World Bank Document

Environmental and Social Impact Assessment (ESIA) for the

Disposal of Obsolete Pesticide Stockpile in Al- Adabeya Port, Suez - Egypt EEAA

Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized

1 Environmental and Social Impact Assessment (ESIA) for the

Disposal of Obsolete Pesticide Stockpile in Al- Adabeya Port, Suez - Egypt EEAA

ACRONYMS

ADI Acceptable Daily Intake

APC Agricultural Pesticide Committee

AT Allowable Tolerances

BAF Bioaccumulation Factor

BAT Best Available Techniques

Committee on the Biological Effects of Ionizing Radiations of the National BEIR Research Council

BEP Best Available Technology

CAPL Central Agricultural Pesticides Laboratory

CAPMAS Central Agency for Public Mobilization and Statics

COP Conference of Parties

ECD Electron Capture Detector

EEAA Egyptian Environmental Affairs Agency

EMP Environmental Management Plan

EMTK Environmental Management Tool Kits

EPA Environmental Protection Agency

ERA Environmental Risk Assessment

ESIA Environmental and Social Impact Assessment

ESMP Environmental and Social Management Plan

FAO Food and Agriculture Organisation

FM Field Manager

GARSP General Authority for Red sea Ports

GCSS General Company for Silos and Storage

GDP Gross Domestic Product

GEF Global Environment Facility

GIS Geographic Information System

GOE Government of Egypt

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Disposal of Obsolete Pesticide Stockpile in Al- Adabeya Port, Suez - Egypt EEAA

HC Henry’s Law Constant

HCH HEXA Clorcyclo Heron

HDI Human Development Index

IARC International Agency for Research and Cancer

IBAS Important Bird Areas

ICRP International Commission on Radiological Protection

IDLH Immediately Dangerous to Life or Health

IDLIT Immediately Dangerous to Life or Health

ISC Integrated Simulators Complex

MALR Ministry of Agricultural and Land Re-climate

MHP Minister of Health and Population

MSTMT Arab Academy for Science, Technology And Maritime Transport

MTS Maritime Transport Sector

MWRI Ministry of water Resources and Irrigate

NARAP North American Regional Action Plan

NAUCL Sodium Hypochlorite

NCRP National Council on Radiation Protection and Measurements

NGO Non -Governmental Organization

NIOSH National Institute of Occupational Safety

Npcu National Project Coordinator Unit

NPM National Project Manager

OECD Organization for Economic Cooperation and Development

OP Absolute Pesticides

OSHA Occupational Safety and Health Authority

PAP Project Attested People

PDO Project Development Objective

PIC Prior Informed Contest

PL Permissible Levels

PMU Project Management Unit

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Disposal of Obsolete Pesticide Stockpile in Al- Adabeya Port, Suez - Egypt EEAA

POPRC Persistent Organic Pollutants Review Committee

POPS Persistent Organic Pollutants

PPE Personal Protection Equipment

PPM Part Per Million

PSMS Pesticide Stock Management System

QAIQC Quality Assurance / Quality Control

R&D Research and Development

RERF Radiation Effects Research Foundation

SIA Social Impact Assessment

SMP Social Management Plan

SUMATRA Surface and Marine Transport Regulatory Authority

SWOT Strengths, Weaknesses, Opportunities and Threats

TA Technical Advisor

Tl V Threshold Limit Value

TLV Threshold Limit Value

TWA Time-Weighted Average

UNEP United Nation for Environmental Protection

UNSCEAR United Nations Committee on the Effect of Atomic Radiation

VP Vapour Pressure

WHO World Health Organization

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Disposal of Obsolete Pesticide Stockpile in Al- Adabeya Port, Suez - Egypt EEAA

Table of Contents

Page EXECUTIVE SUMMARY 1 1. Background 1 2. Environmental Legislation and Institutional Framework 3 3. Inspection of Lindane Containers 4 4. Description of the Proposed Project Site 4 5. Description of the Existing Environment – Baseline Data 5 6. Environmental and Social Impacts 9 7. Environmental and social management plan 10 8. Safeguarding activities 11 9.Environmental and social monitoring plan 11 10. Analysis of alternatives 12 11. Environmental risk assessment 13 12. Public Consultation 14 13.The estimated costs of implementation 15

CHAPTER I: INTRODUCTION 16 1.1. General information 16 1.2.Components of POPs Project in Egypt 16 1.3. Project Owner 18 1.4. Consulting Firm 19

CHAPTER II: Environmental Legislation and Institutional Framework 20 2.1.Introduction 20 2.2.The List Approach 20 2.3.World Bank’s Operational Policies 21 2.4.Analysis of relevant legislation (National, Regional and International) 21 2.5.Hazardous Wastes Regulations 23 2.6. Pesticides use & handling 39 2.7. Law 48/1982 Regulations 39 2.8. Law 48/1982 amended executive regulations with decree 92/2013 39 Article no.4 2.9.Agricultural Laws & Ministerial Decrees 40 2.10.Ministry of Manpower Law 41 2.11. Regional Conventions 41 2.12. International Conventions 41 2.13. Determine the policy, legal, and administrative requirements in Egypt; 44 Environmental policy 2.14. Strategy and action plan elements of the NIP 44 2.15. World Bank Safeguard Policies 44 2.16. Regulations and Ambient Standards/guidelines (air, water, land) governing 45 environmental quality, industrial discharges, health and safety

CHAPTER III: DESCRIPTION OF THE PROPOSED PROJECT 48 3.1. SITE DESCRIPTION 48 3.2. Project Objectives 50 3.3. Management of the Project 51

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3.4. Rationale for conducting ESIA 51 3.5. Scope of the Project 52 3.6. Methodology 52 3.7. Basic Information about Lindane 54

