-45): Shows the surrounding area for site (44)

3.2 Earthquakes:

Earthquakes have direct effect on nature, human activities and buildings. Generally, Egypt is characterized with weak to moderate seismic activity, and the greatest seismic activity is concentrated in the northern parts of the country along with the western coast of the red sea. To estimate the seismic activity in study locations, Egyptian loads code (2008) was taken into considerations which is shown in figure (3-46) and as shown all the study sites are located in Group (III zone) which is subjected to weak to moderate seismic activity.

102

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

26˚ 28˚ 30˚ 32˚ 34˚ 36˚ 3

3 30˚

2 3 2

1 2 28˚ 3 1

26˚ 1 Red Sea 2 1

24˚ 2

3 1 3

Figure (0-46): Seismic activity belt

3.3 Terrestrial Biological Environment: The studied areas are not located within any Statutorily Protected Area as shown in Figure (3-47), which presents both the current protected area (indicated in green) and the study areas (indicated in red circle).

Figure (0-47): Project areas in relation to protected area in Egypt 103

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3.4 Baseline Measurements:

3.6.1 Sampling & Analysis Regime: A total number of 22 samples including air, soil and water samples were collected from different locations around the sites under study.

The analysis of all samples (air, soil and water) was conducted by an approved external laboratory "The Main Chemical Warfare Laboratories (Unit 1615) in the Chemical Warfare Department, Ministry of Defence".

This laboratory is specialized in the analysis of pesticides where EPA standard procedures were applied (EPA 1699).12

The following table (3-31) shows the sampling regime for the sites under study.

Table (3-31): Sampling Regime in the sites under study

Date of sampling Location Number & types of samples

- 2 Soil samples from outside the Site (48) in store. Alexandria port, 29/9/2019 - 1 Air sample from inside the store. Alexandria 1 Air sample from outside the store. Governorate - - 1 Sea water sample 300 m apart from the store. - 2 Soil samples from outside the Site (18) in stores. Nubareya city, - 1 Air sample from inside store (E). Beheira 1 Air sample from outside the stores. Governorate - - 1 water sample from an agricultural drain 2 Km apart from the site 30/9/2019 - 2 Soil samples from outside the store. Site (23) in - 1 Air sample from inside the store. Nubareya city, - 1 Air sample from outside the store. Beheira 1 water sample from an agricultural Governorate - drain 1 Km apart from the site. - 1 water sample from an agricultural drain 2.5 Km apart from the site.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

- 2 Soil samples from outside the store. 24/11/2019 Site (44) in - 1 Air sample from inside the Adabeya port, Suez container. Governorate - 1 Air sample from outside the 12EPA 1699: Method 1699: pesticides in water, soil, sediment, biosoilds andcontainer. tissue by HRGC/HRMS December 2007 - 1 Sea water sample < 1Km apart from the site.

Annex (4) shows the certificates of analysis results obtained from the laboratory for Air, soil and water samples.

Note: Elements detected through the laboratory analysis are according to the types of pesticides existing inside each store, the expected list is attached in Annex (5) according to the TOR.

3.6.2 Air Quality Sampling and Analysis:

Air samplings were conducted in order to characterize the quality of air (from inside and outside the sites). Gaseous pollutants were collected in special air bags (toddler bags) and then measured using GC-MS device.

Figure (3-48) shows a real photo for the toddler bags used in collection of air samples.

Figure (3-48): Air bags used for collection of air samples Eight air samples were collected for air measurements from the 4 sites under study as follows: • 2 air samples from site (18), 1 from inside one of the stores and 1 from outside. • 2 air samples from site (23), 1 from inside the store and 1 from outside. 105

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • 2 air samples from site (48), 1 from inside one of the stores and 1 from outside the building. • 2 air samples from site (44), 1 from inside the container and 1 from outside.

Analysis of air samples was conducted by using the GC – MS device shown in the following figure (3-49).

Figure (3-49): GC-MS used in the analysis of air samples

The following tables (3-32), (3-33), (3-34) and (3-35) show the analysis results of air samples collected from site (18), (23), (48) and (44) respectively.

➢ Nubareya City, Beheira Governorate:

❑ Site (18) in Nubareya City:

Table (3-32): Analysis Results of Air samples collected from Site (18), Nubareya City – Beheira Governorate Analysis Results EPA Limits Test S Parameter Unit Residential Industrial Method N 18 – A (1) N 18 – A (2) Limits Limits 1 Oxamyl Nil Nil -- -- 2 Methomyl Nil Nil -- -- 3 Triazophos Nil Nil -- -- 4 Dimethoate Nil Nil -- -- Scan 5 Aldicarb µg/m3 Nil Nil -- -- GC-MS 6 Chlorophacinone Nil Nil -- -- 7 Carbendazim Nil Nil -- -- 8 Beta Cyfluthrin Nil Nil -- -- 9 Cypermethrin Nil Nil -- --

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Clodinafop- 10 Nil Nil -- -- propargyl 11 Tribenuron methyl Nil Nil -- -- 12 Furathiocarb Nil Nil -- -- 13 Coumatetralyl Nil Nil -- -- 14 Methamidophos Nil Nil -- -- 15 Dicofol Nil Nil -- -- 16 Oxyfluoren Nil Nil -- -- 17 Ethoprophos Nil Nil -- -- 18 Pendimethalin Nil Nil -- -- 19 Metiram Nil Nil -- -- 20 Toxaphene Nil Nil 8.8x10-3 3.8x10-2 Zinc Phosphide as -- -- 21 Nil Nil phosphine Aluminum -- -- 22 Nil Nil Phosphate Comments: - The GC-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the GC-MS scan being used. - No International or National limits are indicated neither in residential nor industrial areas are available for the present pesticides. However, Dimethoate, Aldicarb, Zinc phosphide and Dicofol are classified as highly hazardous pesticides.

❑ Site (23) in Nubareya City:

Table (3-33): Analysis Results of Air samples collected from Site (23), Nubareya City – Beheira Governorate Analysis Results EPA Limits Test S Parameter Unit Residential Industrial Method N 23 – A (1) N 23 – A (2) Limits Limits 1 Oxamyl Nil Nil -- -- 2 Methomyl Nil Nil -- -- 3 Triazophos Nil Nil -- -- 4 Dimethoate Nil Nil -- -- 5 Aldicarb Nil Nil -- -- Scan 6 Chlorophacinone µg/m3 Nil Nil -- -- GC-MS 7 Carbendazim Nil Nil -- -- 8 Beta Cyfluthrin Nil Nil -- -- 9 Cypermethrin Nil Nil -- -- 10 Clodinafop- -- -- Nil Nil propargyl

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 11 Tribenuron methyl Nil Nil -- -- 12 Furathiocarb Nil Nil -- -- 13 Coumatetralyl Nil Nil -- -- 14 Methamidophos Nil Nil -- -- 15 Dicofol Nil Nil -- -- 16 Oxyfluoren Nil Nil -- -- 17 Ethoprophos Nil Nil -- -- 18 Pendimethalin Nil Nil -- -- 19 Metiram Nil Nil -- -- 20 Toxaphene Nil Nil 8.8x10-3 3.8x10-2 Zinc Phosphide as -- -- 21 Nil Nil phosphine 22 Aluminum -- -- Nil Nil Phosphate Comments: - The GC-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the GC-MS scan being used. - No International or National limits are indicated neither in residential nor industrial areas are available for the present pesticides. However, Dimethoate, Aldicarb, Zinc phosphide and Dicofol are classified as highly hazardous pesticides.

➢ Alexandria Governorate:

❑ Site (48) Alexandria Sea Port:

Table (3-34): Analysis Results of Air samples collected from Site (48), Alexandria Governorate

Analysis Results EPA Limits Test S Parameter Unit A 48 – A Residential Industrial Method A 48 – A (1) (2) Limits Limits 1 Oxamyl Nil Nil -- -- 2 Methomyl Nil Nil -- -- 3 Triazophos Nil Nil -- -- 4 Dimethoate Nil Nil -- -- Scan 5 Aldicarb µg/m3 Nil Nil -- -- GC-MS 6 Chlorophacinone Nil Nil -- -- 7 Carbendazim Nil Nil -- -- 8 Beta Cyfluthrin Nil Nil -- -- 9 Cypermethrin Nil Nil -- --

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 10 Clodinafop-propargyl Nil Nil -- -- 11 Tribenuron methyl Nil Nil -- -- 12 Furathiocarb Nil Nil -- -- 13 Coumatetralyl Nil Nil -- -- 14 Methamidophos Nil Nil -- -- 15 Dicofol Nil Nil -- -- 16 Oxyfluoren Nil Nil -- -- 17 Ethoprophos Nil Nil -- -- 18 Pendimethalin Nil Nil -- -- 19 Metiram Nil Nil -- -- 20 Toxaphene Nil Nil 8.8x10-3 3.8x10-2 Zinc Phosphide as -- -- 21 Nil Nil phosphine 22 Aluminum Phosphate Nil Nil -- -- Comments: - The GC-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the GC-MS scan being used. - No International or National limits are indicated neither in residential nor industrial areas are available for the present pesticides. However, Dimethoate, Aldicarb, Zinc phosphide and Dicofol are classified as highly hazardous pesticides.

➢ Suez Governorate:

❑ Site (44) Adabeya Port:

Table (3-35): Analysis Results of Air samples collected from Site (44), Adabeya Port, Suez Governorate

Analysis Results EPA Limits Test S Parameter Unit Method Ad 44 – A Ad 44 – A Residential Industrial (1) (2) Limits Limits 1 Oxamyl Nil Nil -- -- 2 Carbendazim Scan Nil Nil -- -- µg/m3 3 Cypermethrin GC-MS Nil Nil -- -- 4 Chloropyrifos Nil Nil -- -- Comments: - The GC-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the GC-MS scan being used. 109

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

- No International or National limits are indicated neither in residential nor industrial areas are available for the present pesticides.

3.6.3 Soil Quality Sampling and Analysis:

Soil samplings were conducted in order to characterize the quality of soil in each site. Soil samples were collected in plastic jars and analysed using a special device known as "High Performance Liquid Chromatography – HPLC-MS-MS Device".

Figure (3-50) shows a real photo for a soil sample while figure (3-51) shows a real photo for "High Performance Liquid Chromatography – HPLC-MS-MS Device".

Figure (3-50): Real photo for a soil sample

Figure (3-51): HPLC-MS-MS used in the analysis of soil and water samples 110

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Eight samples of soil were collected from the 4 sites under study as follows:

• 2 soil samples from site (18) from outside as the floor of the stores is tiles.

• 2 soil samples from site (23), from outside as the floor of the store is tiles.

• 2 soil samples from site (48), from outside as the floor of the store is concrete.

• 2 soil samples from site (44), from outside the container.

The following tables (3-36), (3-37), (3-38) and (3-39) show the analysis results of soil samples collected from site (18), (23), (48) and (44) respectively.

➢ Nubareya City, Beheira Governorate:

❑ Site (18) in Nubareya City:

Table (3-36): Analysis Results of Soil samples collected from Site (18), Nubareya City – Beheira Governorate Analysis Results EPA Limits Test S Parameter Unit UC* Method N 18 – S N 18 – S Residential Industrial (1) (2) Limits Limits 1 Oxamyl 2.4% Nil Nil 1.6x106 2.1x107 2 Methomyl 2.4% Nil Nil 1.6x106 2.1x107 3 Triazophos 2.4% 5.3 Nil -- -- 4 Dimethoate 2.4% Nil Nil 1.4x105 1.8x106 5 Aldicarb 2.4% Nil Nil 6.3x104 8.2x105 6 Chlorophacinone 2.4% Nil 142.69 -- -- 7 Carbendazim 2.4% Nil Nil -- -- 8 Beta Cyfluthrin 2.4% Nil 27.68 -- -- 9 Cypermethrin 2.4% 713.38 440.9 3.8x106 4.9x107 10 Clodinafop-propargyl 2.4% EPA Nil Nil -- -- ppb 11 Tribenuron methyl 2.4% 1699 Nil Nil 5.1x105 6.6x106 12 Furathiocarb 2.4% Nil Nil -- -- 13 Coumatetralyl 2.4% Nil Nil -- -- 14 Methamidophos 2.4% Nil 0.566 3.2x103 4.1x104 15 Dicofol 2.4% Nil Nil -- -- 16 Oxyfluorfen 2.4% Nil Nil 7.4x103 3.1x104 17 Ethoprophos 2.4% Nil Nil -- -- 18 Pendimethalin 2.4% 683.3 Nil 1.9x106 2.5x107 19 Metiram 2.4% Nil Nil -- -- 20 Toxaphene 2.4% Nil Nil 4.9x102 2.1x103

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Zinc Phosphide as 21 - Nil Nil 2.3x104 3.5x105 phosphine 22 Aluminum Phosphate 2.4% Nil Nil 3.1x104 4.7x105 Comments: - The HPLC-MS-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the HPLC- MS-MS scan being used. - The results showed compliance with all the national and International guidelines for the present pesticides. - Dimethoate, Aldicarb, Zinc Phosphide and Dicofol are classified as highly hazardous pesticides. *UC: Uncertainty

❑ Site (23) in Nubareya City:

Table (3-37): Analysis Results of Soil samples collected from Site (23), Nubareya City – Beheira Governorate Analysis Results EPA Limits Test S Parameter Unit UC* Method N 23 – S N 23 – S Residential Industrial (1) (2) Limits Limits 1 Oxamyl 2.4% Nil Nil 1.6x106 2.1x107 2 Methomyl 2.4% Nil Nil 1.6x106 2.1x107 3 Triazophos 2.4% Nil Nil -- -- 4 Dimethoate 2.4% Nil Nil 1.4x105 1.8x106 5 Aldicarb 2.4% Nil Nil 6.3x104 8.2x105 6 Chlorophacinone 2.4% Nil Nil -- -- 7 Carbendazim 2.4% Nil Nil -- -- 8 Beta Cyfluthrin 2.4% Nil 66.96 -- -- 9 Cypermethrin 2.4% 523.11 484.17 3.8x106 4.9x107 10 Clodinafop-propargyl 2.4% EPA Nil Nil -- -- ppb 11 Tribenuron methyl 2.4% 1699 Nil Nil 5.1x105 6.6x106 12 Furathiocarb 2.4% Nil Nil -- -- 13 Coumatetralyl 2.4% Nil Nil -- -- 14 Methamidophos 2.4% 0.059 Nil 3.2x103 4.1x104 15 Dicofol 2.4% 7.25 Nil -- -- 16 Oxyfluorfen 2.4% Nil Nil 7.4x103 3.1x104 17 Ethoprophos 2.4% Nil Nil -- -- 18 Pendimethalin 2.4% Nil Nil 1.9x106 2.5x107 19 Metiram 2.4% Nil Nil -- -- 20 Toxaphene 2.4% Nil Nil 4.9x102 2.1x103

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 21 Zinc Phosphide as - 0.004 Nil 2.3x104 3.5x105 phosphine 22 Aluminum Phosphate 2.4% Nil Nil 3.1x104 4.7x105 Comments: - The HPLC-MS-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the HPLC- MS-MS scan being used. - The results showed compliance with all the national and International guidelines for the present pesticides. - Dimethoate, Aldicarb, Zinc Phosphide and Dicofol are classified as highly hazardous pesticides. *UC: Uncertainty ➢ Alexandria Governorate:

❑ Site (48) Alexandria Sea Port:

Table (3-38): Analysis Results of Soil samples collected from Site (48), Alexandria Governorate Analysis Results EPA Limits Test S Parameter Unit UC* Method A 48 – S A 48 – S Residential Industrial (1) (2) Limits Limits 1 Oxamyl 2.4% Nil Nil 1.6x106 2.1x107 2 Methomyl 2.4% Nil Nil 1.6x106 2.1x107 3 Triazophos 2.4% Nil Nil -- -- 4 Dimethoate 2.4% Nil Nil 1.4x105 1.8x106 5 Aldicarb 2.4% Nil Nil 6.3x104 8.2x105 6 Chlorophacinone 2.4% Nil Nil -- -- 7 Carbendazim 2.4% Nil Nil -- -- 8 Beta Cyfluthrin 2.4% 315.47 26.52 -- -- 9 Cypermethrin 2.4% 551.28 433.09 3.8x106 4.9x107 Clodinafop- 2.4% EPA 10 ppb Nil Nil -- -- propargyl 1699 11 Tribenuron methyl 2.4% Nil Nil 5.1x105 6.6x106 12 Furathiocarb 2.4% Nil Nil -- -- 13 Coumatetralyl 2.4% Nil Nil -- -- 14 Methamidophos 2.4% Nil 0.14 3.2x103 4.1x104 15 Dicofol 2.4% Nil Nil -- -- 16 Oxyfluoren 2.4% Nil Nil 7.4x103 3.1x104 17 Ethoprophos 2.4% Nil Nil -- -- 18 Pendimethalin 2.4% Nil 895.4 1.9x106 2.5x107 19 Metiram 2.4% Nil Nil -- --

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 20 Toxaphene 2.4% Nil Nil 4.9x102 2.1x103 Zinc Phosphide as 21 - 0.03 0.02 2.3x104 3.5x105 phosphine Aluminum 2.4% 22 Nil Nil 3.1x104 4.7x105 Phosphate Comments: - The HPLC-MS-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the HPLC- MS-MS scan being used. - The results showed compliance with all the national and International guidelines for the present pesticides. - Dimethoate, Aldicarb, Zinc Phosphide and Dicofol are classified as highly hazardous pesticides. *UC: Uncertainty

➢ Suez Governorate:

❑ Site (44) Adabeya Port:

Table (3-39): Analysis Results of Soil samples collected from Site (44), Adabeya Port, Suez Governorate Analysis Results EPA Limits Test S Parameter Unit UC* Method Ad 44 – Ad 44 – Residential Industrial S (1) S (2) Limits Limits 1 Oxamyl 2.4% 0.018 0.018 1.6x106 2.1x107 2 Carbendazim 2.4% EPA Nil Nil -- -- Ppb 3 Cypermethrin 2.4% 1699 0.079 0.119 3.8x106 4.9x107 4 Chloropyrifos 2.4% Nil Nil -- -- - The HPLC-MS-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the HPLC- MS-MS scan being used. - The results showed compliance with all the national and International guidelines for the present pesticides. *UC: Uncertainty

3.6.4 Water Quality Sampling and Analysis:

Water samplings were conducted in order to characterize the quality of nearest water sources to each site. Water samples were collected in plastic bottles and analysed by using a special device known as "High Performance Liquid Chromatography – HPLC- MS-MS Device".

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Figure (3-52) shows a real photo for a water sample while the real photo for "High Performance Liquid Chromatography – HPLC-MS-MS Device" in shown earlier in figure (3-51).

Figure (3-52): A real photo for water samples

Six samples of water were collected from the 4 sites under study as follows:

• 1 water samples from the nearest agricultural drain to site (18) which is 2 Km away from the site.

• 2 water samples from the nearest agricultural drains to site (23), one of them is 1 Km away from the site while the other is 2.5 Km away from the site.

• 1 water sample from the sea which is 300 m away from site (48).

• 2 water samples from the sea which is <1 Km away from site (44).

Note: Only surface water samples were collected from the nearest water sources to the proposed sites because ground water level in all sites was >10 m).

The following tables (3-40), (3-41), (3-42) and (3-43) show the analysis results of water samples collected from site (18), (23), (48) and (44) respectively.

➢ Nubareya City, Beheira Governorate:

❑ Site (18) in Nubareya City:

Table (3-40): Analysis Results of water samples collected from Site (18), Nubareya City – Beheira Governorate S Parameter Unit UC* Analysis Results EPA Limits

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Test International N 18 – W (1) Method Limits 1 Oxamyl 2.4% Nil 110 2 Methomyl 2.4% Nil 110 3 Triazophos 2.4% Nil -- 4 Dimethoate 2.4% Nil 9.9 5 Aldicarb 2.4% Nil 4.9 6 Chlorophacinone 2.4% 259.3 -- 7 Carbendazim 2.4% Nil -- 8 Beta Cyfluthrin 2.4% 73.97 -- 9 Cypermethrin 2.4% 62.06 1.9x105 10 Clodinafop-propargyl 2.4% Nil -- 11 Tribenuron methyl 2.4% Nil 61 EPA 12 Furathiocarb Ppb 2.4% Nil -- 1699 13 Coumatetralyl 2.4% Nil -- 14 Methamidophos 2.4% 0.25 0.21 15 Dicofol 2.4% 3.53 -- 16 Oxyfluoren 2.4% Nil 43 17 Ethoprophos 2.4% 0.082 -- 18 Pendimethalin 2.4% 26707.09 1600 19 Metiram 2.4% Nil -- 20 Toxaphene 2.4% Nil 11 21 Zinc Phosphide as -- - Nil phosphine 22 Aluminum Phosphate 2.4% Nil -- Comments: - The HPLC-MS-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the HPLC-MS-MS scan being used. - The results showed compliance with all the International guidelines for the present pesticides except for Methamidophos and Pendimethalin. - No National limits are available. - Dimethoate, Aldicarb, Zinc Phosphide and Dicofol are classified as highly hazardous pesticides. *UC: Uncertainty

❑ Site (23) in Nubareya City: Table (3-41): Analysis Results of water samples collected from Site (23), Nubareya City – Beheira Governorate Analysis Results EPA Limits Test S Parameter Unit UC* N 23 – W International Method N 23 – W (1) (2) Limits 1 Oxamyl ppb 2.4% Nil Nil 110 116

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 2 Methomyl 2.4% EPA Nil Nil 110 3 Triazophos 2.4% 1699 Nil Nil -- 4 Dimethoate 2.4% Nil Nil 9.9 5 Aldicarb 2.4% Nil Nil 4.9 6 Chlorophacinone 2.4% 23.21 Nil -- 7 Carbendazim 2.4% Nil Nil -- 8 Beta Cyfluthrin 2.4% 117.44 146.18 -- 9 Cypermethrin 2.4% 76.63 53.61 1.9x105 10 Clodinafop-propargyl 2.4% Nil Nil -- 11 Tribenuron methyl 2.4% Nil Nil 61 12 Furathiocarb 2.4% Nil Nil -- 13 Coumatetralyl 2.4% Nil Nil -- 14 Methamidophos 2.4% 0.39 0.33 0.21 15 Dicofol 2.4% Nil Nil -- 16 Oxyfluoren 2.4% Nil Nil 43 17 Ethoprophos 2.4% Nil Nil -- 18 Pendimethalin 2.4% 88.06 125.93 1600 19 Metiram 2.4% Nil Nil -- 20 Toxaphene 2.4% Nil Nil 11 21 Zinc Phosphide as - Nil Nil -- phosphine 22 Aluminum Phosphate 2.4% Nil Nil -- Comments: - The HPLC-MS-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the HPLC-MS-MS scan being used. - The results showed compliance with all the International guidelines for the present pesticides except for Methamidophos. - No National limits are available. - Dimethoate, Aldicarb, Zinc Phosphide and Dicofol are classified as highly hazardous pesticides. *UC: Uncertainty

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez ➢ Alexandria Governorate:

❑ Site (48) Alexandria Sea Port:

Table (3-42): Analysis Results of Water samples collected from Site (48), Alexandria Governorate Analysis Results EPA Limits Test S Parameter Unit UC* International Method A 48 – W (1) Limits 1 Oxamyl 2.4% Nil 110 2 Methomyl 2.4% Nil 110 3 Triazophos 2.4% Nil -- 4 Dimethoate 2.4% Nil 9.9 5 Aldicarb 2.4% Nil 4.9 6 Chlorophacinone 2.4% 295.71 -- 7 Carbendazim 2.4% Nil -- 8 Beta Cyfluthrin 2.4% Nil -- 9 Cypermethrin 2.4% 58.23 1.9x105 10 Clodinafop-propargyl 2.4% Nil -- 11 Tribenuron methyl 2.4% Nil 61 12 Furathiocarb Ppb 2.4% EPA 1699 Nil -- 13 Coumatetralyl 2.4% Nil -- 14 Methamidophos 2.4% Nil 0.21 15 Dicofol 2.4% Nil -- 16 Oxyfluoren 2.4% Nil 43 17 Ethoprophos 2.4% Nil -- 18 Pendimethalin 2.4% Nil 1600 19 Metiram 2.4% Nil -- 20 Toxaphene 2.4% Nil 11 21 Zinc Phosphide as - Nil -- phosphine 22 Aluminum Phosphate 2.4% Nil -- Comments: - The HPLC-MS-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the HPLC- MS-MS scan being used. - The results showed compliance with all the International guidelines for the present pesticides. - No National limits are available. - Dimethoate, Aldicarb, Zinc Phosphide and Dicofol are classified as highly and Extremely hazardous pesticides. *UC: Uncertainty

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez ➢ Suez Governorate:

❑ Site (44) Adabeya Port:

Table (3-43): Analysis Results of Water samples collected from Site (44), Adabeya Port, Suez Governorate Analysis Results EPA Limits Test S Parameter Unit UC* Ad 44 – W Ad 44 – W International Method (1) (2) Limits 1 Oxamyl 2.4% Nil Nil 110 2 Carbendazim 2.4% Nil Nil -- ppb EPA 1699 3 Cypermethrin 2.4% 0.054 0.056 1.9x105 4 Chloropyrifos 2.4% Nil Nil -- Comments: - The HPLC-MS-MS scan represents some organic compounds out of the TOR pesticide list, they may be observed as a result of the decomposition of listed pesticides. - "NIL" indicates a very low presence of the pesticides according to the detection limit of the HPLC- MS-MS scan being used. - The results showed compliance with all the International guidelines for the present pesticides. - No National limits are available. *UC: Uncertainty 3.7 Sampling Procedure: Sampling procedures will follow the EPA Guidelines and Protocols for Soil Sampling13. Collection of soil samples is performed using coring or spooning methods. Following are the details of sampling procedure.

3.7.1 Soil samples: Soil samples are taken within the site when accumulations of soil can be gathered in sufficient quantities to be analysed in the laboratory (approx. 600g of soil). Outside the OPs stores in the sites under study, Soil samples were collected within the likely contaminated area designated. In general, the following equipment was used: • Self-closing plastic bags for use as soil collection containers. • Spoon or garden troll lead free. • Steel or plastic measuring tape. • Plastic gloves, powderless. • Permanent ink marker. • Clean-up equipment - disposable towels, bottle of water, and soap.

13 EPA Soil Sampling, August 2014 119 December 2007.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez To ensure that no cross contamination occurred between sampling positions the following was conducted:

1. After a bulk sample was taken, the trowel or other instrument was decontaminated using low phosphate detergent and water and then rinsed with weak hydrochloric acid followed by a distilled water rinse.

2. Brushes were used only on a one-time basis.

3. Latex gloves were removed and disposed of after each sampling event.

The samples were placed in a cooler with ice and sent to the laboratory for analysis. Ice was double bagged to prevent moisture in the cooler from destroying sample labels.

3.7.2 Sample Identification: All samples were given a unique identifier that was descriptive of the sample that follows the format shown below. Sample ID: Site ID – Sample Location – Type of Sample (soil, air, or water) – Date.