CHAPTER IV: Environmental and Social Baseline data 68 4.1. DESCRIPTION OF THE ENVIRONMENT 68 4.2 Environmental Biology 88 4.3. Socio-Economic context 91 4.4 Radiometric survey of obsolete lindane containers 100 4.5 Inspection of the condition of containers by COMIBASSL 102

CHAPTER V: ENVIRONMENTAL AND SOCIAL IMPACTS 103 5.1. Introduction 103 5.2 Obsolete Pesticides (Lindane in Al Adabeya Port) 104 5.3 Impacts as per existing conditions of the Lindane stockpile 105 5.4 Potential Negative Impacts 108 5.5. Socio-economic and health impacts 110 5.6. Impacts on natural habitats 112 5.7. Environmental risk Analysis 116 5.8.Sampling Locations 137 5.9. Analytical results 139 5.10. Standards and Regulations 143 5.11. Evaluation of Results with Respect to Goals and Standards 145 5.12. Simulation of the Worst Case Release Scenario 146 5.13. Risk Management Options 149 5.14. Conclusion and Recommendations 150

CHAPTER VI: ENVIRONNEMENTAL and SOCIAL MANAGEMENT PLAN (ESMP) 151 6.1 General Context 151 6.2 Objective 152 6.3 Environmental and Social Management Plan Background and Considerations 153 6.4 Mitigation Measures for Current Impacts 153 6.5 Strategy 155 6.6 Safeguarding impacts 156 6.7 Safeguarding Management Aspects 160 6.8 Adopted Implementation Strategy 173 6.9 Cost Considerations for obsolete Lindane Safeguarding and Disposal 174 6. 10. Environmental and Social Management Training Requirements 176 6. 11. Environmental and Social Monitoring Plan 178 6.12. Terms of Reference of the (TOR) Project Team 187 6. 13. Project Team Monitoring and Reporting 189 6.14. Monitoring of the PMU 191 6.15. Project level grievance/complaint management system 191

CHAPTER VII: ANALYSIS OF ALTERNATIVES 192 7.1.Obsolete Lindane Safeguarding Alternatives 192

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7.2.Pesticide and Pesticide Containers Disposal Alternatives 195 7.3.Comparison of options for the involvement of PMU and contractors in 197 obsolete lindane management aspects

CHAPTER VIII: PUBLIC CONSULTATION AND STAKEHOLDERS ANALYSIS 200 8.1.Introduction 200 8.2.The preliminary stakeholders’ engagement and consultation 201 8.3.Stakeholders Survey and Analysis 207 8.4.The public hearing 222

References 233

Annexes

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EXECUTIVE SUMMARY 1. Background: Egypt has large stockpiles of obsolete pesticides that have deteriorated over the years. These materials are considered as hazardous waste. As reported by the Egypt Sustainable Persistent Organic Pollutants (POPs) Management Project (P116230), there are 18 specific sites of obsolete pesticides (OP) in Egypt and could be a candidate for the treatment and disposal. Based on the available data, the total amount of obsolete and POPs pesticides ranges between 2,250 and 4,600 tons. From this amount, the amount for POPs pesticides ranges from 250 to 1,500 tons. A POPs site can have one or more sources of contamination.

The strategic objective of the environmental policy in Egypt is to introduce and integrate environmental concerns relevant to protecting human health and managing natural resources into all national policies, plans, programs and projects of the national development plan. The medium-term objective is to preserve natural resources, biological diversity, and national heritage within a context of sustainable development. The short-term objective is to reduce current pollution levels, minimize health hazards and to improve the quality of life for citizens and residents in Egypt.

Environmental protection has assumed increasing importance in Egypt over the last 20 years, as a result of improving public education and awareness, leading to pressure on the government to take action, increasing privatization of the industrial sector, and thus greater accountability, and pressure from donors to ensure that their projects are environmentally sustainable and to assist Egypt in modernizing its environmental management systems. The Government of Egypt (GOE) is strongly committed to controlling industrial discharges as well as to stricter and more consistent monitoring of all factors that influence drinking water quality and urban air pollution.

It ratified the Stockholm Convention for the management of Persistent Organic Pollutants (POPs) in May 2002.

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The proposed POPs Project triggers two environmental safeguards policies: (i) Environmental Assessment, and (ii) Pest Management. The results of the equivalence assessment showed that the World Bank's EA policy and the Egyptian safeguards systems on EA and Pest Management, as amended through 2009, are nearly fully equivalent. The major gaps are to issue a regulation clarifying that all POPs sub-projects will be subjected to an EIA and prepare TORs or specific guidelines for such EIA (Annex 1). Also, the legal and regulatory framework should be brought into full consistency with the Stockholm Convention and other conventions applicable to POPs and to which Egypt is a party. These gaps can be implemented as part of overall Project implementation. Accordingly, the Government of Egypt (GOE) drafted a National Implementation Plan which includes: (1) the management and environmentally sound disposal of PCBs and obsolete pesticides; (2) institutional and regulatory strengthening measures as well as (3) awareness building and stakeholder involvement activities.

To help achieve these goals, the Egyptian Environmental Affairs Agency (EEAA) requested the World Bank to prepare a GEF project that would focus on all three POPs categories as well as build capacity. Based on this request, a project proposal was submitted and approved for funding under the Global Environment Facility in June 2009. The project aims to support the GOE in the management of obsolete pesticides and POPs and PCBs, and proposes to invest in some pilot sites as demonstration of good practices.

Al Adabeya Port is one such identified pilot site. The project is essentially a cleanup Project which brings substantial environmental and health benefits. However to ensure that all project activities are undertaken in an environmentally and socially sound manner, there is need to undertake an Environmental and Social Impact Assessment (ESIA) and/or Environmental and Social Management Plan (ESMP) for each activity.

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Al Adabeya Port storage facility in Egypt was built in 1975 and dedicated for the storage of dry bulk. It is situated about 125 km east of Cairo easily reachable by good condition highway, The nearest larger city is Suez city in Suez governorate (17 km to the North). The storage is an open yard designed for temporary storage of shipped goods. The yard has two gates one of them (at the NE corner of the yard) is the emergency gate.

It is estimated that about 220 tons of obsolete lindane, have been stored at the Al Adabeya Port since 1998. These obsolete stockpiles are packed in 25 kg heavy paper bags supported by a plastic outer wrapping and stored in 10 standard 20 feet containers occupying an area of 5,850 square meters (225 x 26 m).

The soil in the yard has not been sampled to establish the effect on the soil quality especially the content of chlorinated pesticides. The levels of exposures of the stored pesticides are unknown. There are records of the levels of radioactivity direct where pesticide containers are stored. Detailed inventory is needed and therefore all the containers have to be inspected. Meanwhile, the Chemical Weapons Sector has analyzed the contents of the containers through its accredited laboratories.

It is understood that the obsolete and POPs pesticides may be stored in a substandard way and limit. There may be possibility of emissions as a result of high ambient temperatures; however there are no environmental records. The proposed project involves the handling, packaging, transporting and disposal of these hazardous stockpiled pesticides, as well as the remediation of any site contamination, if required.

Consequently, the Environmental and Social Impact Assessment (ESIA) was prepared for the implementation of the National Implementation Plan in the country. The major aim of ESIA is to put in place a decision making tool for environmentally sound management of obsolete lindane stockpile in Al Adabeya Port, Suez.

2. Environmental Legislation and Institutional Framework:

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Egypt has a number of instruments for sustainable development guidance in the country in terms of policy, legal and institutional arrangement. 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 ESIA. 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, Agricultural Laws & Ministerial Decrees related to pesticides, Ministry of Manpower Law (Law 137/1981).

In addition to policy and legal instruments, the some regional conventions were taken into account: Bamako 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 Transboundary 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).

3. Inspection of Lindane Containers: In order to avoid damage during shipment of obsolete lindane containers, the container should, however, be properly inspected. Comibassl International has been inquired to carry out full inspection to ensure that the containers are suitable for carrying this shipment. The condition of the containers has been visually verified by surveyors of COMIBASSL and found to be structurally sound and suitable for carrying shipment of lindane.

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4. Description of the Proposed Project Site: The site area is flat, paved and occupying an area of 5,850 square meters (225 x 26 m). This area belongs to the General Company for Silos & Storage (GCSS). The site of the stockpiling of obsolete lindane visited is in very good condition in terms of the paved ground and the location relative to the activities in the port. In terms of security, the site, where the stockpile is located, is completely fenced. The 10 lindane containers are safely stacked on the paved ground. In each container, the obsolete lindane bags are stacked in such a way that the upper one third of the container is free. Most of the containers were sealed intact, while each of the 10 containers contains one or two damaged bags which are not efficiently sealed or repacked and kept haphazardly due to the opening during previous sampling activities carried out by the Chemical Weapon Sector and the Egyptian Atomic and Energy Authority (EAEA), thus giving a bad smell.

5. Description of the Existing Environment – Baseline Data: Information was gathered on the existing physical environment, particularly as related to climate, geology, geomorphology, soils, hydrology and drainage.

Soils from the obsolete pesticides yard and from adjacent locations were sampled for grain size analysis to determine soil textures and estimate soil infiltration rates. Moreover, soil samples will be analyzed for their pesticides (especially lindane) to indicate whether soil is contaminated by obsolete pesticides or not and to determine which isomer of lindane contaminate the soil.

 Surface & Groundwater

Surface and groundwater characteristics and flows were assessed using field investigation as well as maps, aerial photographs and data from previous reports. The baseline data provide a quantitative measure of the existing groundwater conditions and also provide an indication whether groundwater is polluted by lindane as a result of 16 years period of storage of obsolete pesticides (lindane) or not.

The Al Adabiya port lies at the extreme northeastern part of the Eastern Desert of Egypt. The northern part of Egypt including, the north Eastern Desert, the north

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Western Desert, the Nile Delta and north Sinai lie in the unstable shelf area (Said, 1962). The obsolete pesticides yard located to the east of Gebel Ataqa and to the north of the northern Galala plateau. It also lies to the north of the down streams of Wadi Hagul, Wadi Badaa and Wadi Ghweiba.

 Geology, structure & soil

The Gulf of Suez region form a distinct structural unit that was involved throughout time in movements that brought it under the sea for almost the entire length of its geological history.

The distribution of the seismic activity of Egypt is more affected by the distribution of the seismic stations. Recently many local seismic stations are installed in Aswan, Minya, Qattamiya, Dahashour and Hurghada, therefore many small to moderate events were recorded.

 Rainfall & Groundwater

Rainfall represents the main source of recharge of groundwater in this area, where rainfall intensity is about 20 mm/year. It infiltrates downward rapidly through fissures in the limestone tableland. The important groundwater aquifers in the Ain Sukhna area. The Quaternary aquifer represents the main water-bearing strata in the Ain Sukhna area. The groundwater is pumped by the companies, factories and tourism villages distributed in the area. It is built up of sand and gravel with clay and limestone intercalations. The penetrated thickness of the Quaternary aquifer in the mouth of Wadi Ghweiba reaches about 400 m. It decreases towards north and northeast. Groundwater in the Quaternary aquifer occurs under free water table condition. The isotopic investigation indicates that recharge of this aquifer depends mainly on the infiltration of surface runoff and upward leakage from deep aquifers. The discharge is

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mainly being through the pumping for different purposes. The depth to water ranges between 6.20 m and 60.20 m and the water flow direction is being towards the Gulf of Suez.

 Flora

The survey encompassed the northern part of Gebel El Galala El Baharya, which was found devoid of vegetation. The plant growth is, therefore, confined to the drainage system (run-off desert). The central part of the wadi bed is usually devoid of perennial plant cover and vegetation is mostly restricted to the sides. As they support a floral community comparatively richer than the rest of the plain and being easily accessible, wadis are subject to grazing and cutting.