3.7.3 Sample Labels: Sample containers were labelled to identify the sample and specify the analyses required. All information requested on the laboratory-printed labels is listed below and should be provided. Labels were filled out using permanent ink marking pens. • Sampler Name: • Project Name or Site: • Project Number: • Sample Date/Time: • Sample Name: • Sample Type: • Analyses Requested: e.g., EPA Method Number • Preservatives Used: As required by method

3.7.4 Sample Chain of Custody: Sample chain of custody documentation must accompany every shipment of samples to the laboratories. This documentation is important because it informs the laboratories what they are receiving, what analyses to perform, and is used to track and document sample condition on receipt, sample discrepancies, and to sample handling procedures throughout the sampling and analysis process. The field personnel will fill out all applicable fields on the Chain of Custody Forms. Data are to be reported to the project manager or task manager by the laboratories. The Chain of Custody Form is generally provided in carbonless paper forms. After filling

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez out and signing the form, the sampler will remove his copy and retain it with the project records. The remaining copies will be removed as the samples move through the shipment and analysis processes. The final copy will be returned to the project with the analytical reports. Where multi-page chain of custody forms are not provided, a photocopy must be taken and retained each time the samples are transferred.

3.7.5 Sample Shipment and Packaging: Samples are packaged in coolers provided by the laboratories with ice and suitable packaging material to prevent damage during shipment. Bubble-wrap packaging material will be provided with the sample kits. Ice should be double bagged in re- sealable plastic bags (to prevent water from damaging sample labels) and placed on top of the sample containers. A shipping label, addressed to the laboratory and from the project, will be adhered to the sealed cooler. The Project Number will be shown in the reference field and the laboratory’s label. The completed shipping container should be delivered on the day of sampling and marked for next day standard delivery. If this is not possible, the samples should be refrigerated overnight and re-packed with ice prior to delivery to the laboratory.

3.7.6 Decontamination: All equipment that comes in contact with sampled soils must first be decontaminated to prevent possible cross contamination between samples that could bias analytical results. Equipment requiring decontamination for this project includes the hand auger, stainless steel bowl, sampling spoons and other hand tools. The equipment are decontaminated prior to use and between samples by washing the (disassembled) sampling equipment using a non-phosphate detergent (Alconox) in water and triple rinsing the washed parts with de-ionized water. The equipment is wrapped with aluminium foil after it is decontaminated to protect it and keep it ready for its next use.

3.7.7 Laboratory Analysis Samples that are shipped out for laboratory testing were analysed for parameters shown in previous tables. The analytical methods that were used and their corresponding standard method numbers are documented (EPA 1699). The laboratory provided a report including all analysis results for all sites are attached in Annex (4). The report also includes: • Standard method used. • Methodology. • QA/QC Plans.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3.8 Quality Control Procedures:

3.8.1 Field Quality Control:

Quality control and Quality assurance (QC/QA) begins in the field and continues on through the analysis procedure. In the field the following actions are taken: • One person is selected to be in charge of QA/QC. This QA/QC manager or safety officer will assure that all personnel have the proper personal protection equipment and sampling gear. He will also make sure that the procedures in the Sampling and Analysis Plan are followed. • In the field, each sampler is responsible for understanding sampling procedures and QA/QC protocols. • To ensure that samples are being analysed correctly in the laboratory, additional samples are taken. For bulk dust samples, a least one-split sample will be taken per 20 samples taken. For a split sample, a 500-gram sample will be taken. It will be well mixed with 1/2 or 200 grams being placed in a second bag. This bag is labelled as other bags but with a location that is fictitious and known only to the QA/QC Manager. For the Wipe Samples, a blank sample was sent to the laboratory for analysis. The blank sample consists of a wipe that has not been used or contaminated. It placed in a tube and labelled as usual with a fictitious location known only to QA/QC Manager. • Once the analyses are complete, the QA/QC reviewed the data to check for accuracy of the analyses by comparing QA/QC samples to those taken in the field and report on the results. The QA/QC Manager looked for suspicious analysis that appears out of place in the data set.

3.8.2 Laboratory Quality Control:

Laboratory quality control procedures adopted for this report are delineated by the laboratory to conform to the Bureau of Laboratory Improvement "Rules for the Certification of Laboratories” that establish the minimum laboratory quality assurance activities required for laboratory certification. Specific procedures addressed by the Laboratory’s Quality Assurance Plan include: • Sample Management. • Reagent/Standard Preparation. • General Laboratory Techniques. • Test Methods (sample preparation and analysis procedures, instrument standardization precision and bias, detection and reporting limits, and analytical method-specific quality control procedures). • Equipment Calibration and Maintenance. • QC Samples (type, purpose, frequency, acceptance criteria). 122

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • Corrective Action. • Data Reduction and Validation. • Reporting. • Records Management.

With minor exceptions, the items identified above are activities and procedures that are addressed internally by the laboratory at the level of data quality required for this project. However, the project’s personnel might scrutinize the laboratory reports produced for this project as an additional check of data quality. Specific items to be assessed are:

Data Package Completeness: The laboratory report was assessed to confirm that they include a case narrative, appropriate method and/or practical quantization limits, and sample custody documentation.

Laboratory QC Samples: The adequacy of laboratory control procedures was verified by determining whether laboratory quality control samples are within established control limits; these methods are:

• Method blanks will be assessed to identify potential sources of laboratory error associated with the samples. • Matrix spike samples will be evaluated to ensure that adequate surrogate recoveries have been achieved for the selected analyses. • Matrix spike duplicates will be evaluated to verify precision in the laboratory’s methodology of each type of analysis. Specifically, matrix spikes and matrix spike duplicates will be evaluated to determine whether reproducibility’s are consistent with project data quality goals as measured by Relative Percent Difference (%RPD).

Sample holding Times: Since each standard analytical method to be performed for the project has a specific holding time, within which sample integrity is judged to be adequate, the date of sample collection, extraction/preparation, and analyses will be checked for all analyses. Proper sample preservation will also be documented.

Detection Limits: Laboratory reports will be reviewed to verify that all requested analyses have been reported. Confirmation that analytical method detection limits are adequate to compare the data with published site clean-up objectives will be verified.

Performance Evaluation: Analytical data will be reviewed to confirm that these data quality criteria have been adequately addressed. Precision, accuracy, representativeness, comparability and completeness (PARCC) parameters will be addressed as part of this evaluation.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3.8.3 Analysis Plan:

Shipped samples off site for laboratory testing will be analysed for detecting the pollutants concentration in all media.

Used analytical methods and their corresponding EPA method numbers or equivalent will be documented.

The method number will be used on the sample labels and Chain of Custody Forms to describe the requested tests.

3.8.4 Workers Protection:

Due to the presence of many banned and obsolete pesticides and the different purposes of their use according to their general condition and severity; some precautions must be taken and occupational safety and health rules must be followed when dealing with such pesticides.

Therefore, PPE is implanted into the site for the workers’ safety. PPE is defined as equipment, tools and protective measures used to protect the worker from injuries and risks that he may be exposed to during the period of work at the facility.

PPE is the first line of defence to protect workers from the harm they may suffer due to working conditions. PPE should be chosen to conform to international standards in order to minimize the risks to which the workers are exposed. There are several types of PPE covering almost all body parts. Each type of equipment depends on the nature of the hazards in the working environment and the purpose for which the equipment is used. Personal Protection Equipment (PPE) of at least level (B) as per OSHA and EPA classification provided to all personal working on site.

The following equipment constitute (Level B) PPE:

1. Positive-pressure (pressure-demand), self-contained breathing apparatus (NIOSH approved), or positive-pressure supplied air respirator with escape SCBA. 2. Chemical Resistant Clothing (overalls and long-sleeved jacket, coveralls, hooded two-piece chemical splash suit, disposable chemical resistant coveralls.) 3. Gloves, outer, chemical resistant. 4. Gloves, inner, chemical resistant. 5. Boots, outer, chemical resistant, steel toe and shank.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Figure (3-53): Level (B) Personal Protective Equipment

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 4. IMPACT IDENTIFICATION AND MITIGATION QUANTITATIVE RISK ASSESSMENT STUDY

Introduction

Obsolete pesticides are defined as those pesticides that can no longer be used for their intended purpose or wanted to be used and therefore must be disposed of.

The main reasons leading to the accumulation of banned & expired pesticides are: • The product has been withdrawn for health or environmental reasons (e.g. through banning worldwide or withdrawal of registration, policy decision issued by the Ministry of Agriculture). • The product has deteriorated as a result of improper or prolonged storage and can no longer be used according to its label specifications and use instructions, nor can it easily be reformulated to be usable again. • The pesticide has undergone chemical / physical changes that result in phytotoxic effects on the crop, or an unacceptable hazard to human health or the environment. • Presence of financing programs that provide pesticides and leave the rest within the country after the end of these programs. • Presence of advertisements that market for the ineffective pesticides. • Importing more quantities than required. • Poor coordination between the different authorities which led to the non-use of excess pesticides in other departments.

The study will present the risk assessment associated with OPs handling in North Delta province which includes 3 sites and Adabeya port which includes 1 site as follows:

1. Site (18): includes 6 stores, and belongs to the Ministry of Agriculture & Land Reclamation, Nubareya city, Beheira Governorate. 2. Site (23): belongs to the Ministry of Agriculture & Land Reclamation, Nubareya city, Beheira Governorate. 3. Site (48): first & third floor at the abandoned goods building, Alexandria Port. 4. Site (44): it is a container that belongs to the Adabeya port authority- Suez Governorate.

The risk study includes two main parts; the risk assessment for all operation stages such as entering the Store, handling of OPs, repacking of OPs, removal of repacked OPs and finally loading to trucks, and also the risk assessment for the site effect on the surrounding sensitive habitats such as residential area, surface water,…etc.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

4.1 Risk Assessment Steps The following part of the study is the risk assessment of site (23) at Nubareya city with all stored OPs which is taken as a model for the four sites under study. This risk assessment tables for all sites are included in Annex (3) of this report.

This assessment incorporates several steps leading to the identification of the risk mitigation.

Step 1: Hazard Identification of OPs under Consideration

The OPs in consideration will be classified as per its hazard as well as its physical state (liquid or powder) as indicated in the previous table. The hazard of these OPs was classified as per the WHO14, EPA15, as well as the MSDS16 of each OP as shown in the following Table. Table (4-1): Hazard of each OP at Beheira Agriculture Directorate site (23)

Hazard of Pesticides Liquid Pesticide (Sludge) Carcinogenetic Pesticide Name Toxicity Other Hazard Flammability Exposure Effect Active ingredient is poisoning Exposure may cause: (cholinesterase Group C‐‐Possible Dermal absorption: The product is flammable Headache, nausea, cramps, Dimethoate inhibitor). Human May cause hypersensitivity by skin it could explode at high weakness, blurred vision, Toxic in contact with Carcinogen. contact. temperature. tightness in chest, and skin as it rapidly other (see MSDS) enters the body. Very toxic to aquatic Exposure may cause: organisms; may cause Group C‐‐Possible Thermal decomposition May be fatal if inhaled, irritate the skin and eyes. long-term adverse Human may emit toxic fume of harmful if swallowed Proved to be carcinogenic effects in aquatic Carcinogen. hydrogen Cyanide in rat and mice Cypermethrin environment

14 The WHO Recommended Classification of Pesticides by Hazard, Guidelines to Classification 2009 15 Chemicals Evaluated for Carcinogenic Potential Annual Cancer Report 2017, US EPA 16 MSDS of each material 127

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Acute oral LD50: Skin Contact Fire and Explosion Eye contact: May cause 1100 mg/kg May irritate skin. The dermal Hazard: Vapours may irritation. Acute dermal LD50: toxicity of this product is low. form explosive mixtures Skin contact: May cause > 2000 mg/kg. However, skin contact should be with air. Heating can irritation. Acute inhalation avoided. This product is not a skin release vapours Ingestion: May cause LC50 : >320 mg/l sensitiser. nausea, vomiting, and Acute skin Eye Contact diarrhea. irritation: M This product may be mildly Inhalation: May cause ild skin irritation. irritating to eyes. However, it is irritation. Acute eye irritation: unlikely to cause any more than Mild eye irritation. mild transient discomfort. It is also Dermal unlikely to cause any lasting sensitization: Not a effects. skin sensitizer. Inhalation Group C‐‐Possible Pendimethalin Teratogenicity: May be a slight respiratory irritant. Human Carcinogen None Ingestion Mutagenicity: None The acute toxicity of this product is low, but it may be harmful if a large amount is swallowed. May cause nausea, vomiting, and diarrhoea. Environmental Slight toxic to aquatic organisms. Fire and Explosion Flammable and explosive at high temperature Main hazard: Pendimethalin is highly toxic to aquatic organisms. Flammable.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez WHO Ib; EPA I Eye contact: Irritating to eyes. Likely routes of A compound which Skin contact: Mildly irritating to exposure: inhibits skin. May be absorbed from the cholinesterase Symptoms of exposure to the gastrointestinal tract, enzyme activity in product include: nausea, through the intact skin, the nervous tissue. It headache, tiredness, giddiness, and through inhalation of is of very high blurred vision and pupillary fine spray mist or dust. toxicity. Contact with constriction. Depending on skin, inhalation of severity of poisoning these Eye contact: Highly toxic. dust or spray, or symptoms become worse with the Irritating to eyes. Not Likely To Be swallowing may be onset of vomiting, abdominal pain, Methamidophos Carcinogenic to Flammable fatal. diarrhoea, sweating and salivation. Skin contact: Highly Humans. Toxic to fish and Confusion, ataxia, slurred speech, toxic, due to possible bees. loss of reflexes are some of the absorption. Mildly central nervous system effects may irritating to skin. lead to misdiagnosis of acute alcoholism. Ingestion: Highly toxic by ingestion.

Inhalation: Highly toxic by inhalation, depends on volatility of compound.

Information on Classification of the substance or Flammability (solid, Toxic by inhalation. toxicological effects mixture gas): No data available Very toxic if swallowed. Acute toxicity Classification according to Upper/lower Very toxic to aquatic No data available Regulation (EC) No 1272/2008 flammability: No data organisms may cause Skin Not Likely To Be Acute toxicity, Oral (Category 2), available long-term adverse effects Beta Cyfluthrin corrosion/irritation Carcinogenic To H300 explosive limits: No data in No data available Humans. Acute toxicity, Inhalation available the aquatic environment. Serious eye (Category 3), H331 Reactivity: No data damage/eye Acute aquatic toxicity (Category available irritation 1), H400 Chemical stability: No data available Chronic aquatic toxicity Stable under Respiratory or skin (Category 1), H410 recommended storage

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez sensitisation Classification according to EU conditions. Germ cell Directives 67/548/EEC or Possibility of hazardous mutagenicity 1999/45/EC reactions: No data No data available T+ Very toxic :R28 available Carcinogenicity T Toxic :R23 Conditions to avoid: No IARC: No N Dangerous for the environment : data available component of this R50/53 Incompatible materials: product present at Label elements Strong oxidizing agents levels greater than or Labelling according Regulation Hazardous equal to 0.1% is (EC) No 1272/2008 decomposition products identified as Pictogram Other decomposition probable, possible or Signal word : Danger products - No data confirmed human Hazard statement(s) available carcinogen by IARC. H300 : Fatal if swallowed. Reproductive H331: Toxic if inhaled. toxicity H410: Very toxic to aquatic life No data available with long lasting effects. Specific target Precautionary statement(s) organ toxicity - P261: Avoid breathing dust. single exposure P264: Wash hands thoroughly after No data available handling. Specific target P273: Avoid release to the organ toxicity - environment. repeated exposure P301 + P310: IF SWALLOWED: No data available Immediately call a POISON Aspiration hazard CENTER or doctor/ No data available physician. Additional P311: Call a POISON CENTER or Information doctor/ physician. RTECS: Not P501: Dispose of contents/ available container to an approved waste disposal plant. Supplemental Hazard: none Statements According to European Directive

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 67/548/EEC as amended. Hazard symbol(s: T+ Very toxic N Dangerous for the environment R-phrase(s) R23 : Toxic by inhalation. R28: Very toxic if swallowed. R50/53: Very toxic to aquatic organisms may cause long-term adverse effects in the aquatic environment. S-phrase(s) S28: After contact with skin, wash immediately with plenty of soap and water. S36/37/39: Wear suitable protective clothing, gloves and eye/face protection. S45: In case of accident or if you feel unwell, seek medical advice immediately (show the label where possible). S60: This material and its container must be disposed of as hazardous waste. S61: Avoid release to the environment. Refer to special instructions/ Safety data sheets. Other hazards – none

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Organ toxicity: Group E‐‐Evidence May be fatal if swallowed. Combustible. Do not use Eye: Irritating, and may Chlorpyrifos Of Non‐ Harmful if absorbed through skin or store near heat or open injure eye tissue if not primarily affects the Carcinogenicity For or inhaled. Causes eye irritation. flame removed promptly. nervous system Humans. through inhibition of Symptoms of Over Exposure: Skin: Harmful if absorbed cholinesterase, an Headaches, nausea, vomiting, through the skin. Large enzyme required for cramps, weakness, blurred vision, exposures could be fatal. proper nerve pinpoint pupils, tightness in chest, Chlorpyrifos functioning. laboured breathing, nervousness, Inhalation: Vapour or Effects on aquatic sweating, watering of eyes, mist concentrations may organisms: drooling, muscle spasms and be harmful if inhaled. Chlorpyrifos is very coma. High concentrations could highly toxic to be fatal. freshwater fish, aquatic invertebrates Ingestion: May be fatal if and estuarine and swallowed. marine organisms.

Organ toxicity: Group C‐‐Possible More important danger for the Combustible. Liquid TWA: 0.1 mg/m3 (8 hrs) Chronic exposure to Human man: inhibition of acetyl formulations containing Contact with the skin: dicofol can cause Carcinogen. cholinesterase and problem organic solvents may be May be absorbed! damage to the kidney, accumulation. Prolonged or flammable. Gives off Redness. liver, and repeated exposure to dicofol can irritating or toxic fumes Contact with the eyes: heart. cause the same effects and (or gases) in a fire. Redness Dangers for the symptoms as acute exposure. Inhalation: Confusion. environment: The Prolonged or repeated skin contact Convulsions. Cough. Dicofol substance is very can cause moderate Dizziness. Headache. toxic to aquatic skin irritation and/or sensitization Nausea. organisms. In the of the skin. Vomiting.Weakness. food chain important Disorientation. to humans, Ingestion: Abdominal bioaccumulation pain. Diarrhoea. Nausea takes place, specifically in fish. Physical-chemical

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez dangers: The substance decomposes on heating, on burning or on contact with acids or acid fumes, producing toxic and corrosive fumes including chlorine.

Group C‐‐Possible Inhalation: Material may be irritant Combustible liquid Human to mucous membranes and Carcinogen. respiratory tract. Skin Contact with skin may result in irritation. May cause skin sensitization in sensitive individuals. May cause transient tingling or numbness in exposed areas. May be an eye irritant. Alpha- Ingestion: Swallowing can result in Cypermethrin tremors, loss of motor control and greater sensitivity to sound.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Powder Pesticide Acute oral LD50 Hazard Phrases: Flammable properties: Fatal if swallowed. rats: 167 mg/kg Fatal if swallowed. Not flammable. Toxic Fatal if inhaled. Acute dermal LD50 Fatal if inhaled. dust and irritating fumes Very toxic to aquatic life. rabbits: >2 150 Very toxic to aquatic life. may be produced during Very toxic to aquatic life mg/kg Very toxic to aquatic life with long fires. with long lasting effects Inhalation LC50 lasting effects IF SWALLOWED: rats: 0.084 mg/ air Precaution Phrases: Immediately call a (4h) Do not breathe POISON CENTER or Acute eye irritation: {dust/fume/gas/mist/vapors/spray}. doctor/physician. Mildly irritating. Wash {hands} thoroughly after IF INHALED: Remove Acute skin handling. victim to fresh air and irritation: Mildly Avoid release to the environment. keep at rest in a position irritating. Wear respiratory protection comfortable for breathing. Sensitisation in P284: Wear respiratory protection Specific treatment is guinea pig: None. Response Phrases: urgent Teratogenicity: Not Likely To Be IF SWALLOWED: Immediately Rinse mouth. Carbofuran No teratogenicity Carcinogenic To call a POISON CENTER or Collect spillage shown. Humans doctor/physician. Adverse Human Health Mutagenic effects: IF INHALED: Remove victim to Fatal if inhaled or Not considered to be fresh air and keep at rest in a swallowed. mutagenic position comfortable for breathing. Effects and Symptoms: Main Hazard: Specific treatment is urgent Material may be irritating Contact with skin, Rinse mouth. to the mucous membranes inhalation of dust or Collect spillage and upper respiratory tract. granules or Adverse Human Health May be harmful by skin swallowing may be Fatal if inhaled or swallowed. absorption. fatal.. Effects and Symptoms: May cause eye, skin, or Fire and explosion Material may be irritating to the respiratory system hazard: mucous membranes and upper irritation. Product is not respiratory tract. Very toxic to aquatic life flammable. May be harmful by skin with long lasting effects. Environmental absorption. To the best of our hazards: May cause eye, skin, or respiratory knowledge, the Toxic to fish. system irritation. toxicological properties

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Effects and Very toxic to aquatic life with long have not been thoroughly Symptoms: lasting effects. investigated Symptoms of To the best of our knowledge, the overexposure include toxicological properties have not Effects and Symptoms: headache, light- been thoroughly investigated Symptoms of headedness, overexposure include weakness, abdominal headache, light- cramps, nausea, headedness, weakness, excessive salivation, abdominal cramps, nausea, perspiration, excessive salivation, blurred vision, perspiration, tearing, pin-point blurred vision, tearing, pupils, blue skin pin-point pupils, blue skin colour, convulsions, colour, convulsions, tremor and coma. tremor and coma. Ingestion: Ingestion: Very toxic. Very toxic. . Skin contact: Mild irritant. Conditions of increased temperature and humidity may aid skin absorption and promote increased toxicity. Eye contact: Mild irritant. Contains a granular material (clay) that may cause mechanical irritation to the eyes

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Information on Group C‐‐Possible Classification according to Harmful by inhalation, toxicological effects Human Carcinogen Regulation (EC) No 1272/2008 ingestion, or skin Acute toxicity Germ cell mutagenicity (Category absorption. LD50 Oral - rat - 1B), H340 Cause eye, skin, or 6.400 mg/kg Reproductive toxicity (Category respiratory system LD50 Dermal - rabbit 1B), H360FD Flammability (solid, gas): irritation. - 8.500 mg/kg Acute aquatic toxicity (Category no data available Cause genetic defects. Skin 1), H400 Upper or lower Damage fertility or the corrosion/irritation Chronic aquatic toxicity (Category flammability: no data unborn child. no data available 1), H410 available Very toxic to aquatic life Serious eye Reactivity with long lasting effects. damage/eye Classification according to EU no data available Material may be irritating irritation Directives 67/548/EEC or Chemical stability to the mucous membranes no data available 1999/45/EC Stable under and upper respiratory tract Respiratory or skin R46 recommended storage sensitisation N Dangerous for the R50/53 conditions. no data available environment Possibility of hazardous Carbendazim Germ cell R60, R61 reactions mutagenicity no data available May alter genetic Label elements Conditions to avoid material. Labelling according Regulation no data available In vivo tests showed (EC) No 1272/2008 Incompatible materials mutagenic effects Pictogram Strong oxidizing agents Reproductive Signal word Danger Hazardous toxicity Hazard statement(s) decomposition products May cause congenital H340 May cause genetic defects. Other decomposition malformation in the H360FD May damage fertility. products - no data fetus. May damage the unborn child. available Presumed human H410 Very toxic to aquatic life In the event of fire reproductive toxicant with long lasting effects. May cause Precautionary statement(s) reproductive P201 Obtain special instructions disorders. before use. Specific target P273 Avoid release to the organ toxicity - environment.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez single exposure P308 + P313 IF exposed or no data available concerned: Get medical advice/ Specific target attention. organ toxicity - P501 Dispose of contents/ repeated exposure container to an approved waste no data available disposal plant. Aspiration hazards Supplemental Hazard none no data available Statements Additional Restricted to professional users. Information Other hazards – none RTECS: DD6500000 To the best of our knowledge, the chemical, physical, and toxicological properties have not been thoroughly investigated.

May be lethal if Group E‐‐Evidence Eyes Lower explosion limit Methomyl TLV (ACGIH) absorbed through Of Non‐ May irritate eyes. May cause acute lower flammability limit : 0.Exposure Guidelines eyes: a rabbit died via Carcinogenicity For acetyl cholinesterase depression., 0.096 g/l Exposure Limit Values ocular Humans Abnormal tearing, constriction of 2 mg/m3 TWA Inhalable exposure. This pupils, Blurred vision. fraction and vapor exposure was within Inhalation the equivalent range May cause acute acetyl Methomyl that cholinesterase depression. produced mortalities Symptoms and signs via oral include headache, dizziness, administration. fatigue, muscular weakness, May cause acute drowsiness and acetyl cholinesterase in extreme cases, loss of depression. consciousness., Nausea, Symptoms and signs Abdominal pain,

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez include headache, Abnormal tearing, Abnormal dizziness, fatigue, salivation, constriction of pupils, muscular weakness, Blurred vision, drowsiness and muscle twitching, Convulsions, in extreme cases, loss Respiratory effects. of consciousness., Ingestion Nausea, Abdominal May cause acute acetyl pain, cholinesterase depression. Abnormal tearing, Symptoms and signs Abnormal salivation, include headache, dizziness, constriction of pupils, fatigue, muscular weakness, Blurred vision, drowsiness and muscle twitching, in extreme cases, loss of Convulsions, consciousness., Nausea, Respiratory effects. Abdominal pain, Abnormal tearing, Abnormal salivation, constriction of pupils, Blurred vision, muscle twitching, Convulsions, Respiratory effects. Target Organ Central nervous system

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Step 2: Mitigation Measures:

Table 4-2): Mitigation measures required when dealing with each material included at Beheira Agriculture Directorate site (23)

Mitigation Measures Liquid Pesticide (Sludge) Handling and Exposure Fire-fighting Accidental Release Disposal First Aid Measures storage Controls/Personal No Pesticide Name Measures Measures Considerations 1 requirements Protection 2 3 5 4 6 Swallowing: Contact Extinguishing: Personal Handling and Waste disposal: Personal Protection: the poison control centre Use dry media. Precautions: Wear storage: Store in Spill and waste Use assisted for immediate PPE to prevent skin well closed disposal procedures ventilation in enclosed intervention. Do not Firefighting: Use and eyes being upright shall be in space if needed. Use give any thing by mouth water spray from affected. Breathing containers in a conformity with proper PPE to unconscious person. upwind direction to aid is advised if cool dry well- regulations. avoid hazard contact is prolonged. ventilated area. Inhalation: Move vapours and toxic Evacuate unprotected Do not reuse Container person to fresh air and decomposition and unnecessary container. Avoid disposal: Triple 1 Dimethoate call poison control products. Use PPE personnel from area. breathing rinse container and centre for immediate for fire fighters Stop leak if this vapour or then puncture and intervention could be done safely. particles or get dispose within the in contact with local regulations. Skin exposure: Rinse Method of Clean skin or cloth skin with plenty of up: Use vermiculite, during handling. water and call poison sand, soil is a control centre for suitable. immediate intervention Contaminated soil should be collected Eyes exposure: Keep for environmentally

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez eye open and gently sound disposal. rinse with water. Call Contaminated area poison control centre for and tools should be immediate intervention washed down with hypochlorite bleach.