Plant cover varies in obvious relation with the extent of the catchment area and the texture and depth of the bed cover. Several plant communities may be recognized. The dominant species include Acacia raddiana, Tamarixaphylla, Launeaspinosa, Hammadaelegans, Anabisarticulata, Panicumturgidum, Zillaspinosa and Zygophyllum coccineum.

Plants that characterize the cliffs and dry waterfalls that intercept the courses of the wadis traversing the hills, include: Capparisspinosa, C. sinaica and Ficuspalmata.

Fauna

Characteristic reptiles of this habitat type in the Gulf of Suez area include rock dwelling forms such as the Egyptian Gecko (Tarentolaannularis), the Pale Agama (Agama agamaspinosa) and the Sinai Agama (Pseudotrapelussinaitus). In the wadi beds, the Egyptian Dabb Lizard (Uromastyxaegyptius) and the Horned Viper (Cerastescerastes) are found. Wadis with fine sandy substrates are characterized by the presence of Nidua Lizard (Acanthodactylus scutellatus), while Bosc’s Lizard (A. boskianus) is common in those with coarse sand (EEAA/UNEP, 1993).

Characteristic breeding species of birds include Neophronpernocpterus, the Sand Partridge (Ammoperdixheyi), Oenanthelugens, Oenanthemonacha, Scrub Warbler

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(Scotecercainquieta), Pharaoh Eagle Owl (Bubo bubo), Trumpeter Finch (Rhodopechisgithaginea) and Pale Crag Martin (Ptyonoprogneobsoleta). There is a great abundance of migratory birds passing through the wadis and mountains, particularly during the autumn migration.

 Socio-Economic conditions:

Socio-economic status and response to project and its ESIA are influenced by a complex mix of socio-economic settings at which the project will be implemented. Thus, before the ESIA findings are presented, a brief secondary data review of socio- economic context of project area is presented such as geographic features, Population features, . Labor force, Education features, Literacy, Health features, General health indicators, Women and children health indicators, Supply services, Sanitary sewage, Energy supply, Potable water supply, Communication.

 Radiometric survey of obsolete lindane containers

The measured radiation dose rate found to be in the range from 0.08 to 0.029 μSv/h and still within the permissible dose rate based on many organizations such as International Commission on Radiological Protection (ICRP), the (US) National Council on Radiation Protection and Measurements (NCRP), the Committee on the Biological Effects of Ionizing Radiations of the National Research Council (BEIR), the United Nations Committee on the Effects of Atomic Radiation (UNSCEAR), and the Radiation Effects Research Foundation (RERF) Also, there is no harmful radiation effects from these containers based on the radiometric survey.

 Inspection of the condition of containers by COMIBASSLIn order to avoid damage during shipment of obsolete lindane containers, the container should, however, be properly inspected. Comibassl International has been inquired to carry out full inspection to ensure that the containers are suitable for carrying this shipment. The condition of the containers has been visually verified by surveyors of COMIBASSL and found to be structurally sound and suitable for carrying shipment of lindane. The complete report of Comibassl International is attached with this report (APENDIX 5.3).

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6. Environmental and Social Impacts: A variety of environmental and social impacts are likely to occur during safeguarding, transportation and final disposal of the obsolete lindane stockpile at Al Adabeya Port A storekeeper assigned by Al Adabeya Port Authority manages the store regularly checks the lindane containers at least once per week. The guard or security is provided almost 24 hours a day. In terms of safety, no fire safety equipment was visible neither were the first aid kits or PPE for the storekeeper to use, except at the shaded store to the vicinity of the stockpile (230 m), which is belonging to the General Company for Silos & Storage (GCSS).

The main impacts will be on workers due to inhalation gases that are released by the obsolete lindane. This is mainly due to the fact that some of the pre opened bags are not sealed intact and an odor or faint smell is felt around the vicinity of the containers especially when doors are open.

There was a unanimous agreement from all stakeholders consulted during the socio-economic survey that these containers must be disposed as soon as possible to avoid its negative impacts on the human health and the environment.

Except for the site workers all stakeholders included in the sample have university degrees. High education level usually reflects high level of awareness. Most stakeholders have years of working experience in the lindane situation of at least five years. Therefore, they have sufficient experience to allow them to have practical knowledge and better perception of the situation of the impacts of the project. The results indicated that the site workers are the only stakeholders who have regular exposure to any risks associated to the lindane.

The social survey results indicated that the site workers and supervisors are the only stakeholders who have regular exposure to any risks associated to the lindane containers. The rate of symptoms occurrence is very low for all symptoms except the eye itching which was more common. All site workers, supervisors and GCSS

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administration representatives stated that they always encounter a pungent pesticide smell whenever they come closer to the lindane containers. Accordingly, we can conclude that although the lindane is stored in sealed containers there still could be some exposure.

 It was found that all individuals from all stakeholders’ group perceive that the project will certainly have positive impacts. These impacts are:  Eliminate the risks of environmental pollution that would occur from the existence of these pesticides containers  Eliminate the health impacts of the exposure to this pesticide especially on the workers at the site. Increase the sense of security for the workers in their working environment.  Improve the work conditions at the site and reduce the occupational health hazards on the workers at the site.  Eliminate the financial loss of the forgone rent of the space occupied by the containers  The stakeholders suggested that to avoid any risk related to the project, the activities of disposal particularly those related to transportation need to be carefully planned.

7. Environmental and social management plan: The objective of the Environmental Management Plan (ESMP) for this ESIA is to provide a strategy for the management of obsolete lindane with a specific focus on safeguarding and final disposal of the obsolete lindane and lindane contaminated empty bags in order to reduce their impacts and risks posed by the stockpile of obsolete lindane. The ESMP covered all aspect related to the safeguarding and disposal operations such as verification; repackaging operations including registration; transport; storage and also it shall address the final disposal options (local/international) of the obsolete lindane including compliance with relevant international chemical conventions. The matrix of ESMP is incorporated in Chapter VI of this report.

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8. Safeguarding activities: To ensure that all current and potential future impacts of the obsolete lindane stockpile stores and contaminated sites are covered, the ESMP will be implemented in two steps. Step 1 will focus on mitigation of effects of the current situation while Step 2 will focus on mitigation of effects of safeguarding and disposal operations. To prevent public health and environmental hazards from getting out of hand at obsolete lindane stockpile and contaminated sites that are in critical conditions, emergency safeguarding will be carried out while awaiting the main safeguarding and disposal measures.

Before the main planned safeguarding operations commence, emergence safe guarding measures need to be taken to put an end to health and environmental risks from obsolete lindane stockpile.

After safeguarding and removal of obsolete lindane, the temporary site of lindane stockpile will need to be cleaned and/or decontaminated as soon as their use comes to an end. In the same vein, vehicles and equipment used in safeguarding and transportation activities that will remain in the country should be decontaminated. Sodium hypochlorite (NaOCl), which is the oxidizing agent of choice during clean up operations, can be used.

9. Environmental and social monitoring plan: Monitoring is needed to check if and to what extent the impacts are mitigated benefits enhanced and new problems addressed. Plans for monitoring have been included in the Environmental and Social Monitoring Plan. The monitoring plan as for ESMP also assigns responsibilities for monitoring activities.

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anticipated that use of NGO monitors will provide an impartial assessment of the effectiveness of the proposed mitigation measures. The PMU shall identify the most appropriate national NGO to fill this role. FAO technical Support Missions monitoring and simultaneously provide backstopping advices and follow up from the FAO Headquarters etc.

One of the main objectives of the GEF project is to build on the existing capacity and to establish new capacity in each of the key components of the project. Specifically, those who will be involved in safeguarding and disposal activities as elucidated in this ESIA document need to be properly trained to enable them discharge their duties effectively, safely and in an environmentally friendly manner. In view of this, capacity needs to be developed in the following areas: Health and safety, Environmental protection, Equipment supply, Public consultation, management, Environmental policies and programs, Management and planning and budgeting. The matrix of Environmental and Social Monitoring Plan is incorporated in Chapter VI of this report.

10. Analysis of alternatives: The two major alternatives, which have been proposed during this study and have been discussed with the stakeholders during the public consultation workshop in May and June 2014, are: "without project" and "with project". It must be stated that the alternative disposal options for POPs pesticides stockpiles are largely the same, however, all notable differences are highlighted below.

In principle, safeguarding is required for lindane stockpile, pesticide contaminated empty bags, contaminated equipment, pesticide contaminated wastes, and contaminated soil.

With respect to the safeguarding needs of the obsolete pesticides, implications of three alternatives were considered and analyzed. The alternatives are: i) no safeguarding action, ii) safeguarding at the current location, iii) safeguarding at the

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main pesticides storage facility of the Ministry of Agriculture (lindane stockpile should be transferred from Al Adabeya Port). It is noteworthy that, unlike the options of safeguarding at the current temporary storage locations of the obsolete lindane on the yard, the option of no safeguarding action does not present any meaningful opportunities. This is understandable because the no action option simply maintains the status quo whose deficiencies are the very reason for carrying out this project.

Considering the discussion on the rationale for establishing safeguarding at the main pesticides storage facility of the Ministry of Agriculture and Land Reclamation (obsolete lindane stockpile should be transferred from Al Adabeya Port), and based on the SWOT analysis, it is evident that the safeguarding at current store location on the yard is most favorable. This is the one recommended for adoption in subsequent decisions in this project.

It is evident from the SWOT analysis that, for transporting obsolete lindane from the shipping port to the ultimate disposal place, sea freighting is the favorable option. There is no doubt that the advantages of sea freighting over air freighting are not disputable.

In addition to the above, it can be noted that due to the lack of incinerators that are large enough and compliant with recognized standards, destruction of obsolete Lindane empty bags, and other types of wastes by incineration in Egypt, is currently not possible.

11. Environmental risk assessment: Based on the site/field observations/investigation/survey, the analytical results of air and soil samples, the calculation of the risk factors FP and FE, and the simulation of the worst case release scenario, it has been concluded that there is a smell of obsolete Lindane odor in the vicinity of the storage area and the containers that leads to minor human health and environmental risk. Lindane may pose a hazard threatening the onsite workers and employees and those in the neighboring facilities and plants (industrial or commercial), which are in

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the impact zone as defined by the risk assessment. Referring to the FP (2,860,000),

FP* = 100 and FE (18), the storage site of Al Adabeya Port stockpile of obsolete pesticides is considered as (Problematic).

After applying risk assessment study to manage the storage yard (contaminated site) at Al Adabeya Port, The Technical Committee decided that the Best Available Techniques (BAT) and the Best Environmental Practice (BEP) method to manage the problem is to eliminate the source/contaminant itself (Obsolete Lindane Pesticide) from contact with the receptors.

An immediate action should be taken to proceed with the proposed safeguarding activities and the final disposal of obsolete Lindane through the export and dispose of them at a licensed facility overseas in compliance with the requirements of the Basel and Stockholm Conventions.

12. Public Consultation: Individual meetings, small and large group meetings have been conducted several times with 4-formate of questionnaires which have been analyzed. Public participation and consultation include public with different levels of education and different age range.

On Tuesday 22nd July 2014, a large public consultation meeting was conducted in the Red Sea Ports Authorities and the meeting was attended by the Governor of Suez Governorate, Director of the Red Sea Ports authorities along with about 70 attendee representing academic staff, EEAA representatives, stakeholders from many maritime companies, Al Adabeya Port workers, representative of Chemical Weapon Sector (Egyptian Army) and finally local community people and media representatives.