Skin: Immediately flush If product is In case of spillage, Use proper PPE. Dispose of waste Use proper PPE skin with running water, involved in fire, use absorb with inert Wash hand after materials in an while removing water foam and dry material and dispose disposal. approved contaminated clothing powder, carbon of in accordance with Store material in incinerator or waste and shoes. Obtain dioxide or sand. applicable well-ventilated treatment/disposal medical attention Do not breathe regulations. area. facility immediately. fume use in accordance with respiratory aid. applicable Eyes: Immediately flush regulations. Do not eyes with running water dispose of wastes for at least 30 minutes. in local sewer or Get medical attention with 2 Cypermethrin immediately. normal waste

Ingestion: If ingested, induce vomiting immediately, only as directed by medical personnel. Never give anything by mouth if victim is unconscious or convulsing. Transport to a clinic or hospital immediately.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Main symptoms of Extinguishing Personal Handling: Do To avoid disposal, Good general acute intoxication are: media: precautions: not consume all attempts should ventilation should be Nausea, vomiting, Foam, carbon Wear suitable food in the work be made to utilize sufficient for most diarrhoea and gastro- dioxide, dry protective clothing. area. Wash the product conditions. Local intestinal tract irritation. chemical, and water Environmental hands and completely, in exhaust ventilation Inhalation: Remove spray. precautions: exposed skin accordance with its may be necessary for victim to fresh air Fires: Contain run-off to with soap and intended and/or some operations. immediately. Treat Use as little water prevent entry into water before registered use. If Respirator: respiratory difficulty as possible. Dike water or drainage eating, drinking this Use an approved air- with artificial respiration area of fire to systems. Advise or smoking after is not possible, purifying respirator. preferably mouth to prevent pesticide water authority if work. handle with care, For emergency mouth. Get medical runoff. Do not spillage has entered Storage: and dispose in a conditions use an attention immediately. contaminate watercourses or Product should safe manner. approved pressure Skin contact: Remove personnel or drainage systems. be stored in Controlled self-contained 3 Pendimethalin contaminated clothing. equipment, or Large spills: compliance with incineration: breathing apparatus. Wash affected area handle broken Barricade area and local Recommended Clothing: For brief immediately with soap packages or consult manufacturer. regulations. disposal method for contact wear clean and large amount water. container without Small spills: Store in a this product is: long sleeved If irritation develops protective Clean up with sand, cool, dry, well- Incineration. impervious body consult a physician. equipment. Avoid clay, sawdust or ventilated Residues and waste covering. Eye contact: Wash breathing other absorbent separate area in must be disposed of Gloves: For brief immediately with large vapours or fumes material and place in original according to local contact wear rubber amounts of water. If from burning suitable fibreboard container. Keep regulations. gloves. irritation develops materials, Control containers for later away Do not contaminate Eye protection: consult a physician. run-off water. If disposal. from sources of ponds, waterways Safety glasses should Ingestion: Treat water Rinse spill area and ignition and or ditches with be sufficient for most symptomatically and enters drainage tools with soapy protect from chemical or used operations. supportively. If system advises water. exposure to fire container. vomiting occurs keep authorities Spill/Leak and heat. Do Package product head lower than hips to downstream. Procedures: not store below wastes:

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez prevent aspiration. Get Hazardous For large spills, 4oC. Segregate Triple rinse medical attention decomposition barricade area and from oxidizers. containers and pour immediately. products: consult manufacturer. rinse into spray Never give fluids or Combustion may tank for further use. induce vomiting if produce carbon and Container and patient is unconscious or nitrogen oxides. waste must be having convulsions. Protective disposed of in Advice to the physician clothing: Wear accordance with There is no specific chemical goggles, local antidote. rubber gloves and regulations. Do not Treat symptomatically impermeable use empty and supportively in clothing. Wear a container for any response to reactions pesticide cartridge other purpose from respirator. patient.

Inhalation Extinguishing Personal Handling: Pesticide disposal: It is essential to Remove source of agents: precautions: Highly toxic by Contaminated provide adequate contamination or move Extinguish small Avoid contact with absorption or if absorbents, used ventilation. The victim to fresh air. Keep fires with carbon skin and eyes. Do not swallowed. containers, surplus measures appropriate affected person warm dioxide, dry breathe in dust or Avoid contact product, etc., for a particular work and at rest. Supply powder, or alcohol- fumes. with eyes, should be burnt at site depend on how oxygen if necessary. resistant foam. For prolonged 1000oC in an this material is used 4 Methamidophos Treat symptomatically larger fires, use Environmental contact with incinerator, and on the extent of and supportively. Seek water spray, fog or precautions: skin, and preferably designed exposure. Ensure that medical advice standard foam. Do not allow to enter inhalation of for pesticide control systems are immediately. drains or water dust and vapour. disposal, or buried properly designed and Fire fighting: courses. When the Use with in designated maintained. Comply Skin contact: Move containers product contaminates adequate landfill. Hydrolysis with occupational Remove contaminated from fire area if public waters, inform ventilation. under alkaline safety, environmental, clothing, shoes and possible. Fight fire appropriate Wash hands conditions (e.g. fire, and other

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez leather goods. Gently from maximum authorities before eating, sodium hydroxide) applicable regulations. wipe of excess distance. Stay away immediately in drinking, is a suitable method chemical. Wash skin from storage tank accordance with local chewing gum, to dispose of small Personal protective gently and thoroughly ends. Contain fire regulations. smoking, or quantities of the equipment: with water and non- control water for using the toilet. product. After If engineering controls abrasive soap. Seek later disposal. Do Occupational spill: Remove hydrolysis, dilute and work practices are medical advice if not scatter material, Do not touch spilled clothing and dispose of via not effective in necessary. Persons who extinguish only if material. Stop leak if immediately if the sewage system. controlling exposure become sensitised may flow can be you can do so the insecticide Comply with local to this material, then require specialised stopped. Use without risk. Use gets inside. legislation applying wear suitable personal medical management flooding amounts water spray to reduce Then wash skin to waste disposal. protective equipment with anti-inflammatory of water as a fog, vapours (contain any thoroughly including approved agents. solid streams may water used). using a non- Package product respiratory protection. be ineffective. Cool Neutralise with abrasive soap wastes: Eye contact: containers with sodium hydroxide and put on clean Emptied containers Respirator: Immediately flush eyes flooding amounts and allow standing clothing. Do not retain vapour and An approved with gently flowing cold of water as far a for 4 hours. For small apply directly to product residues. respirator suitable for water or saline solution distance as spills, sweep up with areas where Observe all labelled protection from dusts for 15 to 20 minutes, possible. Use water sand or other suitable surface water is safeguards until and mists of pesticides holding the eyelid(s) spray to absorb absorbent material, present, or to container is is adequate. open. Seek medical toxic vapours. and place into intertidal areas cleaned, Limitations of attention immediately. Avoid breathing containers for later below the mean reconditioned, or respirator use toxic vapours. Keep disposal. Move high water destroyed. specified by the Ingestion: upwind. Consider containers from spill mark. Water Combustible approved agency and Have victim rinse mouth evacuation of area. For larger used to clean containers should the manufacturer must thoroughly with water. downwind area if spills, contain equipment must be disposed of in be observed. Do not induce vomiting, material is leaking. material far ahead of be disposed of pesticide due to the aromatic spill for later correctly to incinerators or Clothing: solvent. Seek medical Personal disposal. Keep avoid buried in an Employee must wear advice immediately. protective spectators away. contamination. approved landfill. appropriate protective

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez equipment: Isolate hazard area (impervious) clothing Advice to physician: Fire may produce and deny entry. Storage: TRIPLE RINSE and equipment to Atropine must be irritating or Ventilate closed The product empty containers prevent repeated or administered as early as poisonous vapours. spaces before must be kept in the following prolonged skin contact possible and could save Fire fighters and entering. under lock and manner: Invert the with the substance. lives, if given in time others that may be key. Keep out of empty container and in an adequate exposed should reach of over the spray or Gloves: dosage. Patients with wear full protective unauthorised mixing tank and Employee must wear organophosphate clothing and self- persons, allow draining for appropriate synthetic poisoning require contained breathing children and at least 30 seconds protective gloves to amounts of atropine far apparatus. animals.Store in after the flow has prevent contact with in excess of doses its original slowed down to a this substance. Eye usually employed in labelled drip. Thereafter protection: The use of medical practice. The container in rinse the container full-face protection is therapeutic objective is shaded, well- three times with a recommended. to achieve ventilated area, volume of water atropinisation, as away from heat, equal to a Emergency eyewash: evidenced by dilation of sparks and other minimum of 10 % Where there is any the pupils, drying sources of of that of the possibility that an secretion, pulse rate of ignition. Not to container. Add the employee’s eyes may over 120/min and be stored next to rinsing’s to the be exposed to this flushing skin. To foodstuffs and contents of the substance; the prevent gastrointestinal water supplies. spray tank before employer should absorption in the Local destroying the provide an eye wash unconscious that have regulations container in the fountain or swallowed this product, should be prescribed manner. appropriate alternative perform stomach lavage complied with. Do not re-use the within the immediate using bicarbonate empty container for work area for solution and activated any other purpose emergency use. charcoal. but destroy it by

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez perforation and flattening and bury in an approved dumpsite. Prevent contamination of food, feedstuffs, drinking water and eating utensils. Comply with local legislation applying to waste disposal.

Description of first aid Extinguishing Personal Precautions for Waste treatment Control parameters measures media precautions, safe handling methods Components with General advice Suitable protective Avoid contact Product workplace control Consult a physician. extinguishing equipment and with skin and Offer surplus and parameters Show this safety data media emergency eyes. Avoid non-recyclable Exposure controls sheet to the doctor in Use water spray, procedures: formation of solutions to a Appropriate attendance. alcohol-resistant Wear respiratory dust and licensed disposal engineering controls If inhaled foam, dry chemical protection. Avoid aerosols. company. Dissolve Avoid contact with If breathed in, move or carbon dioxide. dust formation. Provide or mix the material skin, eyes and 5 Beta Cyfluthrin person into fresh air. If Special hazards Avoid breathing appropriate with a combustible clothing. Wash hands not breathing, give arising from the vapours, mist or gas. exhaust solvent and burn in before breaks and artificial respiration. substance or Ensure adequate ventilation at a chemical immediately after Consult a physician. mixture ventilation. Evacuate places where incinerator handling In case of skin contact: No data available personnel to safe dust is formed. equipped with an the product. Wash off with soap and Advice for fire areas. Avoid Conditions for afterburner and Personal protective plenty of water. Take fighters breathing dust. safe storage, scrubber. equipment victim immediately to Wear self- Environmental including any Contaminated Eye/face protection hospital. Consult a contained breathing precautions incompatibilitie packaging Face shield and safety physician. apparatus for fire Prevent further s glasses Use equipment

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez In case of eye contact: fighting if leakage or spillage if Store in cool Dispose of as for eye protection Flush eyes with water as necessary. safe to do so. Do not place. Keep unused product. tested and approved a precaution. Further let product enter container tightly under If swallowed: Never information drains. Discharge closed in a dry appropriate give anything by mouth No data available into the environment and well- government standards to an unconscious must be avoided. ventilated place. such as NIOSH (US) person. Rinse mouth Methods and or EN 166(EU). with water. Consult a materials for Skin protection physician. containment and Handle with gloves. Most important cleaning up Gloves must be symptoms and effects, Pick up and arrange inspected prior to use. both acute and delayed disposal without Use proper glove Indication of any creating dust. Sweep removal technique immediate medical up and shovel. Keep (without touching attention and special in suitable, closed glove's outer surface) treatment needed containers for to avoid skin contact No data available disposal. with this product. Dispose of contaminated gloves after use in accordance with applicable laws and good laboratory practices. Wash and dry hands. Prevent further leakage or spillage if safe to do so. Do not let product enter drains. Discharge into

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez the environment must be avoided.

If Swallowed Flash Point: 184°F Action to take for Precautions to Pesticide Disposal: Eye Protection: Use •Call a poison control (84.4°C)(TCC) spills/leaks: Clean be taken in Do not contaminate chemical goggles. If centre or doctor Flammable up spills handling: Keep water, food, or feed vapour exposure immediately for Limits: LFL: immediately, Isolate container closed by storage or causes eye discomfort, treatment advice. 1%UFL: 6% hazard area. Keep when not in use. disposal. Open use a NIOSH •Do not give any liquid (xylene range unnecessary and Handle and open dumping is approved full-face to a person. aromatic solvent) unprotected container in a prohibited. respirator. •Do not induce vomiting Extinguishing personnel from manner as to Pesticide wastes are Skin Protection: unless told to do so by a Media: Foam, entering. prevent spillage. toxic. Improper Wear coveralls over

poison control centre or CO2, dry chemical Small Spill: Absorb Do not disposal of excess long-sleeved shirt and doctor. Fire and spill with inert contaminate pesticide, spray long pants, chemical- •Do not give anything Explosion material such as dry water, food or mixture, or rinsate resistant footwear plus by mouth to an Hazards: Foam sand, vermiculite or feed by storage, is a violation of socks, chemical- 6 Chlopyrifos unconscious person. fire extinguishing fuller’s earth, then disposal or by Federal law. If resistant apron when If In Eyes: system is preferred place in a chemical cleaning these wastes cannot mixing or loading or •Hold eye open and because waste container. equipment. Do be disposed of by exposed to the rinse slowly and gently uncontrolled water Rinse area with not reuse empty use according to concentrate, and with water for 15-20 can spread possible dilute soda ash and container. If label instructions, chemical-resistant minutes. contamination. place rinsate into container is contact your state headgear for overhead •Remove contact lenses, Toxic, irritating chemical waste damaged or spill pesticide or exposure. if present, after the first gases may be container. occurs, use environmental Hand Protection: 5 minutes, then continue formed under fire Large Spill: Same as product control agency or Chemical-resistant rinsing eye. conditions. Rapid for small spills; may immediately or the hazardous gloves, such as barrier •Call a poison control decomposition neutralize with dilute dispose of waste laminate or butyl centre or doctor for above 320-392°F alkaline solutions of product and representative at rubber ≥14 mils. treatment advice. (160-200°C) can soda and ash and damaged the nearest EPA Respirator If On Skin Or occur. Violent place into chemical container Regional Office for Requirements: Clothing: rupture due to over- waste container. Do Precautions to guidance. Atmospheric levels

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez •Take off contaminated pressurization may not allow material to be taken in Container should be maintained clothing. occur at run off into soil, storage: Store Disposal for below the exposure •Rinse skin immediately temperatures drainage systems, or in original Refillable guidelines. When with plenty of water for generated during a bodies of water. container in Containers: respiratory protection 15-20 minutes. fire. Notify and consult secured dry Replace the dry- is required, use a •Call a poison control Fire-fighting with proper storage area. disconnect cap, if NIOSH approved centre or doctor for Equipment: Use regulatory Prevent cross- applicable, and seal respirator with any R, treatment advice. positive-pressure authorities. contamination all openings that P, or HE filter. If Inhaled: self-contained with other have been opened •Move person to fresh breathing apparatus pesticides and during use. Return Engineering air. and full protective fertilizers. Do the empty container Controls: Use only •If person is not clothing. not contaminate to a collection site. with adequate breathing, call an water, food or If the container has ventilation. Local ambulance, and then feed by storage been damaged and exhaust ventilation give artificial or disposal. cannot be returned may be necessary for respiration, preferably Storage according to the some operations. mouth-to-mouth if Temperature recommended Facilities storing or possible. (Min/Max): Do procedures. utilizing this material •Call a poison control not store above should be equipped center or doctor for 100°F for Container with an eyewash further treatment advice. extended Disposal for Non- facility and a safety periods of time. refillable shower. Storage below Containers: Triple 20°F may result rinse (or Additional Protective in the formation equivalent). Then Measures: Discard of crystals. If offer for recycling clothing and other product or reconditioning, absorbent materials crystallizes, or puncture and that have been store at 50-70°F dispose of in a drenched or heavily and agitate to re- sanitary landfill, or contaminated with this

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez dissolve by other procedures product's concentrate. crystals. approved by state Do not reuse them. and local Follow manufacturer's authorities. Or, instructions for triple rinse (or cleaning and equivalent). Then maintaining PPE. If no puncture and such instructions for dispose in a washables, use sanitary landfill, or detergent and hot by incineration or, water. Keep and wash if allowed by state PPE separately from and local other laundry. authorities, by burning. If burned, User Safety stay out of smoke. Recommendations: Users should: •Wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet. •Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. •Remove clothing immediately after handling this product.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Wash outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing.

Skin: Remove Extinguishing Personal cautions: Storage: Waste Disposal TWA: 0.1 mg/m3 (8 contaminated clothes. media safety glasses or Separated from Method: hrs) Rinse and then wash To be used: goggles, rubber acids, bases, Material which Personal protective skin with water and Powder, water gloves, shoes plus food and cannot be used at equipment soap. spray, foam, carbon socks, feedstuffs. Keep the site should be Respiratory Refer for medical dioxide. long-sleeved shirt, in a well- disposed of in an protection: approved attention. Don’t use: not and long pants and ventilated approved waste respirator Eyes: First rinse with applicable hats. Safety glasses, room. disposal facility Protective gloves: plenty of water for Particular risk: not adequate ventilation, Technical following all rubber gloves several minutes (remove applicable gloves protective applicable Federal, Eye protection: contact lenses if easily Measures of Cleaning methods measures: State and Local goggles 7 Dicofol possible), then take to a personal EX: clear the Fire and regulations. Metal: Industrial hygiene: doctor. protection: safety material in time. explosion Triple rinse (or use good industrial Inhalation: Fresh air, glasses or goggles, Transfer to a protection: the equivalent). Then hygiene. Wear face rest. Refer for medical rubber gloves, properly labelled area must be far offer for recycling shield or goggles, attention. shoes plus deposit that will be from fire and or reconditioning, elbow Ingestion: Rinse mouth. socks, long-sleeved closed flammable or puncture and length PVC gloves, Induce vomiting (only in shirt, and long and sealed until the materials dispose of in a cotton overalls conscious persons!). pants and hats. recovery of sanitary landfill, or buttoned to the neck Refer for medical Environmental elimination of the by other procedures and wrist, washable hat attention. cautions product. approved by state and half Antidite: atropine and EX: prevent the Environmental and local face respirator with toxogonin contamination of cautions authorities. Plastic: dust and vapor EX: prevent the Triple rinse (or cartridge. After use

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez the floor and of contamination of the equivalent). Then and before eating, beds of water. floor and of beds of offer for recycling drinking or water. or reconditioning, smoking, wash hands, or puncture and arms and face dispose of in a thoroughly with soap sanitary landfill, or and water. by incineration, or, if allowed by state and local authorities, by burning. If burned, stay out of smoke. Do not contaminate water supplies by disposal of wastes or containers. Spillage disposal: Do not wash away into sewer. Sweep spilled substance into covered containers; if appropriate, moisten first to prevent dusting. Carefully collect remainder, then remove to safe place (extra

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez personal protection: complete protective clothing including self- contained breathing apparatus)

Inhalation: Remove Fire fighting: If Small Spills: Wear Handling: For metal drums Use proper personal victim from exposure - safe to do so, protective equipment Avoid skin and and plastic protection equipment: avoid becoming a remove containers to prevent skin and eye contact and containers: Triple casualty. Remove from path of fire. eye contamination. inhalation of or preferably contaminated clothing Keep containers Avoid vapour, mist or pressure rinse and loosen remaining cool with water inhalation of aerosols. containers clothing. Allow patient spray. On burning vapours. Wipe up Storage: Store before disposal. to assume most may emit toxic with absorbent (clean in a cool, dry, Add rinsing to spray comfortable position fumes. Fire fighters rag or paper towels). well-ventilated tank. Do not and keep warm. Keep at to wear Collect and seal in place and out of dispose of undiluted rest until fully self-contained properly labeled direct sunlight. chemicals on-site. Alpha- 8 recovered. Seek medical breathing apparatus containers or drums Store away from If recycling, replace Cypermethrin advice if effects persist. and suitable for disposal. sources of heat cap and return clean Skin contact: If skin or protective clothing Large Spills: or ignition. Keep containers to hair contact occurs, if risk of exposure Slippery when spilt. containers recycler or remove contaminated to Avoid accidents, closed when not designated clothing and flush skin vapour or products clean up in use - check collection point. If and hair with running of combustion. immediately. Wear regularly for not recycling, water. If swelling, protective equipment leaks. break, crush or redness, blistering or to prevent skin and puncture empty irritation occurs seek eye contamination containers dispose medical and the inhalation of of properly. assistance. vapours. Work up Eye contact: If in eyes wind or increase

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez wash out immediately ventilation. Use with water. In all cases absorbent (soil, sand of eye contamination it or other inert is a sensible precaution material). Collect and to seek medical advice. seal in properly Ingestion: Immediately labelled containers or rinse mouth with water. drums for disposal If swallowed, do NOT induce vomiting. Give a glass of water to drink. Never give anything by the mouth to an unconscious patient. If vomiting occurs give further water. Seek immediate medical advice.

Powder Pesticides In Case of Inhalation: Flammable Personal Handling: Pesticide disposal: Engineering control Remove to fresh air. If properties: precautions: Highly toxic if Open dumping or measures: not breathing, give Not flammable. Avoid contact with swallowed. burning of this It is essential to artificial respiration or Toxic dust and skin and eyes. Do not Avoid contact pesticide is provide adequate give oxygen by trained irritating fumes breathe in dust or with eyes, prohibited. Waste ventilation. The 9 Carbofuran personnel. may be produced fumes. prolonged resulting from the measures appropriate Get immediate medical during fires. Environmental contact with use of this product for a particular work attention Extinguishing precautions: skin, and that cannot be site depends on how In Case of Skin agents: Do not allow inhalation of reused or this material is used Contact: Extinguish small entering drains or dust and vapour. reprocessed and Immediately wash skin fires with carbon watercourses. Use with should be disposed on the extent of with soap and plenty of dioxide, dry Spillage or adequate of in a landfill exposure. Ensure that

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez water for at least 15 chemical, water uncontrolled ventilation. approved for control systems are minutes. Remove spray or standard discharges into water Wash hands pesticide disposal. properly designed and contaminated foam. For larger courses (or public before eating, Do not contaminate maintained. Comply clothing. Get medical fires, use dry waters) to be drinking, rivers, dams or any with occupational attention if symptoms chemical, “alcohol” reported chewing gum, other water sources safety, environmental, occur. Wash clothing foam, Halon, or immediately to the smoking or with the fire and other before reuse. carbon dioxide to Police and to the using the toilet. product or used applicable regulations. In Case of Eye fight fire. Department of Remove containers. Never PERSONAL Contact: Fire fighting: Water/Environmental clothing pour untreated PROTECTIVE Hold eyelids apart and Remove spectators Affairs. immediately if waste or surplus EQUIPMENT: flush eyes with plenty of from surrounding Occupational spill: the carbofuran products into public If engineering controls water for at least 15 area. Remove Keep out unprotected gets inside. sewers or where and work practices are minutes. Have eyes container from fire persons and animals. Wash skin there is any danger not effective in examined area if possible Do not touch spilled thoroughly of run-off or controlling exposure and tested by medical without risk. material; stop leak if using a non- seepage into water to this material, then personnel. Eliminate all you can do it without abrasive soap systems. Comply wear suitable personal In Case of Ingestion: ignition sources in risk. and put on clean with local equipment including Wash out mouth with immediate area. Use water spray to clothing. Do not legislation applying approved respiratory water provided person is Fight fire from reduce vapours apply directly to to waste disposal. protection. conscious. Never give maximum distance. (contain any water areas where Package product Respirator: anything by mouth to an For massive fire, used). Neutralise surface water is wastes: An approved unconscious person. Get use unmanned hose with sodium present, or to Emptied containers respirator suitable for medical attention. Do holder or monitor hydroxide and allow intertidal areas retain vapour and protection from dusts NOT induce vomiting nozzles. Contain standing for 4 hours. below the mean product residues. and mists of pesticides unless directed to do so fire control agents Sweep up high water Observe all labelled is adequate. by for later disposal. with sand or other mark. Water safeguards. Limitations of medical personnel Use a suitable absorbent used to clean Destroy the respirator use recommended material and place equipment must emptied containers specified by the extinguishing agent into containers for be disposed of by perforation and approved agency and for the type of later disposal. Move correctly to flattening. Bury in the manufacturer must

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez surrounding fire. containers from spill avoid an approved dump be observed. Avoid inhaling area. contamination. site. Do not re-use Clothing: hazardous vapours. For spills: Contain Storage: the empty container Employee must wear Keep upwind. material far ahead of The product for any appropriate protective Personal spill for later must be kept other purpose. (impervious) clothing protective disposal. Keep under lock and Comply with any and equipment to equipment: spectators away. key. Keep out of local legislation prevent skin contact Fire may product Isolate hazard area reach of applying to with the substance. irritating or and deny entry. unauthorized disposal. Gloves: poisonous vapours Ventilate closed persons, Employee must wear (toxic oxides of spaces before children and appropriate synthetic nitrogen), mists or entering animals. Store in protective gloves to other products of its original prevent contact with combustion. Fire- labelled this substance. fighters and others container in Eye protection: that may be shaded, well- The use of full face exposed should ventilated area, protection is wear full protective away from heat, recommended. clothing and self- sparks and other Emergency eye contained breathing sources of wash: Where there is apparatus. ignition. Not to any possibility that an be stored next to employee’s eyes may foodstuffs and be exposed to this water substance; the supplies. Local employer should regulations provide an eye wash should be fountain or complied with. appropriate alternative within the immediate

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez work area for emergency use.