The Suez Governor indicated with great emphasis the importance of the study as it has put up an end to all what is being said about the presence of radioactive materials in these containers. He urged the people from the media to elucidate this point in their reports. The main salient issues and comments raised by attendee are:

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1. Delays for dealing with safe disposal and similar problems should be avoid in similar situations allover Egypt. 2. Handling these containers should be done with the highest possible precautions and safety measures. 3. The process of repacking the Lindane packs and if there are any measures proposed by the study to control and monitor this process. 4. Contingency and emergency plans to deal with the situation of any spills that might occur during the different steps of disposal especially repacking and transportation. 5. The presence of any health risks to the workers at the sites where the disposal activities take place. 6. The impacts of the storage of Lindane on the surrounding areas especially considering the long period of storage in the port. 7. Contribution of the NGOs and if they were consulted in the study. 8. The measures that should be done if any spells occurred in the Gulf water.

All these comments and questions were answered by the consulting team. In conclusion, all public and stakeholder attendee agreed about this project and confirmed that the Disposal of Obsolete Pesticide Stockpile in Al Adabeya Port, Suez should be executed in a quick and safe manner for the sake of the public health and safety.

13. The estimated costs of implementation: The Estimated costs of implementing the ESMP (safeguarding and destruction of obsolete Lindane, contaminated soils and other contaminated material) together with the cost of the environmental monitoring plane and the training requirements are about 1,824,000 (USD).

These costs are based on all-inclusive average unit rates accounting for all costs involved until the final disposal outside Egypt. The average unit rate is derived from similar cases with adjustments that take into consideration prevailing conditions.

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CHAPTER I INTRODUCTION

1.1 General information The strategic objective of the environmental policy in Egypt is to introduce and integrate environmental concerns relevant to protecting human health and managing natural resources into all national policies, plans, programs and projects of the national development plan. The medium-term objective is to preserve natural resources, biological diversity, and national heritage within a context of sustainable development. The short-term objective is to reduce current pollution levels, minimize health hazards and to improve the quality of life for citizens and residents in Egypt.

It ratified the Stockholm Convention for the management of Persistent Organic Pollutants(POPs) in May 2002.

1.2 Components of POPs Project in Egypt

Accordingly, the Government of Egypt (GOE) drafted a National Implementation Plan which includes: (1) the management and environmentally sound disposal of PCBs and obsolete pesticides; (2) institutional and regulatory strengthening measures as well as (3) awareness building and stakeholder involvement activities.

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The Project Development Objective (PDO) is to demonstrate the improved management and disposal of targeted POPs stockpiles and PCBs in an environmentally sound manner. The Project consists of three components:

a Component 1: Management of Obsolete Pesticide Stocks (GEF allocation: US$ 2.69million (totaling US$ 10.21 million, including GOE: US$ 7.52 million) 1.1: Destruction of high-risk stocks and storage of pesticides 1.2: Development of an inventory and pesticides management strategy

b.Component 2: Management of PCBs (GEF allocation US$ 3.12 million) (totaling US$ 9.93 million, including GOE: US$ 6.81 million) 2.1: Inventories and Sampling 2.2: Decontamination of Transformer Oils

c.Component 3: Institutional and Regulatory Strengthening and Project Management(GEF allocation: US$ 2.29 million) (totaling US$ 3.46 million, including GEO: US$1.17 million) 3.1: Institutional and Regulatory Strengthening 3.2: Establish and Maintain a Project Management Unit (PMU)

The total project cost is US$ 23.6 million of which US$ 8.1 million is a GEF Grant and US$ 15.5 million is the contribution of the Government of Egypt.

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The project aims to support the GOE in the management of obsolete pesticides and POPs and PCBs, and proposes to invest in some pilot sites as demonstration of good practices.

The Al Adabeya Port is one such identified pilot site. The project is essentially a cleanup Project which brings substantial environmental and health benefits. However to ensure that all project activities are undertaken in an environmentally and socially sound manner, there is need to undertake an Environmental and Social Impact Assessment (ESIA) and/or Environmental and Social Management Plan (ESMP) for each activity.

1.3 Project Owner: Egyptian Environmental Affairs Agency. EEAA

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1.4 Consulting Firm: Alexandria University, Faculty of Science.

The Consulting Team is namely:

1 Prof. Dr. Mohamed Ismail Ibrahim Dean of the Faculty of Science Professor of EIA, Department of Environmental Sciences, Faculty of Science, Alexandria University, Egypt.

2 Prof. Dr. Alaa El-Din Ramadan Mostafa Vice-Dean for Community Development and Environment Services, Professor of Environmental Management and Pollution, Department of Environmental Sciences, Faculty of Science, Alexandria University, Egypt.

3 Prof. Dr. Anwar El-Fiky Prof. of Environmental Geology & Hydrology, Department of Environmental Sciences, Faculty of Science, Alexandria University, Egypt.

4 Prof. Mahmoud Ibrahim Abbas Prof. of Radiation Physics, Department of Physics, Faculty of Science, Alexandria University, Egypt.

5 Dr. Mohamed Youssef Omar Head of Crisis Management Systems, Integrated Simulators Complex (ISC) Arab Academy for Science, Technology and Maritime Transport (AASTMT), Egypt.

6 Dr. Mohamed Awad Lecturer of Environmental Socio-economic studies, Department of Environmental Sciences, Faculty of Science, Alexandria University, Egypt.

7 Dr. Ashraf Zahran Lecturer of Air Quality and pollution, Desert and Environment Research Institute, El Sadat University, El Sadat City, Menoufiya, Egypt.

8 EsalmAly Hassan Specialist, Remote Sensing and GIS, Arab Academy for Science, Technology and Maritime Transport (AASTMT), Egypt.

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CHAPTER II Environmental Legislation and Institutional Framework

2.1 Introduction Egyptian Environmental Law No. 4/1994 states that the environmental impact of certain establishments or projects must be evaluated before any construction works are initiated or a license is issued by the competent administrative authority or licensing authority. The Executive Regulations relating to Law No. 4 identifies establishments or projects which must be subjected to an Environmental Impact Assessment based upon the following main principles: 1. Type of activity performed by the establishment. 2. Extent of natural resources exploitation. 3. Location of the establishment. 4. Type of energy used to operate the establishment.

The number of projects subject to this provision is many and will form a heavy burden to administrative authorities and the EEAA. A flexible system for the management of EIA projects has therefore been developed in order to use limited economic and

technical resources in the best possible way. The system encompasses a flexible screening system and projects are classified into three groups or classes reflecting different levels of environmental impact assessment

according to severity of possible environmental impacts.

2.2 The List Approach The list approach depends on screening projects into three categories based on different levels of EIA required according to severity of possible environmental

impacts as follows:

1. The "A" list projects for establishments/projects with minor

environmental impact.

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2. The "B" list projects for establishments/projects which may result

in substantial environmental impact.

3. The "C" list projects for establishments/projects which require

complete EIA due to their potential impacts.

2.3. World Bank’s Operational Policies The project is classified as a Category A project as per World Bank’s Operational Policies, O.P. 4.01 and Category C following the EEAA guidelines. The fact that the project is a Category A means that a comprehensive ESIA with a detailed ESMP will need to be prepared prior to project implementation.

2.4. Analysis of relevant legislation (National, Regional and International) 2.4.1 National legislations 2.4.1.1 Egyptian Environmental Law 4/1994 amended by law no.9/2009 Environmental Impact Assessment System in Egypt The Government of the Arab Republic of Egypt has issued Law no. 4/1994 amended by law 9/2009, for the Protection of the Environment. Law no 4/1994 addresses pollution resulting from existing projects or establishments as well as potential pollution from new establishments and expansions of existing ones. According to the law, new establishments are required to carry out an environmental impact assessment (EIA) before embarking on the construction or the implementation of the project or the relevant expansions. Environmental impact assessment (EIA) process is the systematic examination of consequences of a 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. This examination yields an EIA form/study that: - Documents the results of the process. - Analyzes potential environmental and social impacts of the project - Analyze the project alternatives - Incorporates the results of the public consultation process

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- Describes the needed environmental management plan (EMP)

Environmental impact assessment regulations: Article 19: Every natural or legal person, public or private, shall committed to presenting a study of Environmental Impact Assessment of the establishment or the project to the competent administrative body or the licensing authority before starting implementation thereof. The study shall be carried out in accordance with the elements, designs, specifications, bases and pollutants loads determined by Egyptian Environmental Affairs Agency EEAA in coordination with the competent administrative bodies. The competent administrative bodies should provide maps of industrial areas clarifying types of the industries allowed depending on environmental loads. The Executive Regulation of this law shall determine the establishments and projects to which provisions of this article shall apply.

Article 20: The competent administrative authority or the licensing body shall forward the above mentioned Environmental Impact Assessment studies to the Egyptian Environmental Affairs Agency EEAA for consideration. The EEAA may give the body preparing the study suggestions concerning preparations and systems necessary to treat the negative environmental effects and demand implementation thereof. The EEAA may also ask the body to provide all the data, designs or clarifications necessary for consideration of the study. The Egyptian Environmental Affairs Agency EEAA shall have to inform the competent administrative authority or the licensing authority with its consideration within a maximum of 30 days from the date of the receipt or completion of the study or execution of the proposals; otherwise, failing to reply shall mean that study is accepted by the Egyptian Environmental Affairs Agency EEAA. The project shall have to start operation within the period granted by the license; otherwise, the environmental approval shall be considered null and void.

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Article 21: The competent administrative authority shall notify the owner of the establishment of the result of the assessment by a registered letter with return receipt requested. The owner of the establishment may object to the result in writing within thirty days of notification before a committee to be formed by a decree of the Minister in charge of Environmental Affairs. The EEAA, the competent administrative authority or the licensing authority and the owner of the establishment shall be represented on the committee. The executive regulations shall determine the functions of the committee as well as its operating and complaint procedures.

Environmental impact assessment executive regulations: Articles 10,11,12,13,14,15,16 show details of administrative procedures for submitting EIA study. - Annex (2) illustrated establishments subject to the environmental impact assessment which are classified according to the following criteria: Type of activity, extent of depletion of natural resources, especially water, agricultural land and mineral wealth, location and type of energy used in operating the establishment. The obsolete pesticide management project can be classified under the "Type of activity" provision 8 which stated that any other establishment, activity or project liable to have a noticeable impact on the environment and for which a decree shall be issued by the EEAA with the agreement of the competent administrative body.

2.5. Hazardous Wastes Regulations: Article 29: It is forbidden to displace hazardous substances and waste without a license from the competent administrative authority. The executive regulations of this Law shall determine the procedures and conditions for granting such a license and the authority competent to issue same. The ministers shall, each in his field of competence, issue in coordination with the Minister of Health and EEAA a table of the hazardous substances and waste referred to in Para one of this article.

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Comment In this context Lindane is included in the ministry of agriculture lists (listA-2 banned chemicals and pesticide formulations used for agricultural pest control according to the Egyptian pesticide committee and international organizations decisions, October 1, 1995 & ministerial decree no. 55/1996). It was mentioned in this list that according to WHO classification Lindane is toxic & probable carcinogenic, moderately hazard and under the control standards of handling it is (banned), nothing is mentioned under means of disposal of empty packages.

Article 30: Management of hazardous waste shall be subject to the rules and procedures laid down in the executive regulations of this Law. The executive regulations shall designate the competent authority, which, after consulting EEAA, will issue the table of hazardous waste to which the provisions of this Law shall apply.