Description of first aid Extinguishing Personal Precautions for Waste treatment Control parameters measures media precautions, safe handling methods Components with General advice Suitable protective equipment Avoid formation Product workplace control Consult a physician. extinguishing and emergency of dust and Offer surplus and parameters Show this safety data media procedures aerosols. Avoid non-recyclable Exposure controls sheet to the doctor in Use water spray, Use personal exposure - solutions to a Appropriate attendance alcohol-resistant protective equipment. obtain special licensed disposal engineering controls If inhaled foam, dry chemical Avoid dust instructions company. Dissolve Handle in accordance If breathed in, move or carbon dioxide. formation. Avoid before use. or mix the material with good industrial person into fresh air. If Special hazards breathing vapours, Provide with a combustible hygiene and safety not breathing, give arising from the mist or gas. Ensure appropriate solvent and burn in practice. Wash hands artificial respiration. substance or adequate ventilation. exhaust a chemical before breaks and Consult a physician. mixture Evacuate personnel ventilation at incinerator at the end of workday. 10 Carbendazim In case of skin contact Carbon oxides, to safe areas. Avoid places where equipped with an Personal protective Wash off with soap and nitrogen oxides breathing dust. dust is formed. afterburner and equipment plenty of water. Consult (NOx) Environmental Conditions for scrubber Eye/face protection a physician. Advice for fire precautions safe storage, Contaminated Safety glasses with In case of eye contact fighters Prevent further including any packaging side-shields Flush eyes with water as Wear self- leakage or spillage if incompatibilitie Dispose of as conforming to EN166 a precaution. contained breathing safe to do so. Do not s unused product. Use equipment for eye If swallowed apparatus for let product enter Store in cool protection tested Never give anything by firefighting if drains. Discharge place. Keep and approved under mouth to an unconscious necessary. into the container tightly appropriate person. Rinse mouth Further information environment must be closed in a dry government standards with water. Consult a no data available avoided. and well- such as NIOSH (US) physician. Methods and ventilated place. or EN 166(EU). Most important materials for Skin protection symptoms and effects, containment and Handle with gloves.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez both acute and delayed cleaning up Gloves must be The most important Pick up and arrange inspected prior to use. known symptoms and disposal without Use proper glove effects are described in creating dust. Sweep removal technique the labelling up and shovel. Keep (without touching Indication of any in suitable, closed glove's outer surface) immediate medical containers for to avoid skin contact attention and special disposal. with this product. treatment needed Dispose of no data available contaminated gloves after use in accordance with applicable laws and good laboratory practices. Wash and dry hands. Body Protection impervious clothing, The type of protective equipment must be selected according to the concentration and amount of the dangerous substance at the specific workplace. Respiratory protection Where risk assessment shows air-purifying

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez respirators are appropriate use a full- face particle respirator type N100 (US) or type P3 (EN

Skin contact: Take off Fire and NOTE: Review FIRE Handling Waste Disposal: In Engineering all contaminated Explosion Hazard: FIGHTING (Personnel): Do accordance with controls: Use only clothing immediately. Fire or intense heat MEASURES and not breathe dust local and national with adequate Rinse skin immediately may cause violent HANDLING or spray mist. regulations. Must ventilation. Refer to with plenty of water for rupture of (PERSONNEL) Do not get in be incinerated in a the product label for 15-20 minutes. Call a packages. Dust may sections before eyes, on skin, or suitable additional poison control centre or form explosive proceeding with on clothing. incineration plant Engineering Controls. doctor for treatment mixture in air. clean-up. Use Wash hands holding a permit Personal protective advice. Suitable appropriate thoroughly with delivered by the equipment Eye contact: Hold eye extinguishing PERSONAL soap and water competent Respiratory open and rinse slowly media : Water PROTECTIVE after handling authorities. Do not protection: For and gently with water spray, Foam, Dry EQUIPMENT during and before contaminate ponds, exposures in enclosed 11 Methomyl for 15-20 minutes. chemical, Carbon clean-up. Safeguards eating, waterways or areas: A respirator Remove contact lenses, dioxide (CO2) (Personnel): drinking, ditches with with an organic if present, after the first Unsuitable Evacuate personnel, chewing gum, chemical or used vapour-removing 5 minutes, then continue extinguishing thoroughly ventilate using tobacco, container. cartridge with a rinsing eye. Call a media : High area, and use self- or using the Waste Disposal: prefilter approved for poison control centre or volume water jet, contained breathing toilet. Do not contaminate pesticides (NIOSH doctor for treatment (contamination apparatus. Use Remove water, food or feed approval number advice. risk) personal protective personal by disposal. prefix TC-23C), or a Inhalation: Move to Fire fighting equipment. Spill protective Pesticide wastes are canister approved for fresh air. Artificial Instructions : In Clean-up: Sweep up equipment acutely hazardous. pesticides (NIOSH respiration and/or the event of fire, and shovel into immediately Improper disposal approval number oxygen may be wear self-contained suitable containers after handling of excess pesticide, prefix TC-14G), or a necessary. Call a poison breathing for disposal. Soak up this product. spray mixture, or NIOSH approved

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez control centre or doctor apparatus. Wear with sawdust, sand, Wash the rinsate is a respirator with an for treatment advice. full protective oil dry or other outside of violation of Federal organic Ingestion: Call a equipment. If area absorbent material. If gloves before Law. If these vapor (OV) cartridge physician or poison is heavily exposed product enters removing. wastes cannot be or canister with any R, control centre to fire and if crevices and cannot As soon as disposed of by use P, or HE prefilter. immediately. If conditions permit, be removed, treat possible, wash according to label For exposures swallowed, drink 1 or 2 let fire burn itself with a sodium thoroughly and instructions, outdoors: A NIOSH glasses of water and try out since water may hydroxide solution change into contact your State approved dust/mist once or twice to induce increase the area and allow to stand 4 clean clothing. Pesticide or filtering respirator vomiting by touching contaminated. Cool hours. Note: Sodium Remove Environmental with any R, P, or HE the back of throat with containers/tanks hydroxide is caustic clothing/PPE Control Agency, or filter or with approval finger. Induce vomiting with water spray. and causes burns. Do immediately if the Hazardous number prefix TC- if person is conscious. not get in eyes, skin material gets Waste 21C. Never give anything by or clothing. inside. representative at Skin and body mouth to an unconscious Accidental Release Wash the protection: person. Measures: Prevent thoroughly and nearest EPA Applicators and other General advice: material from put on clean Regional Office for handlers exposed to ATROPINE IS AN entering sewers, clothing. guidance. the diluted material ANTIDOTE - SEEK waterways, or low Handling Container must wear: MEDICAL areas. Never return (Physical disposal: Container Long sleeved shirt and ATTENTION AT spills in original Aspects): Keep Refilling and long pants, Chemical- ONCE IN ALL CASES containers for re-use. away from heat Disposal: resistant gloves, Shoes OF SUSPECTED Dispose of in and sources of Refer to the plus socks and POISONINGS. Have accordance with local ignition. product label for Protective eyewear. the product container or regulations. Use only in instructions. Mixers, loaders, label with you when well-ventilated If the container is applicators and other calling a poison control areas. to be refilled, do handlers who may be centre or doctor, or Storage: Do not not rinse with any exposed to the going for treatment. For contaminate material or concentrate must medical emergencies water, other introduce any wear:

159

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez involving this product, pesticides, pesticide other than Long sleeved shirt and call toll free 1-800-441- fertilizer, food this product. long pants 3637. See Label for or feed in DO NO REUSE Chemical-resistant Additional Precautions storage. THE CONTAINER gloves and Directions for Use. Handle this FOR ANY OTHER Chemical resistant Notes to physician: package PURPOSE. footwear plus socks This product is an acetyl carefully to Protective eyewear cholinesterase inhibiting prevent Chemical resistant carbamate insecticide. breakage of apron Morphine therapy is inner bag when PPE required for early contra-indicated. stored entry to treated areas Probable mucosal at low that is permitted under damage may temperatures. the Worker Protection contraindicate the use of Allow to warm Standard and that gastric lavage. above 10ºC involves contact with Morphine, 2-PAM and (50ºF) for anything that has been oxime therapy are normal treated, such as plants, contra-indicated. handling. soil, or water, is: Administer atropine Store in original Coveralls sulphate as an antidote container. Chemical-resistant until complete Keep container gloves, Category A atropinisation (1.2- 2.0 tightly closed in (such as butyl rubber, mg i.e. every 10-30 a dry and well- natural rubber, minutes). However, for ventilated place. neoprene rubber, or exposure to methomyl in Not for use or nitrile rubber), all combination with organ storage in or greater than or equal phosphorous around the to 14 mils insecticides, 2-PAM (1- home. Shoes plus socks 2 g slow i.e.) may be Keep out of the Protective eyewear used as required to Protective measures :

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez supplement the atropine reach of Discard clothing and sulphate treatment as children. other absorbent described above. materials that have Artificial respiration been drenched or and/or oxygen may be heavily contaminated necessary. Allow no with this product. Do further exposure to any not reuse them. cholinesterase inhibitor Follow manufacturer’s until full recovery is instructions for assured. cleaning/maintaining PPE. If no such ins tractions for washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Step 3: Hazard Identification Checklist for project stages:

This step includes the identification of hazard associated with this handling and management of the OPs at the site as shown in the following table, and also the effect of its presence on the surroundings. At this stage, the hazard is identified from the MSDS of each material included in the store as indicated in table (4-1) of step1.

A- Risks Associated to the operations of handling and management of OPs on site

• Toxicity (skin contact/ eye contact / ingestion / inhalation). • Carcinogenic effect • Ecological contamination (ground water / soil) • Fire Hazards due to flammability • Accidental spillage due to improper handling • Poor ventilation • Injury due to falling objects

Table (4-3): Risk Identification Checklist at Beheira Agriculture Directorate site (23)

OH&S Hazards/Env.

Aspects

No. contamination contamination

inhalation).

flammability.

Poor ventilation Poor

leakage or spillage. or leakage

contact / ingestion / / contact effect Carcinogenic improper handling. improper

Process Area due to Hazards Fire

Ecological Ecological

Accidental spillage due to to spillage due Accidental

Toxicity (skin contact/ eye eye (skin Toxicity contact/ (ground water / soil) / due to (groundwater Activities Injurydue falling to objects

1 Entering the Store \ \ \ \

2 Handling of OPs \ \ \ \ \ \ \

3 Repacking \ \ \ \ \ \ \

Removal of repacked 4 \ \ \ \ \ \ \ material 5 Loading to trucks \ \ \ \ \

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez B- Risks associated to the effect of the site on the surroundings • Leakage and spillage of OPs due to inadequate storage with long storing period. • Contamination of groundwater or soil due to leakage of pesticides into ground. • Contamination of surface water due to presence of OPs in a nearby place. • Poisoning of residents or animals due to direct or indirect contact with OPs (inhalation of vapours, drinking of contaminated water, or eating of contaminated food). • Fire hazard due to flammability • Ambient air pollution caused by vapours and fumes emitted from fire accidents of OPs. Step 4: Risk Assessment Criteria In this step we will quantitatively evaluate the actual risk associated with each hazard. We will use a typical risk assessment matrix for estimating the severity and probability of occurrence of the unwanted event/damage. The following table shall be used for scoring the severity.

Table 4-4): Severity Scoring Guideline

Guidelines for evaluation of Health & Safety Guidelines for evaluation of Hazards (Use score against Environmental Impact (Use score against Score Severity each row if the below can each row if the below can happen related to happen related to the the evaluated activity) evaluated activity) • If the damage or injury or • Limited emissions within the impact is negligible organization’s premises not affecting the 1 Negligible • Only discomfort or external community irritation • Small spills, limited fire etc. • No property damage or loss • Disfigurement of natural environment • Short lasting damage • Deforestation 2 Minor • First Aid • Migration to surrounding • Minor loss

• Minor Indirect damage to environment • Moderate lasting damage • Limited depletion of natural resources 3 Moderate • Medical treatment • Wastage of energy • Moderate loss • Destruction of natural habitat

• Direct but intermittent emissions to the ecosystem • Serious illness • Limited public complaints 4 Critical or permanent disability • Intermittent excursions beyond regulatory • Major Loss limits

• Direct and continuous emissions to • Death ecosystem • Significant Loss • Large scale public/ community complaints 5 Catastrophic • Offence against law or • Continuous excursions beyond regulatory regulation limits with fines

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez The following table will be used for deciding about the probability that unwanted event happens. Again, all personnel should recall their experiences about occurrence of same kind of events in their careers or even the industry specific data available on many websites. That data can be used for evaluating the likelihood of an event.

Table (4-5): probability scoring guidelines

Score Probability Guideline for Evaluation 1 Rare So unlikely, it can be assumed occurrence may not be experienced. 2 Unlikely Unlikely but possible to occur in the life of an item. 3 Moderate Likely to occur sometime in the life of an item. 4 Likely Will occur several times in the life of an item. 5 Most Certain Likely to occur often in the life of an item

Step 5: Risk evaluation The risk score is evaluated by multiplying probability by severity values and then projected in the risk matrix as shown in the following table:

Table (4-6): Risk matrix

Severity Score= Probability x Severity Catastrophic Critical Moderate Minor Negligible (5) (4) (3) (2) (1) Most Likely to occur often in the life of Certain 25 20 15 10 5 an item (5) Likely Will occur several times in the life 20 16 12 8 4 Probability (4) of an item Moderate Likely to occur sometime in the 15 12 9 6 3 (3) life of an item.

Unlikely Unlikely but possible to occur in 10 8 6 4 2 (2) the life of an item. So unlikely, it can be assumed Rare occurrence may not be 5 4 3 2 1 (1) experienced. Needs immediate attention, controls must be in place prior the Score 20-25 Extreme Risk commencement of job Needs action as soon as possible, control measures should be in Score 12-18 High Risk place prior the commencement of work Needs action when appropriate or possible feasible job can be Score 6-10 Moderate Risk commenced with limited control measures

Score 1-5 Low Risk No action needed, only monitoring is needed

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

4.2 Risk Assessment Matrices of Entailed Operations at Beheira Agriculture Directorate site (23): In the following section the risk associated with the main operation steps and the effect of the site itself on the surrounding are detailed and evaluated in order to recommend the required mitigation measures. The risk severity and probability are identified and a risk template for each step as shown next. Data in the previous tables as well as the risk criteria are the input to the analysis.

A- Risks Associated to the operations of handling and management of OPs on site

4.2.1 Entering the store Risk Analysis The following template shows the risk of entering the store and the required measures suggested to mitigate the risk. The risks are: • Toxicity (skin contact/ eye contact / ingestion / inhalation). • Carcinogenic effect • Poor ventilation • Injury due to falling objects

Risk before Mitigation

Probability Type Risk Risk Hazardous Risk of Legal requirements of Risk Severity Score occurrence Toxicity (skin contact/ Egyptian Labor Law eye contact / ingestion / HS 4 5 20 & OSHA Regulations inhalation). Egyptian Labor Law Carcinogenic effect HS 4 5 20 & OSHA Regulations Egyptian Labor Law Poor ventilation HS 4 4 16 OSHA Regulations Injury due to falling Egyptian Labor Law HS 3 3 9 objects & OSHA Regulations

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Residual Risk after Mitigation Probabilit Risk Risk Hazardous Risk y of Possible activities to mitigate hazard Implementation Severity Score occurrence Train the first aid staff First Aid Measures and Exposure and identify the nearest Controls/Personal Protection are applicable for Toxicity (skin medical centre. Provide Dimethoate, Carbofuran, Carbendazim, contact/ eye contact / collective first aid 2 2 4 Cypermethrin, Methomyl, Pendimethalin, ingestion / equipment and Provide Methamidophos, Beta-Cufluthrin, inhalation). PPE (Level B for Chlorpyrifos, Dicofol, and Alpha- limited time of Cypermethrin. exposure) Train the first aid staff First Aid Measures and Exposure and identify the nearest Controls/Personal Protection are applicable for medical centre. Provide Dimethoate, Carbofuran, Carbendazim, collective first aid Carcinogenic effect 2 2 4 Cypermethrin, Methomyl, Pendimethalin, equipment and Provide Methamidophos, Beta-Cufluthrin, PPE (Level B for Chlorpyrifos, Dicofol, and Alpha- limited time of Cypermethrin. exposure) Exposure Controls/Personal Protection is Train the staff and applicable for Dimethoate, Carbofuran, Provide Carbendazim, Cypermethrin, Methomyl, Poor ventilation 2 1 2 PPE (Level B for Pendimethalin, Methamidophos, Beta- limited time of Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- exposure) Cypermethrin. Handling and storage requirements are applicable for Dimethoate, Carbofuran, Train the staff and Injury due to falling Carbendazim, Cypermethrin, Methomyl, Provide PPE (Level B 1 1 1 objects Pendimethalin, Methamidophos, Beta- for limited time of Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- exposure) Cypermethrin.

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Risk Score 10

0 Toxicity (skin contact/ eye contact Carcinogenic effect Poor ventilation Injury due to falling objects / ingestion / inhalation). Hazardous Risk Risk Magnitude Before Metigation Risk Magnitude After Metigation

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

4.2.2 Handling the POPS Risk Analysis: Following are the risk of OPs handling inside the store followed by the risk analysis template;

• Toxicity (skin contact/ eye contact / ingestion / inhalation) • Carcinogenic effect • Ecological contamination (ground water / soil) • Fire Hazards due to flammability • Accidental spillage due to improper handling • Poor ventilation • Injury due to falling objects Risk before Mitigation Type Probability Risk Risk Hazardous Risk of of Legal requirements Severity Score Risk occurrence Toxicity (skin contact/ eye contact / Egyptian Labor Law & HS 4 5 20 ingestion / OSHA Regulations inhalation). Egyptian Labor Law Carcinogenic effect HS 4 5 20 OSHA Regulations Ecological Egyptian Labor Law contamination EHS 4 4 16 OSHA Regulations & Law (ground water / soil) 4/94 and 9/2012 Egyptian Labor Law Fire hazard due to EHS 4 3 12 OSHA Regulations & Law flammability 4/94 and decree 1095/2011 Accidental spillage Egyptian Labor Law due to improper EHS 4 3 12 OSHA Regulations & Law handling 4/94 and 9/2012 Egyptian Labor Law & Poor ventilation HS 3 4 12 OSHA Regulations Injury due to falling Egyptian Labor Law & HS 3 3 9 objects OSHA Regulations

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Residual Risk after Mitigation Probability Risk Risk Hazardous Risk of Possible activities to mitigate hazard Implementation Severity Score occurrence First Aid Measures and Exposure Train the first aid staff and Controls/Personal Protection are applicable identify the nearest medical Toxicity (skin contact/ for Dimethoate, Carbofuran, Carbendazim, centre. Provide eye contact / ingestion / 2 2 4 Cypermethrin, Methomyl, Pendimethalin, collective first aid equipment inhalation). Methamidophos, Beta-Cufluthrin, and Provide Chlorpyrifos, Dicofol, and Alpha- PPE (Level B for limited time Cypermethrin. of exposure). First Aid Measures and Exposure Train the first aid staff and Controls/Personal Protection are applicable identify the nearest medical for Dimethoate, Carbofuran, Carbendazim, center. Provide Carcinogenic effect 2 2 4 Cypermethrin, Methomyl, Pendimethalin, collective first aid equipment Methamidophos, Beta-Cufluthrin, and Provide Chlorpyrifos, Dicofol, and Alpha- PPE (Level B for limited time Cypermethrin. of exposure). Accidental Release Measures are applicable for Dimethoate, Carbofuran, Carbendazim, Ecological contamination Cypermethrin, Methomyl, Pendimethalin, 2 2 4 Train workers (ground water / soil) Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin. Firefighting measures are applicable for Train workers and provide PPE Fire hazard due to Dimethoate, Carbofuran, Carbendazim, 2 1 2 (Level B for limited time of flammability Cypermethrin, Methomyl, Pendimethalin, exposure). Methamidophos, Beta-Cufluthrin,

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Chlorpyrifos, Dicofol, and Alpha- Cypermethrin. Accedental release measures are applicable for Dimethoate, Carbofuran, Carbendazim, Accidental spillage due Cypermethrin, Methomyl, Pendimethalin, 2 1 2 Train workers to improper handling Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin. Accedental release measures and Handling and storage requirements are applicable for Dimethoate, Carbofuran, Carbendazim, Train workers and provide PPE Poor ventilation 2 1 2 Cypermethrin, Methomyl, Pendimethalin, (Level B for limited time of Methamidophos, Beta-Cufluthrin, exposure). Chlorpyrifos, Dicofol, and Alpha- Cypermethrin. Handling and storage requirements are applicable for Dimethoate, Carbofuran, Train the staff and Provide PPE Injury due to falling Carbendazim, Cypermethrin, Methomyl, 1 2 2 (Level B for limited time of objects Pendimethalin, Methamidophos, Beta- exposure). Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Risk Score 10

0 Toxicity (skin contact/ Carcinogenic effect Ecological Fire hazard due to Accidental spillage due Poor ventilation Injury due to falling eye contact / ingestion / contamination (ground flammability to improper handling objects inhalation). water / soil) Hazardous Risk Risk Magnitude Before Metigation Risk Magnitude After Metigation

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 4.2.3 Repackaging of POPS Risk Analysis:

Following are the risk of OPs repacking inside the store followed by the risk analysis template;

• Toxicity (skin contact/ eye contact / ingestion / inhalation) • Carcinogenic effect • Ecological contamination (ground water / soil) • Fire Hazards due to flammability • Accidental spillage due to improper handling • Poor ventilation • Injury due to falling objects Risk before Mitigation Type Probability Risk Risk Hazardous Risk of of Legal requirements Severity Score Risk occurrence Toxicity (skin contact/ Egyptian Labor Law & eye contact / ingestion HS 4 5 20 OSHA Regulations / inhalation). Egyptian Labor Law & Carcinogenic effect HS 4 5 20 OSHA Regulations Ecological Egyptian Labor Law contamination (ground EHS 4 4 16 OSHA Regulations & Law water / soil) 4/94 and 9/2012 Egyptian Labor Law Fire hazard due to EHS 4 3 12 OSHA Regulations & Law flammability 4/94 and decree 1095/2011 Accidental spillage Egyptian Labor Law due to improper EHS 4 3 12 OSHA Regulations & Law handling 4/94 and 9/2012 Egyptian Labor Law & Poor ventilation HS 3 4 12 OSHA Regulations Injury due to falling Egyptian Labor Law & HS 3 3 9 objects OSHA Regulations

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Residual Risk after Mitigation Probability Risk Risk Hazardous Risk of Possible activities to mitigate hazard Implementation Severity Score occurrence Train the first aid staff and First Aid Measures and Exposure Controls/Personal identify the nearest medical Toxicity (skin contact/ Protection are applicable for Dimethoate, Carbofuran, centre. Provide eye contact / ingestion / 2 2 4 Carbendazim, Cypermethrin, Methomyl, collective first aid inhalation). Pendimethalin, Methamidophos, Beta-Cufluthrin, equipment and Provide Chlorpyrifos, Dicofol, and Alpha-Cypermethrin. PPE (Level B for limited time of exposure). Train the first aid staff and First Aid Measures and Exposure Controls/Personal identify the nearest medical Protection are applicable for Dimethoate, Carbofuran, centre. Provide Carcinogenic effect 2 2 4 Carbendazim, Cypermethrin, Methomyl, collective first aid Pendimethalin, Methamidophos, Beta-Cufluthrin, equipment and Provide Chlorpyrifos, Dicofol, and Alpha-Cypermethrin. PPE (Level B for limited time of exposure). Accidental Release Measures are applicable for Ecological Dimethoate, Carbofuran, Carbendazim, Cypermethrin, contamination (ground 2 2 4 Methomyl, Pendimethalin, Methamidophos, Beta- Train workers water / soil) Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin. Firefighting measures are applicable for Dimethoate, Train workers and provide Fire hazard due to Carbofuran, Carbendazim, Cypermethrin, Methomyl, 2 1 2 PPE (Level B for limited flammability Pendimethalin, Methamidophos, Beta-Cufluthrin, time of exposure). Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Accedental release measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Accidental spillage due 2 1 2 Methomyl, Pendimethalin, Methamidophos, Beta- Train workers to improper handling Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin. Accedental release measures and Handling and storage requirements are applicable for Dimethoate, Train workers and provide Poor ventilation 2 1 2 Carbofuran, Carbendazim, Cypermethrin, Methomyl, PPE (Level B for limited Pendimethalin, Methamidophos, Beta-Cufluthrin, time of exposure). Chlorpyrifos, Dicofol, and Alpha-Cypermethrin. Handling and storage requirements are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Train the staff and Provide Injury due to falling 1 1 1 Methomyl, Pendimethalin, Methamidophos, Beta- PPE (Level B for limited objects Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- time of exposure). Cypermethrin.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Risk Score 10

0 Toxicity (skin contact/ eye Carcinogenic effect Ecological contamination Fire hazard due to Accidental spillage due to Poor ventilation Injury due to falling contact / ingestion / (ground water / soil) flammability improper handling objects inhalation). Hazardous risk Risk Magnitude Before Metigation Risk Magnitude After Metigation

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 4.2.4 Removal of Repacked OPs Risk Analysis

Following are the risk of OPs removal from the store followed by the risk analysis template;

Risk before Mitigation

Type Probability Risk Risk Hazardous Risk of of Legal requirements Severity Score Risk occurrence Toxicity (skin contact/ Egyptian Labor Law eye contact / ingestion / HS 4 4 16 & OSHA Regulations inhalation). Egyptian Labor Law Carcinogenic effect HS 4 4 16 & OSHA Regulations Egyptian Labor Law Ecological contamination EHS 4 3 12 OSHA Regulations & (ground water / soil) Law 4/94 and 9/2012 Egyptian Labor Law Fire hazard due to OSHA Regulations & EHS 4 3 12 flammability Law 4/94 and decree 1095/2011 Egyptian Labor Law Accidental spillage due EHS 4 3 12 OSHA Regulations & to improper handling Law 4/94 and 9/2012 Egyptian Labor Law Poor ventilation HS 3 4 12 & OSHA Regulations Injury due to falling Egyptian Labor Law HS 3 4 12 objects & OSHA Regulations

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Residual Risk after Mitigation Probability Risk Risk Hazardous Risk of Possible activities to mitigate hazard Implementation Severity Score occurrence First Aid Measures and Exposure Train the first aid staff and Controls/Personal Protection are applicable identify the nearest medical Toxicity (skin contact/ eye for Dimethoate, Carbofuran, Carbendazim, center. Provide contact / ingestion / 2 2 4 Cypermethrin, Methomyl, Pendimethalin, collective first aid equipment inhalation). Methamidophos, Beta-Cufluthrin, and Provide Chlorpyrifos, Dicofol, and Alpha- PPE (Level B for limited time Cypermethrin. of exposure). First Aid Measures and Exposure Train the first aid staff and Controls/Personal Protection are applicable identify the nearest medical for Dimethoate, Carbofuran, Carbendazim, center. Provide Carcinogenic effect 2 2 4 Cypermethrin, Methomyl, Pendimethalin, collective first aid equipment Methamidophos, Beta-Cufluthrin, and Provide Chlorpyrifos, Dicofol, and Alpha- PPE (Level B for limited time Cypermethrin. of exposure) Accidental Release Measures are applicable for Dimethoate, Carbofuran, Carbendazim, Ecological contamination Cypermethrin, Methomyl, Pendimethalin, 2 2 4 Train workers (ground water / soil) Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin. Fire fighting measures are applicable for Train workers and provide PPE Fire hazard due to Dimethoate, Carbofuran, Carbendazim, 2 1 2 (Level B for limited time of flammability Cypermethrin, Methomyl, Pendimethalin, exposure). Methamidophos, Beta-Cufluthrin,

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Chlorpyrifos, Dicofol, and Alpha- Cypermethrin.

Accidental release measures are applicable for Dimethoate, Carbofuran, Carbendazim, Accidental spillage due to Cypermethrin, Methomyl, Pendimethalin, 2 2 4 Train workers improper handling Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin. Accidental release measures and Handling and storage requirements are applicable for Dimethoate, Carbofuran, Carbendazim, Train workers and provide PPE Poor ventilation 2 1 2 Cypermethrin, Methomyl, Pendimethalin, (Level B for limited time of Methamidophos, Beta-Cufluthrin, exposure). Chlorpyrifos, Dicofol, and Alpha- Cypermethrin. Handling and storage requirements are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Methomyl, Train the staff and Provide PPE Injury due to falling objects 1 2 2 (Level B for limited time of Pendimethalin, Methamidophos, Beta- exposure). Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin.

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Risk 8 Score

0 Toxicity (skin contact/ Carcinogenic effect Ecological contamination Fire hazard due to Accidental spillage due to Poor ventilation Injury due to falling eye contact / ingestion / (ground water / soil) flammability improper handling objects inhalation). Hazardous Risk Risk Magnitude Before Metigation Risk Magnitude After Metigation

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 4.2.5 Loading OPs to trucks Risk Analysis: • Toxicity (skin contact/ eye contact / ingestion / inhalation) • Carcinogenic effect • Fire Hazards due to flammability • Accidental spillage due to improper handling • Injury due to falling objects Risk before Mitigation

Probability Type of Risk Risk Legal Hazardous Risk of Risk Severity Score requirements occurrence Toxicity (skin contact/ eye Egyptian Labor contact / ingestion / HS 4 4 16 Law & OSHA inhalation). Regulations Egyptian Labor Carcinogenic effect HS 4 4 16 Law & OSHA Regulations Egyptian Labor Law OSHA Fire hazard due to EHS 4 3 12 Regulations & Law flammability 4/94 and decree 1095/2011 Egyptian Labor Accidental spillage due to Law OSHA EHS 4 3 12 improper handling. Regulations & Law 4/94 and 9/2012 Egyptian Labor Injury due to falling objects HS 3 4 12 Law & OSHA Regulations

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Residual Risk after Mitigation Probability Risk Risk Hazardous Risk of Possible activities to mitigate hazard Implementation Severity Score occurrence First Aid Measures and Exposure Train the first aid staff and identify Controls/Personal Protection are applicable for the nearest medical centre. Provide Toxicity (skin contact/ Dimethoate, Carbofuran, Carbendazim, collective first aid equipment and eye contact / ingestion / 2 2 4 Cypermethrin, Methomyl, Pendimethalin, Provide PPE (Level B for limited inhalation). Methamidophos, Beta-Cufluthrin, Chlorpyrifos, time of exposure). Dicofol, and Alpha-Cypermethrin. First Aid Measures and Exposure Train the first aid staff and identify Controls/Personal Protection are applicable for the nearest medical centre. Provide Dimethoate, Carbofuran, Carbendazim, Carcinogenic effect 2 2 4 collective first aid equipment and Cypermethrin, Methomyl, Pendimethalin, ProvidePPE (Level B for limited Methamidophos, Beta-Cufluthrin, Chlorpyrifos, time of exposure). Dicofol, and Alpha-Cypermethrin. Fire fighting measures are applicable for Dimethoate, Carbofuran, Carbendazim, Train workers and provide PPE Fire hazard due to 2 1 2 Cypermethrin, Methomyl, Pendimethalin, (Level B for limited time of flammability Methamidophos, Beta-Cufluthrin, Chlorpyrifos, exposure). Dicofol, and Alpha-Cypermethrin. Accidental release measures are applicable for Dimethoate, Carbofuran, Carbendazim, Accidental spillage due 2 1 2 Cypermethrin, Methomyl, Pendimethalin, Train workers to improper handling. Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin. Handling and storage requirements are applicable for Dimethoate, Carbofuran, Train the staff and Provide PPE Injury due to falling Carbendazim, Cypermethrin, Methomyl, 1 3 3 (Level B for limited time of objects Pendimethalin, Methamidophos, Beta- exposure). Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin.

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12 Risk Score 10

0 Toxicity (skin contact/ eye contact / Carcinogenic effect Fire hazard due to flammability Accidental spillage due to improper Injury due to falling objects ingestion / inhalation). handling. Hazardous Risk Risk Magnitude Before Metigation Risk Magnitude After Metigation

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez B- Risks associated to the effect of the site to the surroundings

• Leakage and spillage of OPs due to inadequate storage with long storing period. • Contamination of groundwater or soil due to leakage of pesticides into ground. • Contamination of surface water due to presence of OPs in a nearby place. • Poisoning of residents or animals due to direct or indirect contact with OPs (inhalation of vapors, drinking of contaminated water, or eating of contaminated food). • Fire hazard due to bad storage conditions. • Ambient air pollution caused by vapors and fumes emitted from fire accidents of OPs.

Risk before Mitigation

Type Probability Risk Risk Hazardous Risk of of Legal requirements Severity Score Risk occurrence Leakage OPs due to Egyptian Labor Law inadequate storage with long EHS 4 5 20 OSHA Regulations & storing period Law 4/94 and 9/2012 Contamination of Egyptian Labor Law groundwater or soil due to EHS 4 5 20 OSHA Regulations & leakage of pesticides into Law 4/94 and 9/2012 ground Contamination of surface Egyptian Labor Law water due to presence of OPs EHS 4 4 16 OSHA Regulations & in a nearby place Law 4/94 and 48/82 Poisoning of residents or animals due to direct or indirect contact with OPs Egyptian Labor Law (inhalation of vapors, EHS 4 4 16 OSHA Regulations & drinking of contaminated Law 4/94 and 9/2012 water, or eating of contaminated food) Egyptian Labor Law Fire hazard due to OSHA Regulations & EHS 4 3 12 flammability Law 4/94 and decree 1095/2011 Ambient air pollution caused Egyptian Labor Law by vapors and fumes emitted EHS 4 3 12 OSHA Regulations & from fire accidents of OPs Law 4/94

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Residual Risk after Mitigation Probability Risk Risk Hazardous Risk of Possible activities to mitigate hazard Implementation Severity Score occurrence Accidental Release Measures are applicable for Dimethoate, Carbofuran, Carbendazim, Leakage OPs due to inadequate 2 2 4 Cypermethrin, Methomyl, Pendimethalin, Train workers storage with long storing period Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin. Accidental Release Measures are applicable Contamination of groundwater or for Dimethoate, Carbofuran, Carbendazim, soil due to leakage of pesticides 2 2 4 Cypermethrin, Methomyl, Pendimethalin, Train workers into ground Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin. Accidental Release Measures are applicable for Dimethoate, Carbofuran, Carbendazim, Contamination of surface water due 2 2 4 Cypermethrin, Methomyl, Pendimethalin, Train workers to presence of OPs in a nearby place Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin. Train the first aid staff First Aid Measures and Exposure and identify the Poisoning of residents or animals Controls/Personal Protection are applicable for nearest medical centre. due to direct or indirect contact with Dimethoate, Carbofuran, Carbendazim, Provide OPs (inhalation of vapours, 2 2 4 Cypermethrin, Methomyl, Pendimethalin, collective first aid drinking of contaminated water, or Methamidophos, Beta-Cufluthrin, Chlorpyrifos, equipment and eating of contaminated food) Dicofol, and Alpha-Cypermethrin. Provide PPE (Level B for

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Fire fighting measures are applicable for Train workers and Dimethoate, Carbofuran, Carbendazim, provide PPE (Level B Fire hazard due to flammability 2 1 2 Cypermethrin, Methomyl, Pendimethalin, for limited time of Methamidophos, Beta-Cufluthrin, Chlorpyrifos, exposure). Dicofol, and Alpha-Cypermethrin. Train the first aid staff and identify the First Aid Measures and Exposure nearest medical centre. Controls/Personal Protection are applicable for Provide Ambient air pollution caused by Dimethoate, Carbofuran, Carbendazim, collective first aid vapours and fumes emitted from 2 1 2 Cypermethrin, Methomyl, Pendimethalin, equipment and fire accidents of Ops Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Provide Dicofol, and Alpha-Cypermethrin. PPE (Level B for limited time of exposure).

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20 Risk Score

0 Leakage OPs due to Contamination of Contamination of surface Poisoning of residents or Fire hazard due to Ambient air pollution inadequate storage with groundwater or soil due to water due to presence of animals due to direct or flammability caused by vapors and long storing period leakage of pesticides into OPs in a nearby place indirect contact with OPs fumes emitted from fire ground (inhalation of vapors, accidents of OPs drinking of contaminated Hazardous Risk water, or eating of contaminated food)

Risk Magnitude Abefore Metigation Risk Magnitude After Metigation

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C- Summary of Hazard Mitigation for all project stages on health & environment at Beheira Agriculture Directorate site (23):

Possible Hazard Possible activities to mitigate hazards

First Aid Measures and Exposure Controls/Personal Protection are applicable for Dimethoate, Toxicity (skin contact/ eye Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, contact / ingestion / inhalation).

Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

First Aid Measures and Exposure Controls/Personal Protection are applicable for Dimethoate, store Carcinogenic effect Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin. Exposure Controls/Personal Protection is applicable for Dimethoate, Carbofuran, Carbendazim,

Poor ventilation Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Entering the the Entering Alpha-Cypermethrin. Handling and storage requirements are applicable for Dimethoate, Carbofuran, Carbendazim, Injury due to falling objects Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin. First Aid Measures and Exposure Controls/Personal Protection are applicable for Dimethoate, Toxicity (skin contact/ eye Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, contact / ingestion / inhalation). OPs Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

First Aid Measures and Exposure Controls/Personal Protection are applicable for Dimethoate, Carcinogenic effect Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Handling of Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

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Accidental Release Measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Ecological contamination Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- (ground water / soil) Cypermethrin.

Firefighting measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Fire hazard due to flammability Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin.

Accedental release measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Accidental spillage due to Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- improper handling Cypermethrin.

Accedental release measures and Handling and storage requirements are applicable for Dimethoate, Poor ventilation Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

Handling and storage requirements are applicable for Dimethoate, Carbofuran, Carbendazim, Injury due to falling objects Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

First Aid Measures and Exposure Controls/Personal Protection are applicable for Dimethoate,

Toxicity (skin contact/ eye Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, contact / ingestion / inhalation). Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

First Aid Measures and Exposure Controls/Personal Protection are applicable for Dimethoate, Repacking Carcinogenic effect Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

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Fire fighting measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Fire hazard due to flammability Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin.

Accidental release measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Accidental spillage due to Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- improper handling Cypermethrin.

Accidental release measures and Handling and storage requirements are applicable for Dimethoate, Poor ventilation Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta- Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

material Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

repacked repacked Removal of of Removal

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Fire fighting measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Fire hazard due to flammability Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin.

Accidental release measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Accidental spillage due Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- to improper handling Cypermethrin.

Accidental release measures and Handling and storage requirements are applicable for Dimethoate, Poor ventilation Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

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Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

Fire fighting measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Fire hazard due to flammability Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha-

Cypermethrin.

Trucks Loading to Accidental release measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Accidental spillage due Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- to improper handling. Cypermethrin.

Alpha-Cypermethrin.

Accidental Release Measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Leakage OPs due to inadequate

Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- on the the storage with long storing period

Cypermethrin.

Effect of site of site Effect surrounding

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Contamination of groundwater or Accidental Release Measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, soil due to leakage of pesticides Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- into ground Cypermethrin.

Contamination of surface water Accidental Release Measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, due to presence of OPs in a Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- nearby place Cypermethrin. Poisoning of residents or animals due to direct or indirect contact First Aid Measures and Exposure Controls/Personal Protection are applicable for Dimethoate, with OPs (inhalation of vapours, Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, drinking of contaminated water, Chlorpyrifos, Dicofol, and Alpha-Cypermethrin. or eating of contaminated food) Fire fighting measures are applicable for Dimethoate, Carbofuran, Carbendazim, Cypermethrin, Fire hazard due to flammability Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, Chlorpyrifos, Dicofol, and Alpha- Cypermethrin.

Ambient air pollution caused by First Aid Measures and Exposure Controls/Personal Protection are applicable for Dimethoate, vapors and fumes emitted from Carbofuran, Carbendazim, Cypermethrin, Methomyl, Pendimethalin, Methamidophos, Beta-Cufluthrin, fire accidents of OPs Chlorpyrifos, Dicofol, and Alpha-Cypermethrin.

The previous Table indicates the mitigation measures for handling and managing the Liquid/powder OPs in the store 23.

The quantitative risk assessment for all sites under study showing the details of the risk analysis and the associated risk mitigations is attached in Annex (3) in this study.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 4.3 ENVIRONMENTAL SOCIAL MANAGEMENT PLAN WITH MITIGATION MEASURES:

Phase Targets Mitigation Measures Institutional Responsibility • Inform the residents in the areas surrounding the sites under study in advance on not to be close to the sites during project implementation .

• Establish temporary guidelines agreed with local agricultural authorities and community in sites (18 & 23) at Nubareya city - Project Management unit to prohibit planting of vegetables or livestock garaging around - Agricultural directorates Protect public health for the sites during project implementation. Before people in the surrounding • Place barriers and warning signs around the sites indicating not - Egyptian Environmental Starting trespassing zones. area outside the site Affairs Agency Project (residential and service units) • Keep public and routine workers around the site under study Phases aware with all possible health hazards upon exposure to these - Local health facilities and routine workers in site pesticides and how to minimize the risk and their quick response procedures in case of accidents (fire or spillage) during project implementation. And how to file a complaint in case of exposure to bad offensive order or any other environmental problem during project. • Providing first aid measures and medical care services to deal with injuries resulting from exposure to pesticides.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Phase Targets Mitigation Measures Institutional Responsibility

• Remove any obstacles that prevent entrance and exist of the sites. - Agricultural directorates • Protection of • Prepare evacuation plan and emergency response plan for each workers in the site. - Egyptian Environmental Site preparation proposed sites. • Place spillage barriers to prevent spreading of pesticides in case of Affairs Agency before starting spillage. - Local health facilities the project • Protection of • Work zones should be covered from top with heavy duty plastic implementation surrounding sheets as a ceiling to prevent dispersing dust or vapors of pesticide - Contractor stages environment & to the surrounding air during repackaging also, floors should be public health. equipped with barriers to prevent pesticides spreading in case of - Firefighting department. spillage.

• Availability on site of absorbing materials suitable to absorb any spilled liquid pesticides. • Each site should be equipped with fire protection and firefighting equipment such as powder and CO2 Extinguishers alarm device and sand pickets. • Each site should have first aid kits required for use in case of emergency and accidents. • Presence of personal protective equipment and respiratory makes.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez s Targets Mitigation Measures Institutional Responsibility • The specialized team who will conduct the verification stage should wear PPE (level B). - Egyptian Environmental • Availability of first aid kits in each site. Affairs Agency. • Notify project's workers with the nearest hospital or medical clinic. • Inform the neighboring community and routine workers present in - Contractor. the sites with the start date of this stage and ask them to keep away from the sites locations. - Local health facilities. • Review the - Trained team from conditions of the EEAA. existing - POPs Project officer. Verification pesticide - Hazmat officer (in case phase containers to the sites are located in decide which of ports). them needs repackaging. - Port police (in case the sites are located in ports). - Maritime transport officer (in case the sites are located in ports). - Port authority (in case the sites are located in ports).

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Phase Targets Mitigation Measures Institutional Responsibility • Train project workers on type of hazard expected from exposure to pesticides, how to use properly the personal protective equipment and safe handling of pesticides during packaging. - Egyptian Environmental Affairs Agency. • Explain to workers detailed procedures which should be followed during repackaging which will include: - Contractor. - Site preparation before work start. - Dividing the site into zones depending on the degree of - Local health facilities. hazard. - Trained team from - Methods of repackaging of obsolete pesticides. EEAA. - Post labels including all required information about the • Protect health pesticides to be repackaged and prepare records for the - POPs Project officer. and safety of pesticides to be disposed. workers during - Use of personal protective devices and respiratory masks. - Hazmat officer (in case Repackaging repackaging. - Ensures workers uniform to be kept at site and the sites are located in stage decontaminated after finishing the work. ports). • Conduct medical examination before and during the - Port police (in case the implementation stage (monthly) and after completion of the sites are located in ports). project, they will include: - Chest X- Ray. - Maritime transport - Blood pressure monitoring. officer (in case the sites - Complete blood analysis. are located in ports). - Sugar analysis. - Liver and lungs function. - Port authority (in case - Skin examination. the sites are located in • Inform the project workers with the nearest hospital or medical ports). clinic in the surrounding area to go to in case of emergency. • Inform the project workers with the potential risks due to exposure to obsolete pesticides and train them how to use PPE

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez and how to apply safe handling methods during repackaging phase. • Give the workers a detailed explanation about the procedures that should be followed during repackaging phase which includes the following: - Preparation of the sites before starting the project. - Divide each site into 3 zones depending on the degree of hazard (dirty zone, intermediate zone & clean zone). - How to apply safe handling methods during repackaging stage. - Place labels showing information about repackaged pesticides and prepare registers for the pesticides stockpiles that will be disposed. - How to use PPE and respiratory masks. - Keep the workers clothes clean and not contaminated with pesticides. • Conduct regular medical checks for workers before, during project implementation stage (on monthly basis) and after completion of the project, they will include: ▪ Chest X- Ray. ▪ Blood pressure monitoring. ▪ Complete blood analysis. ▪ Sugar analysis. ▪ Liver and lungs function. ▪ Skin examination. • Inform the project workers with the nearest hospital or medical clinic in the surrounding area to go to in case of emergency.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez - Egyptian Environmental Affairs Agency. • Prevent • All repackaging works to be implemented at the designated and - Contractor. protected area (well paved or lined platforms, under temporary volatilization, - Local health facilities. wind water proof roof, with spills- leakage barriers) and only within - Trained team from EEAA. dispersion, the perimeters of sites. spillage and • Limit works under strong winds and rain fall conditions. - POPs Project officer. leaks during • Collect and pack all wastes and used contaminated supporting - Hazmat officer (in case the repackaging materials in double containment. sites are located in ports). and loading and • Decontaminate all equipment and double parts to be used in - Port police (in case the prevent other site before transportation. sites are located in ports). contamination • Avoid surface contamination of approved packing materials, - Maritime transport officer of approved equipment (lifting, pumping …etc.). (in case the sites are packaging • Keep the repacked bags stock & barrels out of contaminated located in ports). materials. areas and put them on wooden pallets. - Port authority (in case the sites are located in ports). Loading of • Prevent spillage • Training of workers on safe loading and handling procedures. - Egyptian Environmental pesticides on or spreading of • The following procedures will be conducted in case of loading Affairs Agency. trucks pesticides to the repackaged OPs in containers: - Contractor. surrounding ▪ Cover the floor of each container with PVC sheet then put a - Local health facilities. area. 15 mm thickness of absorbent layer (sand). - Trained team from EEAA. • Avoid fires and ▪ Jumbo bags and drums will be laid on two levels on wooden accidents. pallets inside the containers. - POPs Project officer. ▪ Strap the barrels & jumbo bags to be balanced inside the - Hazmat officer (in case the container. sites are located in ports). - Port police (in case the sites are located in ports).

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez - Maritime transport officer (in case the sites are located in ports). - Port authority (in case the sites are located in ports).

• Avoid accidents • Trucks should be well maintained and equipped with all safety Egyptian Environmental during devices (fire extinguishers, first aid kits, PPE, absorbent Affairs Agency. transportation. materials... etc.). - Contractor. • Avoid spills or • Place warring sign on the trucks to indicate the hazardous effect - Local health facilities. spread of and how to deal with it in case of emergency. - Trained team from EEAA. pesticides to the • The size of trucks should be suitable for the quantity of pesticides - Project Management unit. surrounding to be transported. environment. • Check safety of trucks prior loading. - Traffic police. • Protect the - Hazmat officer (in case the Transportation • Truck drivers should be aware of first aid, fire fighting and how surrounding to deal with pesticides in case of emergency. sites are located in ports). and temporary environment • In the case of transport within the ports: The truck speed should - Port police (in case the storage in ports from the not exceed 40 km/h, with choosing the shortest and most suitable sites are located in ports). negative route. - Maritime transport officer impacts of • The floor of the storage area shall be made of a chemical-resistant (in case the sites are pesticides. material. located in ports). • The storage area should be free from any flammable materials and away from any electrical cables. - Port authority (in case the • The storage area should be close to the health and safety facilities sites are located in ports). in the port. • Training the workers on the safe handling and transporting procedures.

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4.4 Roles and Responsibilities for the Implementation of the ESMP:

• Contractor responsibilities: The contractor who is going to remove the OPs from the proposed sites shall: - Submit a health and safety plan including all mitigation measures delineated in the ESIA study. - Appoint an Environmental Expert to be responsible full execution of the ESMP and the Mitigation Measures including the Health and Safety Plan and to monitor the on-site compliance with the ESMP. - Responsible to purchase all required PPE and tools required for the implementation of the ESMP

4.5 Decontamination plan for the sites under study after removing obsolete pesticides: After removing the pesticides from the sites under study, it is necessary to decontaminate these sites from any pesticide residue before proceeding to use them for any other purposes. Also, all equipment and trucks that were used during handling, repackaging and transportation of these pesticides must be decontaminated.

• Details of the decontamination plan:

A budget of six million Egyptian Pounds will be directed to the decontamination plan.

The sites decontamination plan should include the following: - Determine the future use of each of the sites under study. - Conduct a site conceptual model for each site, this model helps to identify the contamination either in (walls, floors or soil) through conducting measurements and analysis that helps in determining the areas required to be decontaminated according to the future use of each site. - Conduct decontamination alternatives to determine the best alternative that complies the applicable law limits and the required level of decontamination

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez taking into consideration the cost which should be within the estimated budget of the project. - Before starting in the decontamination plan, environmental impact assessment study including public consultation session should be prepared in order to obtain EEAA approval. - Prepare an implementation plan including the required environmental precautions, environmental management plan including mitigation measures, occupational health and safety plan and an emergency response plan.

• Notifications about contaminated sites:

In order to decontaminate the sites under study from obsolete pesticides residuals, warning signs should be placed in order to indicate that these sites are polluted and prohibited from entry.

The guardians of the sites should wear personal protection equipment (level D) which are as follows: ▪ Overalls. ▪ Gloves. ▪ Protective goggles. ▪ Safety shoes. ▪ Respiratory mask.

Figure (4-1): shows personal protection equipment (level D) that should be provided to the guardians of the sites, while figure (4-2) shows the warning sign that should be placed in each site before starting the decontamination plan.

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4.6 Grievance Redress Mechanism (GRM) Preface: A grievance redress mechanism (GRM) is a key tool through which local communities and other stakeholders exercise their voice. It is guidance on how project management unit (PMU) can provide effective remedies to affected parties who perceive that their rights have been adversely affected by business activities. A (GRM) is a set of arrangements that enable local communities, employees, out growers, and other affected stakeholders to raise grievances with the project implementing entity and seek redress when they perceive a negative impact arising from the project’s activities. It is a key way to mitigate, manage, and resolve potential or realized negative impacts, as well as fulfil obligations under international human rights law and contribute to positive relations with communities and employees. Furthermore, giving stakeholders, mainly the community, an opportunity to express it concern is a key to successful project implementation, especially when this project is implemented to it wellbeing. In fact, the GRM is also a way to mitigate, manage, and resolve potential or negative impacts, and to ensure that project management meets its obligations in terms of international human rights law. Addressing grievances early is preferable, especially in activities involving hazardous waste management in general and OPs and POPs in particular, as practices proved that apparently minor complaints can quickly become major if left unmanaged. A GRM is an important tool that enables project management unit to learn about and resolve concerns before they escalate. It should also permit a peaceful and timely resolution of problems, assuring stakeholders that their concerns have been heard and that the institutionalized mechanism will yield a fair and impartial outcome.

Plan of Action to GRM

• The PMU should identify and address a board range of obligations derived from international laws, national regulations and contractual commitments and how they might give rise to grievances and that this should be considered in the design of GRM. • GRM should establish clearly structured process from complaint to resolution. The process has to be clear, sequential to follow that stipulates steps to take and allocate responsibilities at each stage. The process should indicate which person in the PMU is responsible for following up and resolving the grievance—and those functions should be a part of employees’ performance indicators. This process should be communicated to aggrieved parties to manage expectations about the process. It should include deadlines for actions of both the PMU and the aggrieved party. Accordingly, the plan of action shall include the following steps:

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez GRM Guidance Panel:

A mechanism will be set up to receive any grievance resulting from the status of the site. A guide panel will be placed at the site entrance and in a prominent place with the following information: • Project contact details include: - Name and contact details of the POPs Project Management Unit - Telephone number to be contacted, fax and e-mail - Identify the focal point within the PMU and direct it to how complaints are handled • GRM shall be posted on the project's websites and the EEAA Division • A regular meeting is to be held between the PMU and the EEAA representative to handle complaints ❖ Guidance Panel

Sustainable Persistent Organic Pollutants (POPs) Management Project (SPMP)

In Case of any Complaint, Contact:

Sustainable Management of Persistent Organic Pollutant Project Attention of: Eng. Ahmed Abdel Hamid, SPMP Manager Address: Bldg. No. 26, Street No. 100 Maadi, Floor No. 4, Apartment No.3 , Cairo Telephone number: +2012 266 422 65 GrievanceFax: +20Process 2 23594239: The process email: [email protected] are: www.popsegypt.com Step I: Grievance reception/acceptance Directly to management, company employee, or suggestion box.

Step II: Acknowledgment, assessment, and record The applicant receives confirmation that his grievance has been received. The grievance is entered in the database using a grievance registry form, and relevant management is notified.

Step III: Investigation Appropriate investigation is decided at the assessment stage. If deemed necessary, the investigation can include a risk assessment. The investigation may include follow-up meetings between stakeholders and the PMU, where an impartial party is present. Minutes are recorded and added to the grievance database.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Step IV: Resolution Depending on the findings and their severity, a resolution is often decided immediately. In cases where the resolution does not follow predetermined criteria, the case must be presented to management for review.

Step V: Complaint satisfaction Yes: The process concludes with a written agreement signed by the plaintiff(s) and management. No: The issue is shared with senior management. If unresolved, it is taken to the company’s Environment, Social, and Governance Committee. If unresolved, it is taken up to an impartial mediator. If it remains unresolved, legal action may be taken.

Step VI: Documentation Management Throughout the procedure, it is of the highest importance that documentation be kept in the database.

4.7 Signs and Guidance Panels1 In order to comply with Safety, Health and Welfare at Work Regulations, Signs and Guidance (US EPA, A Guide to the Disposal and Decontamination of PCB- contaminated Transformers and other PCB applications, National Waste Prevention Program), Panels shown next should be used to signpost associated Hazard with each operation. The reason for this requirement is that signs are intended to be understood independently of the literacy or language ability of the worker or any people existing on site viewing it. All these signs applied to all operations and should be left on site until the processes are completed. Other signs are to be used during transport.

ATTENTION

Contaminated by OPs

CONFIRMED BY SURVEY, WEAR APPROPRIATE PPE

IN CASE OF SPILL OR ACCIDENT CONTACT

Sustainable Management of Persistent Organic Pollutants Project

12 US EPA, A Guide to the Disposal and Decontamination of PCB-contaminated Transformers and other PCB applications, National Waste Prevention Program

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Sign for on Progress Process

WARNING

Handling of OPs on Progress WEAR APPROPRIATE PPE IN CASE OF SPILL OR ACCIDENT CONTACT

Sustainable Management of Persistent Organic Pollutants Project

Attention: Engineer Ahmed Abel Hamid

Telephone: +2012 266 422 65

Signs at work places

Toxic if swallowed: Do not eat, drink or smoke when handling these products.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 5. ONSITE:

5.1 Onsite and Storage Conditions:

• Site (18) at Nubareya City: − This site is a compound surrounded by a brick fence and includes units of 30 m2 each. The current use of the site is mostly for storage of equipment. − Pesticides are stored in only six units. Store floors are tiled, poor ventilated, and there are leakages and spills of OPs. − The site is filled with a large quantity of obsolete pesticides where extremely and highly hazardous OPs are mixed with moderately and slightly hazardous ones as shown in the following figure (5-1). −

Figure (5-1): Real photos from site (18) showing the storage conditions for the OPs • Site (23) at Nubareya City: − This store contains the OPs collected from three sites (23, 24 and 25). The store is one room with tiled floor, and poor ventilation.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez − The site is filled with a large quantity of obsolete pesticides where extremely and highly hazardous OPs are mixed with moderately and slightly hazardous ones as shown in the following photos.

Figure (5-2): Real photos from site (23) showing the storage conditions for the OPs • Site (48) at Alexandria port:

In this site, obsolete pesticides are stored only in the 1st & the 3rd floor of a building existing inside the port, where the highly hazardous, moderately hazardous, slightly hazardous OPs with those that unlikely present acute hazard in the normal use are mixed in a way that could not be separated as shown in the next real photos.

Figure (5-3): Real photos from site (48) showing the storage conditions for the OPs

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• Site (44) at Adabeya port: In this site, obsolete pesticides are stored inside a container (capacity:40 ft3) existing inside the port, where the highly hazardous, moderately hazardous, slightly hazardous OPs with those that unlikely present acute hazard in the normal use are mixed in a way that could not be separated as shown in the next real photo.

Figure (5-4): Real photo from site (44) showing the storage conditions for the OPs inside the container

OPs stored inside the sites under study are packed inside metallic & plastic barrels, plastic bags, sacks but due to its long storage period a large portion of these barrels and bags have been worn out which led to the leakage & spillage of pesticides.

5.2 Methodology of Work

Through the data given from the Sustainable Persistence Organic Pollutants (POPs) Management Project (SPMP) in Egypt, there are of a total of 94.118 tons of obsolete pesticides stored inside the sites under study.

The following section is a brief description of the stages that will be carried out to accomplish the project’s aim “Clearing the sites under study from banned & expired pesticides by preparing and re-packaging these OPs prior being transferred to safe disposal sites, taking into consideration adherence to the proper environmental management controls”. The stages of the proposed project are summarized as follows: 1- Inventory of types & quantities of OPs stored inside the sites under study. 2- Monitoring the environmental situation inside and outside the stores (air, soil & water).

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 3- Repackaging and Handling of obsolete pesticides. 4- Loading the repacked obsolete pesticides and transportation stage.

Below is a detailed description for each stage of the proposed project:

5.2.1 Inventory of types & quantities of OPs stored inside the sites under study:

This stage was established by a global consulting company (TAUW) where the types, quantities, physical properties and severity of each type of pesticides present in each site were specified.

Annex (5) includes detailed inventory of the types and quantities of OPs stored in the sites under study.

The following tables (5-1), (5-2), (5-3) and (5-4) illustrate the inventory of extremely and highly hazardous obsolete pesticides stored inside each site no. (18), (23), (48) and (44) respectively.

Table (5-1): Types & Quantities of Extremely and Highly hazardous obsolete pesticides stored in site (18)

Site Chemical Name Hazard Classification Qty (Kg) Oxyfluorfen Highly Hazardous 7 Methomyl Highly Hazardous 20 Carbofuran; Furadan (insecticide) Highly Hazardous 10 18-1 Pendimethalin Highly Hazardous 12 Oxamyl Highly Hazardous 10 Beta-Cyfluthrin Highly Hazardous 8 Chlorpyrifos Highly Hazardous 34 Fenamiphos Highly Hazardous 6 Unknown no hint in Google nor Egypt Highly Hazardous 6 list Carbendazim Highly Hazardous 67.65 18-2 Cypermthrin Highly Hazardous 76.5 Oxamyl Highly Hazardous 12 Methomyl Highly Hazardous 13.6 Thiamethoxam Highly Hazardous 0.72 Carbofuran Highly Hazardous 100 Chlorpyrifos + Beta cyfluthrin Highly Hazardous 73 Methiocarb Highly hazardous 8 18-3 Dimethoate Highly Hazardous 11 Alpha-cypermethrin Highly Hazardous 8 Thiamethoxam Highly Hazardous 3.96

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Chlorpyrifos Highly Hazardous 211.81 OXxamyl Highly Hazardous 18 Beta-Cyfluthrin Highly Hazardous 8.5 Carbendazim Highly Hazardous 10.65

Chlorpyrifos Highly Hazardous 443 METHOMYL Highly Hazardous 4 Carbendazim Highly Hazardous 54 Oxyfluorfen Extremely Hazardous 9 Chlorpyrifos + Beta cyfluthrin Highly Hazardous 23 18-4 Cypermethrin Highly Hazardous 10 Fenamiphos Highly Hazardous 12 Alpha-cypermethrin Highly Hazardous 9.5 Chlorpyrifos + Indoxacarb Highly Hazardous 8.5 Fenamiphos Highly Hazardous 20

Cyfluthrin Highly Hazardous 3.24 Oxamyl Highly Hazardous 15 Carbendazim Highly Hazardous 1 Aluminum phosphate Highly Hazardous 1 Thiamethoxam Highly Hazardous 77 Alph acypermethrin Highly Hazardous 15 Chlorpyrifos Highly Hazardous 18 Beta-cyfluthrin Highly Hazardous 65.5 18-5 Lambda cyhalothrin + acetamipride Highly Hazardous 16.5 Cypermthrin Highly Hazardous 30 Methamidophos Highly Hazardous 1 Aluminium Phosphate Highly Hazardous 36 Carbofuran Highly Hazardous 52.4 Tribenuron-methyl Highly Hazardous 39 Fenamiphos+Oxamyl Highly Hazardous 160 Methomyl Highly Hazardous 1.9 Carbendazim Highly Hazardous 4.5 Ethoprophos Extremely Hazardous 2620 Carbendazim Highly Hazardous 135 18-6 Chlorpyrifos + Imedaclopryd Highly Hazardous 130 Condazol+Oxamyl Highly Hazardous 75 Fenamiphos Highly Hazardous 7500 12326.43 Total (12.326 Ton)

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Table (5-2): Types & Quantities of Extremely and Highly hazardous obsolete pesticides stored in site (23) Site Chemical Name Hazard Classification Qty (Kg) Dimethoate Highly Hazardous 24 23 Carbofuran; Furadan (insecticide) Highly Hazardous 60 Carbendazim Highly Hazardous 108 Carbendazim Highly Hazardous 52.5 Carbofuran; Furadan (insecticide) Highly Hazardous 44.1 Cypermethrin Highly Hazardous 147 24 Methomyl Highly Hazardous 1.38 Pendimethalin Highly Hazardous 36 Methamidophos Highly Hazardous 7.5 Dimethoate Highly Hazardous 15 Beta-Cyfluthrin Highly Hazardous 43.2 Carbendazim Highly Hazardous 59.7 25 Methomyl Highly Hazardous 250 Carbofuran Highly Hazardous 170 Chlorpyrifos Highly Hazardous 5.5 1023.88 Total (1.023 Ton)

Table (5-3): Types & Quantities of Extremely and Highly hazardous obsolete pesticides stored in site (48) Site Chemical Name Hazard Classification Qty (Kg) Cypermethrin Highly Hazardous 1655 48 Methomyl Highly Hazardous 3 Carbendazim 50% Highly Hazardous 2 1660 Total (1.66 Ton) Table (5-4): Types & Quantities of Extremely and Highly hazardous

obsolete pesticides stored in site (44) Site Chemical Name Hazard Classification Qty (Kg) Cypermethrin Highly Hazardous 910 Carbendazim Highly Hazardous 1000 44 Oxamyl Highly Hazardous 460 Chlorpyrifos Highly Hazardous 276 2646 Total (2.646 Ton)

Grand total quantities of highly hazardous OPs stored in all sites under study = 94.118 tons.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 5.2.2 Monitoring the Environmental Situation Inside and Outside the Stores:

The full baseline study and the site characterization reports for each of the four sites under study were conducted and submitted to the Sustainable Persistent Organic Pollutants Management Project.

5.2.3 Repackaging and Handling of Obsolete Pesticides:

According to the nature of activities to be conducted in this stage, it was necessary to prepare a Health and Safety plan describing the types of personal protective equipment (PPE) suitable for this activity and other safety measures to be undertaken during the works in order to reduce employee exposure to hazards. In case the engineering and administrative controls are not feasible or effective to reduce the risks to acceptable levels, suitable suits with chemical and acid protection with personal respiratory equipment, chemical-resistant gloves and eye protection are required17. This stage will include the following actions:

1. Access routes to the warehouse should be cleared and containers (Intermediate Bulk Containers (IBC) and over pack salvage drums) were placed in relevant locations guaranteeing the absence of obstacles that could potentially obstruct or slow down a rapid evacuation of the warehouses in case of an accident or emergency. 2. Each site should contain an area with showers or water taps to be used for washing in case of contact with pesticides. 3. Place spillage barriers to limit the spread of pesticides in case of leakage. 4. Provide absorbent materials to absorb any spills that may occur from liquid pesticides. 5. Spilled OPs will be handled and repackaged again by trained team to be then packed in new packages that are complying with UN & EPA requirements. 6. Repacked OPs will be placed in two levels over wooden pallets in large containers of high quality (complying with UN & EPA requirements). 7. Plastic sheets will be distributed on the entire floor of the containers to collect any leakage that may occur, and then a layer of 15 mm thickness of an absorption material (sand) should be placed to absorb any leakage that may occur from the packages of liquid pesticides. 8. Packs containing repacked OPs will be strapped to ensure that they are balanced inside the container. 9. The pesticides containers will be loaded on the truck by crane to be transported to final disposal site either local cement kilns or to the designated port for transportation abroad.

17 Characterization and management of lindane-containing waste at an abandoned Lindane production facility in Huesca Province (Spain). Primary emergency actions for organophosphate Waste conditioning and ex situ management. R. S. Gutiérrez Environmental division, Zaragoza, Spain 212

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Two preferable alternatives for OPs safe disposal are considered in the repackaging stage:

A. Disposal in local cement kilns:

▪ Solid pesticides will be packed in packages of suitable dimensions that are complying with UN and EPA requirements (to be identified by cement companies).

▪ Liquid pesticides will be packed in plastic packages with suitable capacities that are complying with UN and EPA requirements (to be identified by cement companies).

▪ The re-packaged OPs will be packed in larger cardboard boxes which will be tightly sealed and then placed on wooden pallets to be transported by trucks to the cement kilns.

▪ The size of new packages of pesticides should be suitable for the waste feeding systems in cement kilns.

▪ Labels for each pesticide should be placed on the packages in order to be identified to the party of final disposal.

B. Disposal outside Egypt:

▪ Solid pesticides with dilapidated bags – sacks... etc., should be repackaged in special packages that are complying with UN and EPA requirements.

▪ Liquid pesticides with dilapidated barrels should be repackaged in metallic or plastic, barrels that are complying with UN and EPA requirements.

▪ All the repackaged solid pesticides should be placed on wooden pallets, to be inventoried and place warning signs and labels on it.

▪ Repackaged liquid pesticides should be packed inside other containers of larger volume that will be tightly sealed to reduce the hazardous emissions which may emit from those pesticides if it is opened then they are placed on wooden pallets. Then these containers are inventoried and warning signs and labels are placed on them.

The following figure (5-5) shows a photo for packages that should be used in repacking of OPs.

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Figure (5-5): Packages used in repacking of OPs Warning signs indicating the type of waste & its severity must be placed on the packages containing OPs as shown in figure (5-6).

Figure (5-6): Placing warning signs on pesticides containers

➢ Containers preparation and packing procedures:

• The entire floor of the container should be covered by a plastic sheet plastic in order to collect any leakage that may occur as illustrated in the following figure (5-7), and then a layer of 15 mm thickness of an absorption material (sand) should be placed to absorb any leakage that may occur from the packages of liquid pesticides.

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Figure (5-7): Plastic sheet distributed inside the container of OPs

• Place each two packages on a wooden pallet on two levels above and below inside the container. • Strap the packages to be balanced inside the container as shown in figure (5-8) to ensure that no vibrations will occur during loading to trucks and also during the unloading from truck.

Figure (5-8): Obsolete pesticide packages strapped inside the container

After closing the containers, a full statement will be attached from the outside containing the following data: • Type & composition of the waste.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez • The amount of waste that will be transported. • Risks that may arise from the waste in the emergency cases. • Preventive measures that must be followed during dealing with the waste. • First aid measures that must be followed in case of spillage in order to protect the workers & the environment. • Special stickers should be affixed to indicate the risk of the cargo to be transported according to the United Nations and Europe union classifications.

5.2.4 Loading the Repacked Obsolete Pesticides and Transportation Stage18:

• The pesticides containers will be loaded on the truck by crane to be transported to final disposal site or to the designated port for transportation abroad as shown in the following figure (5-9).

Figure (5-9): Crane loading pesticides containers on the truck

• Clear warning signs should be placed on trucks to indicate the waste type, its dangerous characteristic and potential risks of transporting such expired banned pesticides. • The warning signs should be placed in a clear place on the sides and back of the truck to facilitate monitoring, inspection, and intervention in case of emergency. • These warning signs should be visible enough and not be obscured by any other signs or advertisement, but in case of presence of any other any advertisements on the vehicle; warning signs must be placed at least 76mm away from it. • Place warning signs on backgrounds that are not close to the colour of the sign it self, for easy visibility. • Warning signs should be placed away from water or dust that can be produced from vehicle wheels.

216 18 The company should be Apply all the requirements of ADR for transportation of OPs by road, January 2011.

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

• Warning signs must be made of a material that bears various factors and should be placed in a special frame on the vehicle. • Warning sings should be protected from damage to ensure its clarity and colour consistency. • Warning signs should comply the following specifications: - It must be made of plastic, metal or other weather resistant material. - The risk group number must be placed at the bottom of the sign and the number size should be at least 41 mm in height. - The caution sign scale must be at least 273 mm on each side. Also, its inner frame must be a continuous line far from the edge of the sign by about 12.7 mm. - For the text that is determining the risk, it must be at least 41 mm in height.

• It is preferable that the transportation process be carried out at night time to ensure the ease of traffic specially during using roads inside cities or those of high traffic density. • After the arrival of the pesticides shipment at the Egyptian ports (Alexandria port or Ain sokhna port), the companies responsible for the safe disposal of pesticides are the party responsible for transporting these containers from the trucks to ships, custom clearance and completion of all data and documents related to this shipment from EEAA and the ministry of industry, the ministry of investment, customs authority and any other relevant authorities.

5.3 Road Transport Transportation process will be carried out through a licensed company having EEAA approval to handle and transport this special hazardous waste (OPs), the obtained permit shall delineate the requirements of a specific ESMP in which a clear mitigation measures are stated, such as:

• Type of carriage • Required safety measures • Signs used to indicate the type of shipment • Trained driver • Specific routes • Other requirements

Tracking statement for transporting the hazardous pesticides: • The waste tracking statement must include data on the types, quantities of waste being transported, its quality, degree of severity as well as the packing and

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez packaging details and any other details that must be taken into consideration in order to ensure safe handling of this waste. • Tracking statement consists of an original form and six carbon copies distributed among the authorities concerned with the transportation process. • The original copy must include all the details of the waste transport process and the signatures of all the authorities concerned with this process and it is sent to the relevant control authorities by the disposal facility. • The trace statement with the 6 carbon copies should be signed according to the entity handed to. Each hand handling the transferred waste must sign the trace statement and keep a copy of it. This ensures the clarity of the responsibilities during the transport operations and upon arrival and delivery of the waste to its final destination. A signed copy of the trace statement will be returned to the site where the OPs are stored, confirming the delivery of the banned pesticides to their destination. • The six copies are distributed as follows:

Table (0-5): Distribution of track statement carbon copies and the entity that will be sent to Number of Copy Description Entity sent to Carbon Copies First version of the 1 statement EEAA from the bottom

Second version of the 2 statement from the Civil of Defense Authority bottom Third version of the Stored as a document in the site to prove the delivery of 3 statement waste to the carrier and the rest of the copies are from the bottom delivered to the waste transporter. Fourth version of the Kept by the waste transporter after handing the waste to 4 statement from the the final disposal party. bottom Fifth version of the Kept by the disposal facility as a document proving its 5 statement receipt of waste from the transporter. from the bottom Sixth version of the Disposal facility sends to the sites where the pesticides 6 statement were stored as a document proving the completion of from the bottom waste transporting process to the disposal facility.

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6. OCCUPATIONAL AND PUBLIC HEALTH

6.1 Exposure and Effects of Pesticides:

The FLEMISH Environment and Health studies in Flandern19, Belgium illustrates the clear dependence of human pollutant levels from pollutant pressure in designated areas. Bio monitoring samples of study participants living in areas of waste incinerators had significantly elevated blood urine levels. Also sex hormone concentrations were increased. Another study reported on a cohort of 8–9 years old boys in Chapaevsk, a small city in Central Russia, where half of the city was occupied by chemical industries producing chlorine containing agricultural chemicals including HCB and HCHs. OCP (organochloro pesticide) concentrations were found to be associated with total time living in Chapaevsk, distance from OCP source, but also with local dairy consumption, longer duration of breast feeding and ower BMI in these children. In the city of Ufa, a hot spot of dioxin pollution, higher dioxin concentrations were found in ejaculate of men diagnosed as infertile. High dioxin levels were also associated with pathospermia.

Cancer: Excess cancer risk is increasingly found to be associated with abundant use of pesticides in agricultural, commercial, home and garden applications. Positive associations are also found between childhood leukaemia and pesticide exposures. Other studies suggest that occupational agents like chlorinated solvents or organochloro compounds (PCBs) may play a role in the causation of exocrine pancreatic cancer, while DDT’s association with breast cancer has been described repeatedly. Exposures remain high: New studies report that more than half of the study population in Spain had concentrations in the top quartile of ≥1 POPs.

Neurotoxicity: In more recent systematic reviews on neurodevelopment outcomes of children exposed to pesticides (organophoshates, organochlorines), PCBs, mercury, cadmium and/or lead during early life, the majority of studies indicate a negative impact. There is increasing evidence that chemicals present in the environment can interrupt neurodevelopment processes during critical periods of development, with adverse effects on structure and function, leading to functional disturbances in children, adolescents and adults.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 19 Health Problems At Obsolete Pesticides Sites (Exposures And Toxicity Of Pesticides) M. Schlumpf & W. Lichtensteiger Green Tox, Zurich, Switzerland globa , Experience On POPs And Obsolete Pesticides Waste Management .

Exposed neonates can exhibit, i.e., hearing loss, higher proportion of abnormal reflexes, while young children show more attention deficits and other behavioural problems. Important to know: Neurodevelopmental disorders like autism, ADHD (attention deficit and hyperactivity disease), mental retardation and cerebral palsy are common, costly and are all lasting for lifetime.

Liver diseases: Brazils Santos and São Vicente Estuary suffer from contamination by toxic waste. Prevalence of liver disease, hepatitis, cirrhosis and liver, biliary tract or pancreas cancer was evaluated in a study at St. Paulo University, Brazil. Occupational exposure to chemicals, alcohol consumption, consumption of locally produced milk and fruit, and water from natural sources, appeared as risk factors for liver. In conclusion, there is evidence from more recent international studies presented at the symposium in Kiev that elevated exposures to persistent organochlorines and other pesticides can occur in proximity to dump and waste sites or landfills and affect biomarkers of exposure (concentrations of chemicals in the environment) and have detrimental effects on exposed human and animal populations. Especially at risk are early life stages with respect to reproductive and neurodevelopmental effects (fatal origin of adult diseases). Additional areas of concern are cancer in young and adult life, liver diseases and derailed energy metabolism, which is increasingly attracting attention.

6.2 Effects of the clean-up (removal of OPs) on the quality of the environment:20

Drinking water: The sites (18) and (23) in Nubareya City – Beheira Governorate are located in residential and agricultural area, site (48) in Alexandria is located in the seaport while site (44) is located in Adabeya port in Suez. The areas where the proposed sites exist are connected to the local water network. Because of this reason, the clean-up is not likely to affect the quality of the drinking water.

Crops Site (18) and (23) in Nubareya City – Beheira Governorate are only the sites that are located next to agricultural areas. The analysis of surface water indicated the contamination of agricultural drains used in irrigation. After the clean-up, the obsolete pesticides will not exist anymore in the agricultural products; thus they will not enter the food chain. In case of restriction of the purposes of use of the site, even the probably contaminated soil cannot mean any harm for the crops.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 20 Repackaging of Obsolete Pesticides in Kakheti Region, Georgia as a case study. TAUW, 2008. Livestock As the four sites under study are located in residential areas and sea ports, therefore no effect on livestock upon clean-up can be considered.

However, a reference of repackaging of obsolete pesticides indicates that while the repackaging was taking place, suddenly a herdsman appeared with a drove of cattle, and rode the cattle on the territory of the contaminated site to let the cows graze. Even the scenery of the Working Group in full PPE did not scare him away from letting the cattle graze around. The clean-up has a positive effect in the sense that it is not possible any more for the animals to get in touch with the substances directly. The grass is probably contaminated around the hotspots, therefore just as all kind of plant production activities should be prohibited also all livestock presence should not be allowed on the site.

Human health The following components should be developed in the context of impact assessment: neighbouring populations, safety and public health, human activities (agriculture, school, slaughterhouse, and silos). Because of the clean-up, the primary contamination source is not present any more, no further contamination can occur. With the clean-up, the chance of direct human exposure has decreased to a minimum level.

6.3 Emergency Response Plan:

6.3.1 Preface: In accordance with the requirements of the EEAA, an emergency response plan should be developed including a report on the probability of accidents such as hazardous material leakage and a precise description of the methods to be taken to contain such incidents if they occur to address their environmental impacts. Emergency response plan is an important tool to prevent accidents and control their results if they occur. The plan will be updated and strengthened based on an analysis of the risks from possible accidents in the project under study to mitigate the environmental impacts of the hazardous waste spill and dispersion. The basic structure of the emergency plan is the proper design of the plan which is prepared by a group of operating engineers who writes and updates the plan constantly. This plan will address the actions that must be taken in the event of a natural disaster or as a result of improper operation and handling of the pesticides by optimizing the utilization of all the available means, in addition to the services available in the roads, especially the medical services or the ambulance and the fire. Consequently, this will minimize the loss of individuals' lives, damage of property, prevent the deterioration of the environment and maximize control of the situation. Also, this plan must include a method to document accidents and disasters experienced by workers in the working areas. 221

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6.3.2 Objectives of the Emergency Plan at the proposed Sites:

The emergency response plan aims to:

• Control of emergencies in a safe manner in order to minimize losses as much as possible. • Protecting the lives of individuals. • Reduce damage in the sites under study and the surrounding environment. • Restore the normal state in the sites under study and the surrounding environment.

6.3.3 Potential emergencies during implementation of the proposed project:

A) Classification of Potential emergencies:

Potential emergencies are classified into:

▪ External emergencies: where emergency is out of control and causing loss of life, loss of properties and neighbouring facilities.

▪ Internal emergencies: where emergencies are within the site boundaries and can be controlled by mitigation measures available on site.

B) Types of Potential emergencies that may occur:

1. Exposure to dust and vapours emitted from OPs during handling & repackaging phases. 2. Leakage/ spillage of liquid or solid OPs from packages during handling, repackaging and loading phases. 3. Fires breakout on site as a result of electrical short circuit or direct fire. 4. Work injuries and accidents due to falling from elevated place, sliding or injury during the loading phase. Accordingly, an emergency response plan should be prepared to respond and mitigate any potential accidents to minimize its impacts on workers, society and the environment. The emergency plan will include evacuation procedure of sites under study from workers in case of emergency and considering all procedures to ensure safety of workers, properties, buildings and surrounding environment.

The emergency response plan to be applied should include the following: 1. Identifying means of communication with governmental agencies, organizations and individuals concerned with rescue and minimizing damages.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 2. Immediate response to minimize loss of life, damage of properties and use of external emergency assistance (if needed). 3. Follow up and implementation of mitigation procedures required to eliminate or reduce possibility of accidents occurrence. 4. Restore the normal state including short and long term activities to restore operations to normal state and help to restore the surrounding environment to its previous state. In order to achieve the objectives of the emergency plan, all workers should be well- trained on the plant implementation and how to handle any problem in case of emergency. The following issues should be ensured in the training program:

1. Raise environmental awareness among workers and train them how to respond to emergencies and how to mitigate their potential impacts. 2. Follow up safe and proper methods in handling of pesticides to minimize occurrence of accidents. 3. Prepare accidents registers and safety instructions.

6.3.4 Fire Handling Procedures:

- Human Resources:

Sufficient number of technicians responsible for fire-fighting should be provided in each site. They should be distributed on shifts to be available for 24 hours. - Fire Fighting Systems:

An appropriate fire-fighting system must be implemented in the sites under study to ensure safety of workers in the proposed project from fire risks. The system that will be implemented should comply with fire-fighting conditions and all fire-fighting instructions and procedures should be taken into consideration during handling, repackaging and transportation of obsolete pesticides as indicated in the risk assessment study for each site.

Also, adequate number of different types of fire extinguishers (Dry powder, CO2) should be provided in each site, these extinguishers should be distributed properly and they should be placed onto supports fixed on walls in a visible place. Moreover, warning and guidance signs showing escape routes, no smoking and preventing the use of direct fire inside the sites should be placed in each site.

6.4 Requirements for Emergency Plan: Emergency requirements vary depending on the type and size of the project. The following are the general emergency requirements in accordance with the Hazardous Waste Management and Handling Regulations 2002: 223

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 1- Determination of precautions and equipment for facing emergencies by providing the following:

- Fire extinguishers of different uses and capacities (CO2 extinguishers, Dry chemical powder extinguishers, etc). - Automatic extinguishing system (if needed). - Barrels and buckets of dry sand as inert absorbent. - Alarm to notify the workers in case of emergency. - Equipment and instruments used in rescuing and first aid such as (buckets, helmets, ropes, personal protection equipment, hand barrow, Emergency Response Kits). 2- Employ a qualified emergency officer in each site to be responsible for the following: - Handling emergency cases and procedures for hazardous wastes during normal working conditions or during emergency situations. - Respond to any emergency situation and following the instructions mentioned below: • In case of fire: Contact the Civil Defence immediately then try to extinguish the fire.

• In case of leakage or spillage of Obsolete Pesticides:

1. The spilled material must be contained and area of spillage should be promptly cleaned. 2. Prevent the entry of any unauthorized person to the area of spillage by putting a (NO ENTRY) sign. 3. Use the information mentioned in the MSDS of obsolete pesticides in case of spillage / leakage. 4. Protect the rainwater drainage, sanitation and surface water systems from leakage of spilled OPs into these networks. 5. Collection of spilled material inside an appropriate container & putting a warning label on the container showing the type of spilled material and it must be shipped out of the site to be disposed with obsolete pesticides stocks either in local cement kilns or outside Egypt. 6. Contact the Civil Defence, Ministry of Environment and/or any other concerned authority.

3- Prepare and submit a report about the accident, this report should include the following information: (Date/ time/ type of accident /reasons that lead to occurrence/ types and amounts of spilled materials or wastes) and identifying the damages and methods of handling.

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7. PROJECT ALTERNATIVES:

This chapter deals with the project alternatives for "Repackaging of POPs and Obsolete Pesticides in the sites under study and disposal in a safe manner" The project includes four sites where two of them located in Nubareya city, Beheira Governorate, one in Alexandria port and one in Adabeya port in Suez. The two major alternatives that are proposed during this study are "Without project" and "With project". Both alternatives will be discussed in details in the following section. The (GEF) project alternative will support on-the-ground investments for environmentally safe disposal of POPs pesticides and PCBs; building institutional capacity for sound management of POPs; and raising public awareness on POPs risks. The study considered various configurations for the project design including various disposal options; siting of facilities; methods of collection, packaging and storage; Disposal; institutional & socio-political risks.

7.1 "WITHOUT PROJECT" ALTERNATIVE:

If the proposed project is not is not implemented, this will lead to deterioration of the environmental situation due to accumulation of POPs and obsolete pesticides which are considered as highly hazardous wastes. Therefore, this may lead to transportation and disposal of these pesticides by an illegal and unsafe procedures such as: Disposal in agricultural or desert land, water drains (canals, lakes, … etc) which will contribute in turn to disappearance of wild and marine life and accumulation of the traces of this hazardous materials in soil leading to adverse effect on environment and human health. On the other hand, improper storage of the pesticides may result in fire breakout inside the storage areas as these pesticides may be leaked from the deteriorated containers on the floor of the storage areas due to exposure to high temperature which may cause fires. This will threaten the surrounding environment, public health and the nearby urban areas due to exposure to harmful and hazardous gases and other emissions resulting from fire occurrence. In case the pesticides stores are insecure, there will be a possibility that it will be stolen and sold to small farmers with low cost. These farmers will use these pesticides in their fields causing great danger to public health and environment.

If this project is not implemented, this will lead to the following:

1. Increase pollution, loss of natural resources, support illegal methods of disposal due to the absence of proper management of POPs and OPs.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 2. Accumulation of obsolete pesticides in these stores may lead to leakage to the surrounding environment and could reach surface or ground water bodies. 3. Hazardous gases and harmful odours may be released from the stores which can adversely affect public health and surrounding environment. 4. Negative impacts on public health and health of workers in agricultural sectors and facilities specially those who are exposed to these pesticides due to the absence of awareness about the dangers of this type of wastes and how to handle and deal with them in a safe manner. 5. Non-compliance with international laws, conventions and national environmental legislations (Egyptian Environmental law no. 4/1994) concerning the methods of handling and safe disposal of these hazardous wastes.

7.2 "REPACKING AND SAFE DISPOSAL OF OPs IN THE SITES OF NORTH DELTA PROVINCE (NUBAREYA & ALEXANDRIA) & ADABEYA PORT IN SUEZ" ALTERNATIVES:

The project will support on-the-ground investments for environmentally safe disposal of obsolete pesticides, including co-financing for incineration of these pesticides in local cement kilns or outside of Egypt if needed. The project will support a detailed inventory and risk assessment of the POPs pesticides storage sites.

The project will be a major contribution to:

- Reducing the risks resulting from leakage of OPs from storage sites by repackaging, transportation and final disposal in an environmentally safe manner.

- Building an institutional capacity capable of management of OPs and POPs in an environmentally sound manner.

- Raising public awareness concerning risks of OPs and POPs to the environment and human health.

The following disposal options have been considered under the project:

7.2.1 In-country disposal (using facilities available in Egypt), including thermal neutralization, chemical treatment or landfill. This is not applicable since the landfills in Egypt are not prepared to receive OPs.

• Incineration in local incinerators: Currently there are no large-scale incinerators in Egypt equipped for hazardous waste including pesticides and there are no future plans for establishing such equipment. Large incinerators are expensive in terms of initial investment (ranging from US$10,000,000 to 200,000,000 depending on the capacity, stack gas cleaning and water treatment performance) and operating costs. In addition, these incinerators require permanent 226

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez expert supervision, maintenance and repair, (expatriate) highly trained technicians, continuous supply of fresh water, reliable supply of electricity, large quantities of chemicals for gas and liquid effluent treatment and safe disposal of ashes and scrubber liquor. All these factors are essential if they are to be operated safely and comply with emission requirements. These facilities currently only operate effectively in the US and Europe and are cost-effective only if a continuous and substantial stream of chemical waste is offered for incineration.

• Chemical treatment: This method is not widely spread and used for disposal of limited amount of some pesticides and they should be treated separately on a condition that the products of the chemical reaction are non-toxic materials or cause any harms to health or environment. No suitable facilities for chemical treatment exist in Egypt. Chemical treatment of large quantities of material requires: (i) Special reactor tanks. (ii) Process control devices. (iii) Analytical facilities. (iv) Continuous expert supervision. (v) A disposal facility for residues. (vi) A range of chemicals suitable for reaction with all types of obsolete pesticides. The wide variety of pesticide types, coupled with the requirements above make the use of this technology locally unsuitable.

• Landfilling of OPs: This alternative depends on disposal of hazardous wastes by burial. This method is not suitable for disposal of pesticides or other toxic materials as it may cause pollution of the surrounding media due to the following reasons: • Obsolete pesticides and POPs are chemically very stable and will not breakdown when buried. • Probable contamination of soil or underground water in case of migration or leakage of contaminants from the bottom of the landfill cells. • No landfill cells especially designed to receive hazardous waste with leachate capture and treatment in Egypt. There is only one landfill site in Alexandria which was designed to receive inorganic solid wastes. • The cost for construction of a new big landfill is high, construction of several small landfills are also costly and limited by high population density in the country.

• Incineration in local cement kilns21: 227

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez This alternative was investigated by SPMP to evaluate local cement kilns existing in Egypt, it was found that this option can be used to dispose OPs provided that they are packed in a certain way that is appropriate to be fed into the fuel burning system of the kilns according to the following: - Solid materials in suitable packages of 20 * 20 * 20 cm or as the Cement Company requirements that comply with UN and EPA requirements. - Liquid materials packed in suitable plastic containers that comply with UN and EPA requirements. This alternative requires that the cement companies have the EEAA approval for incineration of this type of hazardous wastes in the cement kilns and they should be provided with pollution control equipment to deal with the emissions which may be released from the incineration process to ensure that the concentrations of these emissions especially dioxin & furan are below the allowable law limits (0.1 nanogram/ m3 of air emitted from the stack of the kiln). Workers in cement companies should be well-trained on the safe procedures of handling these OPs in order to reduce risks on public & occupational health and on the surrounding environment.

7.2.2 Disposal of OPs outside Egypt (Export to a disposal facility in Europe):

Obsolete pesticides can be disposed outside Egypt and incinerated at high temperature in large incinerators designed for this purpose. Transhipment of OPs for final destruction to a developed country for incineration has been the favoured option promoted by FAO guidelines. It is widely used method in the treatment of OPs from developing countries. Specially designed high temperature large incinerators dedicated for hazardous waste destruction including POPs are available in Europe. This kind of incinerators is not available in Egypt and therefore this method is proposed in this project besides incineration in cement kilns in Egypt. Incineration of OPs either in local cement kilns or in incinerators outside Egypt are the best alternatives for safe disposal due to the following reasons:

a. Repackaging of OPs in an appropriate manner in solid sealed containers that meet the UN and EPA requirements to ensure that no leaks or spills to soil or water bodies or dispersion in air will occur. This process will be conducted by a well-trained staff on safe handling and repackaging methods and considering all health and safety measures during implementation.

b. OPs and other waste containing traces of OPs such as: barrels, containers, soil, … etc are repackaged in suitable containers that comply with UN and EPA

21 Disposal of bulk quantities of obsolete pesticides in developing countries. Provisional technical guidelines. UNEP, WHO, FAO.1996 228

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c. requirements are transported by trucks to cement companies or to the ports in order to be shipped outside Egypt for final disposal.

All the above activities will be conducted in according to the requirements of law no. 4/1994 amended by law 9/2009 and its executive regulations, the international requirements and the occupational health and safety requirements. Therefore, this operation will remove large and widely dispersed stockpiles of OPs which are currently contaminating natural environment, food sources, soil, water and air and adversely affect the public health.

7.3 METHODS OF COLLECTION, REPACKAGING AND STORAGE: The activities related to identification, repackaging, temporary storage, transportation, and clean-up of POPs pesticides will be conducted in accordance with local legislation and standards law 4/1994 amended by law no. 9/2009, international requirements and best practice, as well as Occupational Health, Safety and Environment standards.

7.4 COSTS: The cost of Management and disposal of Obsolete Pesticides (repackaging, collection and elimination of pesticide residues on the proposed sites) is ranged between 2,100 and 2,500 (USD/tonne)22 "As Sustainable Persistent Organic Pollutants (POPs) Management Project (SPMP) mentioned". The estimated total cost for implementing the ESMP (safeguarding and destruction of obsolete pesticides, contaminated soils and other contaminated material) together with the cost of the environmental monitoring plan and the training requirements is around 925,000 (USD). This cost shall include also training and awareness raising activities inside the proposed sites and implementation of monitoring and mitigation measures with all necessary activities related to the EMP responsibilities mentioned in the third part of the ESIA study.

22 Sustainable Persistent Organic Pollutants (POPs) Management Project (SPMP), data from Eng. Ahmed the manager of the project. 14/2/2018. 229

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8. PUBLIC CONSULTATION SESSIONS

A series of specific consultation meetings were held among the scope of this study; these meetings included:

• Specific consultation meeting with the central department of Environmental Impact Assessment in Egyptian Environmental Affairs Agency (EEAA) was held with PMU of the project in presence of the regional branch offices of the three governorates where the sites under study are located. This meeting aimed to identify the requirements of EEAA entailing the technical scope, specific requirements during the handling of this type of hazardous waste and the social issues to be covered by the study • Several meeting were held at the four project sites in order to know the current situation in each site such as: its location, quantity & types of the stored pesticides, the storage period…etc. And to know the opinions of the nearby residents of each site and the general workers in the ports about the presence of these pesticide stores located in their surrounding area as well as their opinions towards implementing this project. • A public hearing was held at each site (4 hearings) after preparing the study draft; the details of each session are included next.

Four Public consultation sessions were held for the project “Repackaging of obsolete pesticides stored on sites under study as follows:

• The first session: A public hearing session for the sites of the North Delta region (Beheira and Alexandria) was held on 24/12/ 2019 at the Hilton Ramada - Sidi Beshr - Alexandria Governorate.

• The second session: A specific public consultation session for sites (18 and 23) located in the same compound of the agriculture directorate of Noubareya - Beheira Governorate was held on 27/2/2020 at the location of the compound. • The third session: A public consultation session for site (44) located in Adabeya port - Suez governorate was held on 19/2/2020 at Adabeya port in Suez Governorate. Further details of the public consultation sessions are described in section (8) of this study.

Details of the public hearings and meetings are explained next: 230

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8.1 First Site (48) – Alexandria Port – Alexandria Governorate:

Site Visit and Site Inspection On Wednesday 25/9/2019, a site visit was conducted to inspect site (48) at Alexandria port, and the following persons were interviewed:

- Mr. Ahmed Youssef abo el Hassan- Director of Customs Administration - Alexandria Port. - A representative from EEAA branch of Alexandria.

Public Consultation Session at North Delta Region A public consultation session for the sites of the North Delta region (Beheira and Alexandria) was held on December 24, 2019 at the Hilton Ramada - Sidi Beshr -

Alexandria Governorate.

8.1.1 Invitations to consultation session of North Delta Region sites were sent to the following:

➢ Governmental bodies concerned with environmental affairs:

▪ Environmental Affairs Agency (Central Administration for Environmental Impact Assessment). ▪ Industrial Development Authority, Ministry of Industry. ▪ Regional branches office of EEAA at Alexandria governorate. ▪ Regional branches office of EEAA at Beheira governorate.

➢ Governmental Officials:

▪ The Central Laboratory for Pesticides, Ministry of Agriculture. ▪ Secretary General of Alexandria governorate. ▪ Secretary General of Behiera governorate. ▪ Alexandria port Authority- Customs Administration. ▪ Directorate of Agriculture and Land Reclamation in Nubareya city. ▪ Directorate of Agriculture and Land Reclamation in Beheira governorate. ▪ Directorate of Agriculture and Land Reclamation in Alexandria governorate. ▪ Former Governor of Beheira governorate.

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➢ Non-Governmental Organizations (NGOs):

▪ Association of Friends of the Environment in Alexandria governorate. ▪ National Council for Women in Alexandria governorate. ▪ Women's National Association in Beheira governorate “Althanaa Association for society development and environment protect”.

The project management proposed invitations via: • Sending faxes to the invitees (attached are the sent faxes) • Email for each invitee in the project contact list • Telephone calls to all concerned people for attending the consultation session • Follow up through phone calls to confirm attendance.

The invitations covered NGOs & Community Service (faxes attached) as detailed herein:

• NGOs in Alexandria and Beheira Governorates; they were entrusted to announce the details of the meeting to the societies of concern and to they were tasked with mobilizing the community to attend the session; This was followed up with him via phone calls. • National Council for Women (Alexandria Branch) • Ex – Governor of Beheira Governorate (Mrs/ Engineer Nadia Abdo) ; public figure in the local community • Media representative serving the community(Mrs Omneya Karim)

Women contribution in the session was about 50%; noting three main facts that invited women from the surrounding of sites 18 and 23 did not attend, as they are Tribal Arabs their traditions do not allow them to contribute into such activities.

In addition, the invitation was posted on the project’s web site as shown in the next Figure (8-1).

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

Figure (8-1): Invitation to the public consultation session of North delta region sites on the project’s website

8.1.2 Proceeding of the Public Consultation Session of North Delta Region sites: The public consultation session for the repackaging of obsolete pesticides project in North Delta Province (Beheira & Alexandria) was held on Tuesday, 12/24/2019 at Hilton Hotel Ramada - Sidi Bishr - Alexandria.

The consultation session was attended by a high number (38) of representatives from the various authorities concerned with the project, such as the regional branch of the Environmental Affairs Agency in Beheira and Alexandria governorates, the central laboratory of pesticides, Ministry of Agriculture- the Directorate of Agriculture and Land Reclamation at (Nubareya city & Alexandria), Industrial Development Authority, General Secretary of Beheira and Alexandria Governorates , Alexandria Port Authority - Customs, Former Governor of Beheira governorate, Institute of Studies and Research - Alexandria University, Association of Friends of the Environment in Alexandria, National Council for Women, Women's National Association in Beheira governorate.

This is in addition to the attendance of the director of the Sustainable Persistent Organic Pollutants Management Project and the team work who prepared the environmental impact assessment study for the proposed project.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez The following table (8-1) shows names and information of the attendees at the first consultation session.

Table (8-1): Names and information of the attendees at the consultation session of North Delta Region Sites Telephone Entity Name Position E-mail no. Environmental Mrs: Mohour Assessment Ibrahim Manager- 01227597092 [email protected] Hassan EEAA Alexandria branch Director of the Mrs:Mona Environmental Ossama Department 01010388783 [email protected] Shehab (Beheira governorate) General manager Saad of EEAA regional Mohamed branch office- 01001631206 [email protected] zamel Beheira governorate Governmental Director of the bodies Environmental Mrs: Ghada Affairs concerned with 01112708693 environmental Ibrahim Department- affairs Alexandria Governorate Environmental researcher- EEAA Mrs: Walaa regional branch 01003610248 [email protected] Saied Selim office- Beheira governorate Environmental Inspector- Mrs: Rabab Environmental fathy El Affairs 01226527027 [email protected] Wardany Department- Alexandria Governorate Mrs:Mona Chemical projects Ashraf Abdel specialist- 01005191425 [email protected] Aziz Industrial

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Development Authority (IDA) Director of Waste and Hazardous Materials Mrs: Amal Management Abd Environmental 01283439536 [email protected] Elmeneem Affairs Department- Alexandria Governorate Environmental Inspector- Environmental Mrs:Magda Affairs 01223078749 [email protected] Abdel Razak Department- Alexandria Governorate Environmental inspector- Mrs: Hanan Department of Ibrahim 01201345765 [email protected] Environmental Hassan Affairs -General Court Ahmed Professor at Morsi Alexandria 01004435086 [email protected] Mahmoud University CEO- El Sayed international 01224553355 [email protected] Faisal group Professor at Nabil Saber central laboratory 01098760152 [email protected] Governmental Abdel hay Officials of pesticides Walid Deputy general Youssef manager of 0122270409 [email protected] Ibrahim Adabeya port Laboratory Peter Nabil specialist at 01147821187 [email protected] fekry Alexandria Port Motafa Undersecretary of [email protected] kamel the Ministry of 01224512110 el Agriculture – m Bukhshwan

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Alexandria governorate General Director Mohamed of Agricultural Ahmed Extension- 01272920098 Abdel Alexandria Rahman Directorate of [email protected] Agriculture Public relations - Youssef Alexandria saber 01227213857 Directorate of Ibrahim Agriculture Control manager- Hassan Nubareya 01005169934 [email protected] Mahmoud Directorate of Hassan Agriculture Undersecretary of Hussam the Ministry of eldeen 01000821290 Agriculture – Mahfouz Nubareya city Nubareya Stores Ahmed Officer- Nubareya Abdel latif 01090294835 Directorate of Rashed Agriculture Director of the Ahmed Customs Aboelhassanahmed65@gmail Youssef abo Administration – .com el Hassan 01223267934 Alexandria port Former governor Mrs (Eng) of Beheira 01222220295 [email protected] Nadia Abdou governorate

Undersecretary of Mohamed the Ministry of Ismail Agriculture – 0106508160 elzawawy Beheira governorate Control department Ghedr Directorate of Mohamed el 01012595975 Agriculture- Aasar Beheira governorate

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Head of research Yasser wahid at the Central 01001117071 [email protected] abdl fatah Pesticide Laboratory Director of the Control Mrs: Triza Department - 01002805389 saad atallah Alexandria Agricultural Directorate CEO of Al Thanaa Association for Mrs: Sanaa Society El Sayed Development and 01001587793 [email protected] Mostafa Environment Protect (Beheira governorate) Member in the Board of Directors at Al Thanaa Non- Mrs: Salwa Association for Governmental El Sayed Society 01275914452 [email protected] Organizations El Samad Development and (NGOs) Environment Protect

(Beheira governorate) Mrs: Samia CEO of the moustafa el National Council 01122281888 [email protected] sayed for Women Member of the Board of Directors- Friends Mrs: Gihan of the Refaat 01001999869 [email protected] Environment Zaalouk Association- Alexandria governorate Dr: Samia Project Teamwork of 01003449530 [email protected] Massoud consultant-

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez ESIA Study Environmental &Water Engineering Consultant (EWATEC) Project Engineer - Environmental Eng: Samah &Water Samah.gaber@ewatec- 01223915122 Gaber Engineering eg.com Consultant (EWATEC) Project Engineer - Environmental Eng:Nermin &Water nermin.ibrahim@ewatec- 01000032776 Ibrahim Engineering eg.com Consultant (EWATEC) Project Engineer - Environmental Eng: Hend &Water Hend.elwakeel@ewatec- 01200884878 El-Wakeel Engineering eg.com Consultant (EWATEC) Project Engineer - Environmental Hossam &Water hossam.elnabawy@ewatec- 01111202623 Nabawy Engineering eg.com Consultant (EWATEC) Financial manager- Environmental Samir El samir.elsawah@ewatec- &Water 01224309682 Sawah eg.com Engineering Consultant (EWATEC) Employee - Environmental Mohamed &Water 01225549413 Anwar Engineering Consultant (EWATEC)

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez ❖ Women Contribution in the public consultation session of North Delta Region sites:

Women contribution in the session was about 50%; where the following women were attended:

• Dr. Samia Massoud, the consultant who prepared the study and leading the public consultation session. • Three female engineers from the team work who prepared the study. • Dr. Nadia Abdo, Beheira former Governor. • Eng. Mona Ashraf from Industrial Development Authority (IDA). • Mrs/ Triza saad atallah- directorate of agriculture – Alexandria governorate. • Eight women representatives from governmental agencies concerned with environmental affairs (Environmental Office in Alexandria and Beheira Governorate - Regional Branch of the Environmental Affairs Agency in Alexandria and Beheira). • Four women representatives from different NGOs in (Beheira and Alexandria) governorates.

Annex (6) includes copies of the invitations sent to the attendees, registration list for the participants in this session, photos for the attendees during the session, as well as questionnaire form.

Women contribution in the session was about 50%.

In this session, the following was done:

- Opening speech by Eng. Ahmed Abdel Hamid – POPs project Manager.

- Presenting the proposed project, negative environmental effects, mitigation measures and its positive effects by Dr.Samia Massoud- the consultant who prepared the study for the proposed project.

- Receiving inquires and questions which have been answered as shown below:

Firstly: The opening Speech:

The consultation session of the proposed project initially started with an opening speech by Eng. Ahmed Abdel Hamid- project manager of the sustainable persistent organic

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez pollutants Management project, as he welcomed the attendees the speech included a brief definition of the Sustainable Persistent Organic Pollutants Management Project, and its important role in the “ safe disposal of banned and obsolete pesticides stored in the sites under study in North Delta province (Nubareya city & Alexandria).

Eng. Ahmed illustrated that the project management had assigned a foreign company “TAWU” in 2017 to take the responsibility for the inventory of obsolete pesticides stored in the sites under study which pose a serious threat to human health & surrounding environment. He also added that safe disposal of these OPs will be carried out by an international company.

Eng. Ahmed stressed also on the importance of holding the consultation session to present the stages of the proposed project to the various competent authorities including its potential effects and mitigation measures that will be followed, in order to know the extent of community’s interaction with the proposed project in order to take their opinions into consideration during implementing the project.

Eng. Ahmed Abdel Hamid then presented a movie about the “Lindane pesticide disposal project procedures which is already implemented at Adabeya port – Suez governorate and has been shipped in containers to be safely disposed outside Egypt.

Secondly: Presenting the Project and analysing its Environmental Impacts, Mitigation Measures, Social impact Analysis and Environmental Management plan:

• The presenter Dr. Samia Massoud “ the main consultant for the project” has clarified the importance of the Environmental Social Impact Assessment (ESIA) study for the proposed project, she also mentioned briefly the contents of the study and the OPs stores under study which are located in four sites as follows: ▪ Site (18) – Nubareya City- Beheira Governorate. ▪ Site (23) – Nubareya City- Beheira Governorate. ▪ Site (48) –Alexandria port- Alexandria Governorate. • Dr. Samia Massoud indicated that the total quantity of obsolete pesticides stored in these four sites is about 94.118 tons, which poses a serious threat to human and all

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez components of the surrounding environment. She also highlighted on the reasons for the accumulation of these pesticides in these sites. • Dr. Samia also presented all the regulations, laws and legislations that are related to the project, she also briefed on some laws such as the environmental law no.4 of 1994, as amended by law no.9 of 2009, and all related articles regarding the handling of hazardous waste by law no.4 of 1994 and its executive regulation for 2005 in addition to the international conventions such as Stockholm convention signed by Egypt on the 17th of May 2002, and ratified on the 2nd of May 2003 on POPs which prohibit and severely restrict the manufacturing of POPs. • Dr. Samia then described the main environmental elements in three governorates where the sites are located to, such as climatic conditions (temperature, rain, wind roses, and relative humidity) and earthquakes. She also described surrounding areas around the stores (agriculture lands, residential areas… etc) she also displayed internal and external photos for surrounding areas for each site. • Dr. Samia also presented the results of the measurements that were taken from inside and outside each site for air quality, water and soil quality which were analysed in the accredited “The Main Chemical Warfare Laboratories”. • Dr. Samia described briefly the risk assessment study and the hydrogeological study that were conducted for each site by specialized consultant. • After that, Dr. Samia described briefly the stages of implementing the proposed project, which include the following: ▪ Inventory for types & quantities of OPs stored inside the sites under study. ▪ Monitoring the environmental situation inside and outside the stores (air, soil and water). ▪ Repackaging and handling of obsolete pesticides. ▪ Loading the repacked OPs and transportation stage.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez equipment (level B) with the entire body covered which is required to ensure that workers will be protected and not directly exposed to these pesticides. • Moreover, during the session, Dr. Samia has presented the different environmental impacts during the phases of the project. • She referred to the study conducted to assess the potential risks of each site separately, and talked about the risks that the workers may face and how to avoid these risks when entering the store and dealing with packaging of pesticides then the risk posed by transporting the packed containers outside the store and finally the risk posed during loading the containers on trucks. • Then, Dr. Samia presented a summary of the mitigation measures which are need to be followed in order to reduce the negative environmental impacts that may be produced during the different stages of the project. • Dr. Samia was then discussed the proposed alternatives of the project as follows: ➢ The First alternative: “without implementing the project and keep the situation as it is” this will deteriorate the environmental situation resulting from poor & long storage duration of obsolete pesticides which in return adversely affects the safety of the environment and pose a threat to the human health especially people working in the stores in addition to the nearby residential and agricultural areas. ➢ The Second alternative: “Burning of pesticides in local incinerators in Egypt”: it cannot be implemented as there are no especially designed incinerators in Egypt for the safe disposal of these wastes in addition to its expensive cost. ➢ The Third alternative: “Burning pesticides in cement kilns in Egypt”: ▪ This alternative was studied through the management of the Sustainable Persistent Organic Pollutants Management Project where cement kilns were evaluated and found that pesticides could be incinerated in the cement kilns if they are packed in a certain way that is appropriate to be fed into the fuel burning system of the kiln. ▪ This alternative requires that the cement companies should have the EEAA approval for incineration of hazardous wastes including POPs in the cement kilns. The kiln has pollution control procedures to deal with any emissions which may be released from the incineration process to ensure that the

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez concentrations of these emissions especially dioxin & furan are below the allowable law limits.

➢ The Fourth alternative: “Chemical treatment in Egypt” it is difficult to implement this alternative to dispose obsolete pesticides for the following reasons: ▪ This method is not widely spread. ▪ It is used for disposal of limited amount of some pesticides. ▪ There is no chemical treatment units in Egypt designed for this type of disposal.

➢ The Fifth alternative: “Burying in landfill in Egypt”: ▪ There are no landfills in Egypt designed to receive hazardous organic wastes including pesticides.

▪ Probable contamination of soil or underground water in case of migration or leakage of contaminants from the bottom of the landfill cells.

▪ Requires very high investment to build this type of landfill which is complying with the international standards.

➢ The Sixth alternative: “Disposal of obsolete pesticides outside Egypt”: ▪ Obsolete pesticides can be disposed outside Egypt and incinerated at high temperature in large incinerators available in Europe designed for this purpose. Finally, Dr. Samia confirmed that incineration of OPs either in local cement kilns or in incinerators outside Egypt are the two preferable alternatives for safe disposal of OPs. After that, Dr. Samia has clarified the components of the environmental management plan & self-monitoring plan (ESMP) that will be followed during and after the completion of the project as well as the emergency plan and occupational health and safety measures.

Thirdly: Open Discussion:

During the open discussion, some questions and inquiries were discussed with Dr. Samia and Eng. Ahmed Abdel Hamid these are:

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Q1. Regarding the air samples results, most of them are Nil although there is a pungent smell of pesticides in the site when opened, why the portable GC-MS apparatus was not used to measure the concentration of pesticides instead of collecting samples in toddler bags and send them for analysis in external laboratory?

Dr. Samia Massoud replied that the study included many different types of pesticides, so it is difficult to use portable GC-MS apparatus to measure the concentration of each pesticide. Besides that, standards for all types of stored pesticides are not easily available.

Eng. Ahmed Abdel Hamid added that it was difficult to have the standards required to measure concentration of all pesticides included in the study, and these standards are found to be available only in Chemical Defence Laboratories. In addition to that, during the inventory phase (2017) pesticides were classified by the foreign company where they were analysed in a reference laboratory in Europe. No significant difference between the results obtained from the European laboratory and those of the Egyptian laboratory. Moreover, there are also consultants from the Central Pesticide Laboratory hired to assist in the analysis phase.

Q2. Is there any carcinogenic pesticide?

Eng. Ahmed Abdel Hamid replied that this matter depends on the duration and conditions of exposure to the pesticide. There are some types of pesticides that exposure does not lead to cancer; However, there are other types of pesticides the exposure under certain conditions may lead to cancer.

For example, the profile of Lindane pesticide issued by WHO in 2009 states that prolonged exposure to Lindane may leads to cancer, but in 2015 this profile is updated as direct exposure to this pesticide although for short time leads to cancer.

Dr. Samia also added that obsolete pesticides can be decomposed due to the long storage period, which may lead to generation of hazardous derivatives more hazards than the primary pesticide.

Q3. The study included only four sites to get rid of a large amount of obsolete pesticides, so is there a plan to monitor the rest of the pesticides’ sites in Egypt?

Eng. Ahmed Abdel Hamid replied that the obsolete pesticides disposal project has been started since 2016 and its goal was to dispose of about 1000 tons of these pesticides.

He also clarified that at the beginning of the project there was an international tender held to select a specialized consultancy office which was commissioned jointly with the

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Ministry of Agriculture and the Central Pesticides Laboratory to conduct inventory for the sites of OPs all over Egypt.

In addition, the Central Pesticides Laboratory has addressed all the agricultural directorates all over Egypt with this national project. Also, site visits to the pesticides’ warehouses have been already conducted. However, it was found that the available quantities OPs are less than 1000 tons. Therefore, all ports all over Egypt have been addressed and already about 70 sites have been visited and inventory for them were completed.

Eng. Ahmed also added that in case of identification of any new site, the Central Pesticide Laboratory must immediately be informed where an immediate inventory of OPs will be conducted and procedures for their safely disposal will be followed.

Q4. Has the alternative concerning “Burning of pesticides in cement kilns” been studied or already been applied before?

Eng. Ahmed Abdel Hamid replied that not all types of pesticides can be incinerated in cement kilns and with reference to guidelines of the World Bank which include a classification for disposal methods of obsolete pesticides. Based on pesticides severity, components, and active substance, a list of pesticides that can be burnt is issued by World Bank. We will be committed to burn these types of pesticides only.

Dr. Samia Massoud added that cement factories which have approval from the Egyptian Environmental Affairs Agency (EEAA) to burn such hazardous wastes have special precautions and procedures which are stipulated in the approval, such as periodic maintenance for the cement kiln, maintain the oven temperature within the range of 1500-2000oC to ensure that dioxins and furans will not be released to air to avoid harmful impacts on human health.

Q5. Will the project include training courses for prosecutors to be aware of the risks of OPs before taking execution actions as these execution actions currently are carried out in environmentally unsafe conditions?

Eng. Ahmed Abdel Hamid replied that the last stage of the project is how to achieve sustainability and it will be achieved through the training courses which will be conducted for regional branches of the Ministry of Environment and Ministry of Agriculture, taking into account the training courses that will be also conducted for prosecutors who are considered as a part of this project.

Q6. Is there a clear timetable to dispose of obsolete pesticides from the sites under study or not?

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Eng. Ahmed Abdel Hamid replied that about 241 tons of Lindane in Adabeya port had already been disposed of. After that, about 471 tons of obsolete pesticides in El Saff store at Giza Governorate were also disposed of.

Currently, an EIA study is being prepared to dispose about 100 tons of obsolete pesticides in North Delta Province (Nubareya city - Alexandria) and Adabeya port in Suez governorate.

Once the environmental approval is obtained, the phases of the proposed project will begin for repackaging the obsolete pesticides before it being safely disposed.

Q7. There are some obsolete pesticides that can be used to control locusts or termites instead of destroying them, so why this matter has not been considered especially that execution of 1 ton of obsolete pesticides requires very high cost?

Eng. Ahmed Abdel Hamid replied that there is specialized consultant already hired by the project to study the possibility of reusing some types of obsolete pesticides.

Once the analysis for each pesticide is completed, the decision for either re-using the pesticide or not will be made.

Q8. With regard to water monitoring in the ports included in the study, were water samples been taken at a distance of 1 kilo meters inside the sea?

Dr. Samia Massoud replied that water samples were taken from the nearest surface water source in each of sites under the study.

For ports, samples were taken from the shore which is the closest water source to the pesticide storage site in the port.

Eng. Ahmed Abdel Hamid added that the main goal of taking samples of soil, air and water is to identify if there is any leakage of these pesticides has been occurred whether in soil, air, the nearest surface water or ground water (if any).

For ports the closest surface water source is the shore which is located at less than 1 km, he also added that there is a hydrogeological study prepared for each of the four sites under the study by a specialized consultant in order to know the depth of ground water in each site (if any).

Q9. Was a study or analysis of by-product from pesticide decomposition being studied or conducted?

Dr. Yasser from the Central Pesticide Laboratory replied that there is no by-product in case if no pesticide is present at all.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez He also added that these pesticides are considered to be persistent organic materials which do not break down and remain stable for a long period of time.

Even if the pesticide is stored for 10 years; GC-MS apparatus can read and measure any residual pesticide even if its concentration is in micrograms.

As, the concentrations of these pesticides are very small as shown in the analysis results, therefore, they are neither decomposed nor have any by-products.

Q10. What is the guarantee that Lindane pesticide will not enter Egypt again?

Dr. Yasser from the Central Pesticide Laboratory replied that since 1994 Lindane pesticide are not allowed to be imported to Egypt. Regarding the Lindane pesticide which was existing in Adabeya port since 1964, it had already been disposed of since 2016.

Fourth: Fill up the Questionnaire forms:

Questionnaire forms were distributed to all attendees to record any observations on the proposed project or the results of the EIA study and the proposed mitigation measures in the study as well as any observations on the Consultation session.

The form format and the feedback of the attendees are attached in Annex (6).

8.2 Second Sites (18 and 23) – Noubareya – Behaira Governorate: Site visit

On Tuesday 5/9/2019, a site visit was conducted to inspect site (18) and site (23) at Nubareya city, and the following persons were interviewed:

- Eng. Hassan Heeba- Former undersecretary of Ministry of Agriculture in Nubareya city. - Eng. Hassan El Kordy – Control manager at the Directorate of Agriculture in Nubareya city. - Mr. Ahmed Abdel latif - Nubareya Stores Officer. In addition, many people of the surrounding community were present to have some information about the project. Public Consultation Session A specific site consultation was held on site 18 and 23as they exist in the same compund on 27/2/2020. The session was held on the Agricultural Directorate of Behaira – Noubareya.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez 8.2.1 Invitations to consultation session The invitations were conducted by faxes and direct contact through the MALR officials. ➢ Governmental bodies concerned with environmental affairs:

▪ Regional branches office of EEAA at Alexandria governorate. ▪ Regional branches office of EEAA at Beheira governorate.

➢ Governmental Officials:

▪ The Central Laboratory for Pesticides, Ministry of Agriculture. ▪ Directorate of Agriculture and Land Reclamation in Nubareya city. ▪ Administration Staff of the site ▪ Site caretakers and guards

➢ Non-Governmental Organizations (NGOs):

▪ Residents surrounding the site ▪ Women's from the surrounding community

8.2.2 Proceeding of the Public Consultation Session Twenty-five representatives from different background attended the session including about 20% women from the workers directly and indirectly in charge of the site. The surrounding women community did not attend as most of the surrounding community are Tribal Arabs their traditions do not allow them to contribute into such activities. Following is the list of attendees and the session photos are attached:

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Table 7: Names and information of the attendees at the consultation session of North Delta Region Site 18 and Site 23

Entity Name Position National Identification E-mail number

Ehab Fathellah Agricultural 27404041802711 ...... Ismail Admin .....

Sayed Ibrahim Agricultural 26012221803535 ...... Zaky support .....

Mohammed Agricultural 27905101501013 ...... Shaaban El engineer ..... slayed

Hussein El Agricultural 27812041501495 ...... slayed engineer .....

Fatouh Mosaad Agricultural 26211291202054 ...... Support .....

Ramy Agricultural 27412021801397 ...... Mahmoud Admin ..... Governmental Atef Agricultural 21404141800592 ...... bodies Abdelkader Admin ..... (Agricultural Sameh Reda Agricultural 28011011606676 ...... directorate ) Support .....

Azza Elsayed Environmental 27008092101081 ...... specialist .....

Ahmed Technician ...... Abdellatif .....

Elsayed Technician 28606061301609 ...... Hassan .....

Nasser Technician 26412121800572 ...... Abdelsalam .....

Gamal Driver ...... Aborahmah .....

Salah Fathy Agricultural 2704301800571 ...... Khatab engineer .....

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Mohammed Driver 28601011847713 ...... Ali El slayed .....

Abdel Hameed Agricultural 26611301701851 ...... saad engineer .....

Hossny Sayed Agricultural ...... engineer .....

Ashraf Hassan Agricultural 26211201204339 ...... engineer .....

Kamal Technician 28109171801335 ...... Ramadan .....

Non- Mohammed Farmer 26011061801511 ...... governmental Ahmed ..... bodies Hegazy (People work Ayman Site worker 27812021302356 ...... from the site ) Mohammed .....

Rania Roshdy Nubaria ...... Directorate ..... (Site worker)

Mayessa Nubaria ...... Ahmed Directorate ..... Women (Site worker) Attendees Doaa Faesel Nubaria ...... Directorate ..... (Site worker)

Lobna Ragheb Nubaria ...... Directorate ..... (Site worker)

The project representative introduced the project and explained all activities and indicated that this project is based mainly on the wellbeing of the people working in these sites in particular and on the surrounding community in general and for all Egypt on the broader scale. Many Questions were raised from the attendees:

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Why did you leave such hazardous materials for that long?

A1: The government did not have the funds to complete such huge operation including inventory, classification, and preparation for safe disposal…etc. The Government moved when the funds were available.

Are these pesticides carcinogenic?

The representative replied that this effect depends on the type and the hazard extent of each pesticide; in addition to, the exposure time and frequency. For instance the direct exposure leading to inhalation or swallowing such pesticides; However, there are other types of pesticides the exposure under certain conditions may lead to cancer.

He added that obsolete pesticides can be dangerous due to the long storage time that leads to their decay, which may produces derivatives of more hazards than the original pesticide.

What are the precautions taken during the disposal of these pesticides and how they will affect the surrounding?

The project has performed a Quantitative Risk Assessment Study for all operations and identified very stringent measure to protect workers and surrounding during all operations. The ESIA, which is subject to this discussion shall be submitted to EEAA for permitting the operation; as you all know that EEAA would not allow any risky operation.

What are the benefits of this project to us here in this location?

• First of all the location shall be relieved from the hazard of this store • After, this project the people in charge of pesticides storage will have the right knowhow to deal with the pesticides in general and OPs in particular

Would the storage of OPs would be repeated here?

The MALR does not have a plan to store these pesticides repeat this procedure since Pesticide Committee of the Ministry has promulgated a decree to oblige the importer of

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez these pesticides (either public or private) to deal with any leftover or obsolete presides on his own expenses in a way other than storage.

What about these stores? Would they left without clean up?

The Ministry shall allocate funds for remediation of highly hazardous stores; it depends on priorities, but at least after OPs removal the place shall be rehabilitated as in El Saff store.

What about the worker of such stores?

Workers shall be trained on:

• How to apply clean operations • How to use Personal Protection Equipment • How differentiate between the hazard of OPs • How to manage these OPs

Where is the final destination of these OPs? Is it going to be restored somewhere else in Egypt?

The OPs shall be safely disposed (incinerated) either in Cement Kilns inside Egypt. The project shall give these OPs for incineration in well-equipped certified cement kiln that acquired a permit from EEAA for such disposal, or to export it outside the country for safe disposal in specialized incineration facility. I such case all International and National measures for the safe transport and disposal shall apply.

Fill up the Questionnaire forms:

Questionnaire forms were distributed to all attendees to record any observations on the proposed project or the results of the ESIA study and the proposed mitigation measures in the study as well as any observations on the Consultation session.

The form format and the feedback of the attendees are attached in Annex (6).

8.3 Third site (44) - Adabeya port: Site visit

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez On Sunday 24/11/2019, a site visit was conducted to inspect site (44) at Adabeya port, and the following persons were interviewed:

- Major General. Walid Youssef- Deputy General Manager of Adabeya port. - Eng. Nermin Mohamed Fathy- Environmental Affairs Officer at Adabeya port.

Public Consultation Session A public consultation session for site (44) located in Adabeya port - Suez governorate was held on 19/2/2020 at Adabeya port in Suez Governorate.

8.3.1 Invitations to consultation session of site (44) at Adabeya port were sent to the following:

▪ Representatives from Adabeya port. ▪ Representatives from SC zone. ▪ Media and Information Administration- EEAA at Suez Governorate ▪ National Council for Women in Suez governorate. ▪ The Directorate of Trade and Supply in Suez governorate. The project management proposed invitations via: • Email for each invitee in the project contact list • Telephone calls to all concerned people for attending the consultation session • Follow up through phone calls to confirm attendance.

The total attendance is 22 representatives from the aforementioned bodies, as shown in annex no. (6).

8.3.2 Proceeding of the Public Consultation Session of site (44) at Adabeya port: The public consultation session for the repackaging of obsolete pesticides project in site (44) at Adabeya port was held on Wednesday, 19/2/2020 at Adabeya port – Suez Governorate.

The consultation session was attended by a number (22) of representatives from the various authorities concerned with the project, such as SCZone, Adabeya port, National

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Council for Women –Suez branch, National and women's Asssociations in Suez representing the civil society in Suez governorate.

This is in addition to the attendance of the team work who prepared the environmental impact assessment study for the proposed project.

The following table (8-2) shows names and information of the attendees at the second consultation session.

Table (8-2): Names and information of the attendees at the consultation session of site (44) at Adabeya port Telephone Name Position Entinty E-mail no. Manager of Entsar Media and EEAA at Suez 01222958963 [email protected] Moustafa Information Governorate Elhegazy Administration

Amal Director of the Minstry of distance 01007147647 [email protected] Mahmoud Eduaction Moustafa learning hall Suez Eman Salama Suezbalady 01203037739 Ahmed Association governorate CEO of National Fawzaya National Council for Mohamed Council for Women in 01223128830 [email protected] Abdallah Women in Suez Suez governorate governorate

Secretary of Soha Samir Adabeya Port Adabeya port aboelwafaa Director Saber ataa Electonic Adabeya port mohamed management Osamaa Electonic Adabeya port Qasim Gomaa management Hesham Director of the Hamdy Port Director's Adabeya port 01222330599 [email protected] Mohamed Office Official of the Farida zaki el translation Adabeya port 01066341490 [email protected] sayed department

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Mai Mahmoud Electonic Adabeya port Aboelolla management Financial Aziza Hassan Adabeya port 01271189266 Affairs Director Follow-up Ayman department Adabeya port 01022293040 [email protected] Abdelhamid official Senior expert in Bahaa hamed electronic SCZone 01009444089 [email protected] abdelraouf management Nermin Environmental Mohamed SCZone 01018123707 [email protected] Affairs Officer fathy Environmenta Khaled Pollution 01226891242 l Protection abdelrahman observer Department Mona Hassany Civil Engineer SCZone 01002093974 [email protected] Mohamed Walid Youssef Admiral SCZone 0122270409 [email protected] Ibrahim

Kamal Ezzat Admiral SCZone 01001640171 [email protected]

Environmental &Water Samia Project Engineering 01003449530 [email protected] Massoud consultant Consultant (EWATEC) Environmental &Water Nermin nermin.ibrahim@ewatec- Project Engineer Engineering 01000032776 Ibrahim eg.com Consultant (EWATEC) Environmental &Water Hend El- Hend.elwakeel@ewatec- Project Engineer Engineering 01200884878 Wakeel eg.com Consultant (EWATEC) Environmental &Water Mohamed Employee Engineering 01225549413 Anwar Consultant (EWATEC)

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez

❖ Women Contribution in the public consultation session of Site (44) – Adabeya Port:

As illustrated from the previous table, women contribution in the session was about 59% where the following women were attended:

• Mrs/ Entsar Mostafa-Manager of Media and Information Administration – EEAA at Suez Governorate. • Mrs/Amal Mahmoud-Director of the distance learning hall at Suez Governorate. • Mrs/Eman Salama Ahmed- Member in Suezbalady Association. • Eng. Fawzaya Mohamed Abdallah-CEO of National Council for Women in Suez governorate. • Eng/Nermin Mohamed fathy-Environmental Affairs Officer at SCZone. • Dr. Samia Massoud, the consultant who prepared the study and leading the public consultation session. • Two female engineers from the team work who prepared the study. • Four women representatives from Adabeya port (Secretary of Adabeya Port Director, translation department, Electonic management, Financial Affairs).

Annex (6) includes copies of the invitations sent to the attendees, registration list for the participants in this session, photos for the attendees during the session, as well as questionnaire form.

In this session, the following was done:

- Opening speech by Dr.Samia Massoud- the consultant who prepared the study for the proposed project, and then she presented the stages of the proposed project, negative & positive environmental effects, mitigation measures that will be followed, environmental & social management plan of the project.

- Receiving inquires and questions which have been answered by Dr.Samia Massoud as shown below:

Firstly: The opening Speech:

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez The consultation session of the proposed project initially started with an opening speech by Dr.Samia Massoud- the consultant who prepared the study for the proposed project, as she welcomed the attendees and the speech included a brief definition of the Sustainable Persistent Organic Pollutants Management Project, and its important role in the “safe disposal of banned and obsolete pesticides stored in the sites under study in North Delta province (Nubareya city & Alexandria) and site (44) at Adabeya port.

Dr.Samia also illustrated that the project management had assigned a foreign company “TAWU” in 2017 to take the responsibility for the inventory of obsolete pesticides stored in the sites under study which pose a serious threat to human health & surrounding environment. She also added that repackaging of these OPs will be carried out by an international company to be safely disposed either in the local cement kilns or to be incienrated in specific incinerators outside Egypt.

Dr.Samia stressed also on the importance of holding the consultation session to present the stages of the proposed project to the various competent authorities including its environmental & social impacts that may be produced and mitigation measures that will be followed, in order to know the extent of community’s interaction with the proposed project in order to take their opinions into consideration during implementing the project.

Secondly: Presenting the Project and analysing its Environmental &Social Impacts, Mitigation Measures, Social impact Analysis and Environmental Management plan:

• The presenter Dr. Samia Massoud “the main consultant for the project” has clarified the importance of the Environmental Social Impact Assessment (ESIA) study for the repackaging of OPs project in Site (44) –Adabeya port –Suez governorate. • Dr. Samia Massoud indicated that the total quantity of obsolete pesticides stored in these four sites is about 94.118 tons; about 7.32 ton of the total quantity is stored in site (44) which poses a serious threat to human and all components of the surrounding environment. She also highlighted on the reasons for the accumulation of these pesticides in these sites. • Dr. Samia presented all the regulations, laws and legislations related to the project and also mentioned some laws such as the Environmental Law No. 4 of 1994 257

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez amended by Law No. 9 of 2009 and the amended executive regulations on the detailed requirements for the management of hazardous waste in addition to the environmental and social safeguard policies of the World Bank (Environmental Assessment (EA) and Environmental Health and Safety Guidelines (EHSG). • She also gave a brief about the international agreements related to the proposed project, which are: Basel Convention, Rotterdam Convention, Stockholm Convention, and Bamaco Agreement. • Dr. Samia then described the main environmental elements in Suez governorate where site (44) is located, she also described surrounding areas around site (44), and she also displayed internal and external photos for surrounding areas for the site. • Dr. Samia also presented the results of the measurements that were taken from inside and outside site (44) for air quality, water and soil quality which were analysed in the accredited “The Main Chemical Warfare Laboratories”. • Dr. Samia described briefly the risk assessment study and the hydrogeological study that were conducted for site (44) by specialized consultant. • After that, Dr. Samia described briefly the stages of implementing the proposed project, which include the following: ▪ Inventory for types & quantities of OPs stored site (44). ▪ Repackaging and handling of obsolete pesticides. ▪ Preparing and packing the container. ▪ Loading the repacked OPs and transportation stage.

• Dr. Samia described each stage of the project starting from entering the store, repackaging and packing of pesticides, then the stage of loading and transport from the store for final disposal she also clarified all the instructions that must be followed and the necessary precautions when dealing with pesticides, as personal protective equipment (level B) with the entire body covered which is required to ensure that workers will be protected and not directly exposed to these pesticides. • Moreover, during the session, Dr. Samia has presented the different environmental & social impacts during the phases of the project. • She referred to the study conducted to assess the potential risks of site (44), and talked about the risks that the workers may face and how to avoid these risks when 258

English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez entering the store and dealing with packaging of pesticides then the risk posed by transporting the packed containers outside the store and finally the risk posed during loading the containers on trucks. • Then, Dr. Samia presented a summary of the mitigation measures which are need to be followed in order to reduce the negative environmental & social impacts that may be produced during the different stages of the project. • Dr. Samia was then discussed the proposed alternatives of the project as follows: ➢ The First alternative: “without implementing the project and keep the situation as it is” this will deteriorate the environmental situation resulting from poor & long storage duration of obsolete pesticides which in return adversely affects the safety of the environment and pose a threat to the human health especially people working in the stores in addition to the nearby residential and agricultural areas. ➢ The Second alternative: “Burning of pesticides in local incinerators in Egypt”: it cannot be implemented as there are no especially designed incinerators in Egypt for the safe disposal of these wastes in addition to its expensive cost. ➢ The Third alternative: “Burning pesticides in cement kilns in Egypt”: ▪ This alternative was studied through the management of the Sustainable Persistent Organic Pollutants Management Project where cement kilns were evaluated and found that pesticides could be incinerated in the cement kilns if they are packed in a certain way that is appropriate to be fed into the fuel burning system of the kiln. ▪ This alternative requires that the cement companies should have the EEAA approval for incineration of hazardous wastes including POPs in the cement kilns. The kiln has pollution control procedures to deal with any emissions which may be released from the incineration process to ensure that the concentrations of these emissions especially dioxin & furan are below the allowable law limits.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez ▪ It is used for disposal of limited amount of some pesticides. ▪ There is no chemical treatment units in Egypt designed for this type of disposal.

➢ The Fifth alternative: “Burying in landfill in Egypt”: ▪ There are no landfills in Egypt designed to receive hazardous organic wastes including pesticides.

▪ Probable contamination of soil or underground water in case of migration or leakage of contaminants from the bottom of the landfill cells.

▪ Requires very high investment to build this type of landfill which is complying with the international standards.

➢ The Sixth alternative: “Disposal of obsolete pesticides outside Egypt”: ▪ Obsolete pesticides can be disposed outside Egypt and incinerated at high temperature in large incinerators available in Europe designed for this purpose. Finally, Dr. Samia confirmed that incineration of OPs either in local cement kilns or in incinerators outside Egypt are the two preferable alternatives for safe disposal of OPs. After that, Dr. Samia has clarified the components of the environmental & social management plan (ESMP), monitoring plan that will be followed during and after the completion of the project as well as the emergency plan and occupational health and safety measures.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez Thirdly: Open Discussion:

Several questions by attendants are directed and answered by Dr. Samia Massoud as follows:

Q 1: Which the repackaging project will not be implemented outside the port?

Answer: The repackaging stages will be conducted in an area nearby site (44) in Adabeya port as the obsolete pesticides exist inside 40 ft3 container which is located in the containers area.

Q2: How the repackaged waste containing residual pesticides will be handled and disposed?

Answer: Repackaged waste containing pesticides will be handled and disposed using the same methods as the pesticides; this waste will be collected and packed in double layer container according to (UN and EPA requirement).

Even the 40 m3 container (site 44) after removing the pesticides will be dismantled and disposed out with the obsolete pesticides.

Q3: why the project is named repackaging of obsolete pesticides and not named safe disposal of pesticides?

Answer: the scope of work of the ESIA study is limited to safe repackaging of obsolete pesticides with all its stages until trucking to disposal sites and does not include the disposal process.

The following is detailed scope of work of the ESIA:

- Identification and quality evaluation of obsolete pesticides. - Handling and repackaging of obsolete pesticides - Preparation and applying safety measure on port containers prior packing. - Loading the packages on trucks. - Transportation to ultimate disposal site.

Q4: In case of local incineration in cement kilns what will be the controlling regulations and guidelines?

Answer: The Pops Management project evaluated the local cement kilns and based on that, they determined the cement companies who have cement kilns suitable for receiving and incineration of these pesticides.

The pesticides have to be packed in special containers approved by UN and EPA and also to be suitable in size and material for feeding the fuel system of the kilns.

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez In addition, the cement companies should have the approval of EEAA which allow burning of these types of hazardous waste (EIA approval).

Also the kilns should be equipped with dust and gas emission control systems and also have trained employees on safe handling procedures of hazardous obsolete pesticides in order to protect health, environment and workers from hazards.

Fourth: Fill up the Questionnaire forms:

The form format and the feedback of the attendees are attached in Annex (6).

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English ESIA Study for Repackaging & Storage of Obsolete Pesticides in North Delta Province & Adabeya Port in Suez ANNEXES:

Annex (1): Hydrogeological Study of all sites.

Annex (2): Detailed description of Beheira, Alexandria & Suez governorates

Annex (3): Risk Assessment Studies of all sites.

Annex (4): Laboratory certificate

Annex (5): Inventory of types & quantities of pesticides existing in each site.

Annex (6): Public Consultation Sessions documents – (Alexandria, Adabeya AND Noubareya)

• Invitation letters and Faxes • List of Consultation Attendees • In-Session photos • In – Session Questionnaire feedback

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