Article 31: It is forbidden to construct any establishment for the treatment of hazardous waste without a license issued by the competent administrative authority after consulting the EEAA. Disposal of hazardous waste shall be in accordance with the conditions and criteria set forth in the executive regulations of this Law. The Minister of Housing shall, after consulting with the Ministries of Health and Industry and the EEAA, designate the disposal sites and determine the conditions of the license to dispose of hazardous waste.

Article 32: It is forbidden to import hazardous waste or to allow its introduction into or its passage through Egyptian territories. It is forbidden without a permit from the competent authority to allow the passage of ships carrying hazardous waste in territorial seas or in the exclusive maritime economic zone of the ARE.

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Article 33: Those engaged in the production or circulation of hazardous materials, either in gas, liquid or solid form, are held to take all precautions to ensure that no environmental damage shall occur. The owner of an establishment whose activities produce hazardous waste pursuant to the provisions of this Law shall be held to keep a register of such waste indicating the method of disposing thereof, and the agencies contracted with to receive the hazardous waste. The executive regulations shall determine the data to be recorded in the said register and the EEAA shall be responsible for following up the register to ensure its conformity with the facts. The owner of or the person in charge of managing an establishment from which hazardous waste is produced, shall be committed to decontaminating the establishment, the soil and the place where it was set up, in case of moving the establishment or stopping its activity. Decontamination should be done according to standards and conditions provided in the executive regulation of this law.

Hazardous Wastes Executive Regulations Article (25) It is forbidden to displace and use hazardous substances and waste without a license from the competent administrative authority indicated for each as here in below: 1. Hazardous agricultural substances and wastes, including pesticides and fertilizers - Ministry of Agriculture. 2. Hazardous industrial substances and wastes - Ministry of Industry. 3. Hazardous pharmaceutical, hospital and laboratory substances and waste and domestic insecticides - Ministry of Health. 4. Hazardous petroleum substances and wastes - Ministry of Petroleum. 5. Hazardous substances and wastes from which ionizing radiation is emitted - Ministry of Electricity - Nuclear Energy Authority. 6. Hazardous substances and wastes which are flammable and explosive - Ministry of Interior.

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7. Hazardous substances and wastes used in the field of researches & practical studies – ministry of high education and ministry of state of scientific research. 8. Hazardous substances and wastes used in the field of laboratories & sewage treatment plants – ministry of housing utilities and urban communities. 9. Hazardous substances and wastes used in the field of laboratories & waterways cleaning works and herb resisting.

The ministers heading the ministries, each within his scope of competence and in coordination with the Minister of Health and the EEAA, issue a table of hazardous substances and wastes specifying the following: A. The types of hazardous substances and wastes falling within his ministry scope of competence and their respective degrees of danger for each. B. The constraints to be observed in the displacement of each. C. The means of disposing of the empty containers of such substances after their displacement. D. Any other constraints or conditions the minister deems important to add. E. The concerned authority in this regard within the ministry.

Article (26) The applicant for a license shall submit his application in writing to the competent authority as defined in Article (25) of these Executive Regulations in accordance with the following procedures and conditions:

Procedures for granting a license: The body or individual wishing to obtain a license for the displacement of hazardous substances or waste shall submit an application containing the following data: 1- Handler of hazardous substances and wastes: - Name of establishment - Address and telephone No. - Site and area of establishment

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- Contour maps of the site - Level of underground water - Safety equipment in the establishment - Information concerning insurance - Program for monitoring the environment in the area surrounding the establishment. 2- Producer of hazardous substances and wastes (full name, address, telephone and fax numbers). 3- A complete description of the hazardous substances and wastes intended to be handled and the nature and concentration of the hazard elements contained therein. 4-The amount of hazardous substances and wastes intended to be handled annually and a description of the method of packing to be used (barrels - tanks - bulk). 5-The means to be used in storing hazardous substances and wastes and the storage period for each, as well as an undertaking to place a clear written description on the container indicating its contents, the degree of danger thereof and how to act in an emergency. 6 - Clarification of available means of transport (by land - rail - sea - air - internal waterways), their routings and schedules. 7- A complete statement of the method intended to be used for the treatment and disposal of the hazardous substances and waste for the displacement of which a license is sought. 8- A commitment not to mix hazardous substances and waste with any other type of waste produced by social and production activities. 9- A commitment to keep registers containing detailed accounts of the sources, quantities and types of hazardous substances and waste, the rates and periods of their collection and storage and the means of their transport and treatment, to furnish such data on request, and not to destroy the registers for a period of five years running from the date they are first opened. 10- A commitment to take all procedures as are necessary to ensure the proper packing of hazardous substances and wastes during the collection, transportation and storage phases.

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11- A detailed description of the emergency plan for confronting all unforeseen circumstances which guarantees the protection of human beings and the environment. 12- A certificate of previous experience in the field of handling hazardous substances and waste. 13- A declaration of the veracity of data stated in such document.

Procedures for deciding on the request: 1-The competent ministry decides on the request in a period of time not more than 30 days from the date of receiving a request with the above data completed. 2-The competent ministry notify the person who submitted request with the result by a registered letter with return receipt requested. the person who submitted request may object to the result in writing within thirty days of notification in front a committee to be formed by a decree of the Minister in charge of Environmental Affairs, including Advisor of the Council of State as head of committee and delegate from the competent ministry and two experts are chosen for committee membership from outside ministry and representative from EEAA and it issue its decree with majority of members in 60 days.

Conditions for granting a license: 1- Completion of all required data. 2- Availability of personnel trained in the handling of hazardous substances and waste. 3- Availability of means, resources and systems required for the safe handling of these substances. 4- Availability of requirements to confront the risks which may result from accidents occurring during the handling of these substances. 5-That no harmful effects to the environment and public health shall result from the activity for which a license is sought.

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Article (27) The license to handle hazardous substances and waste shall be issued in consideration of a cash payment to be determined by a decree from the competent minister. The license shall be valid for a maximum period of five years subject to renewal. The licensing authority may revoke the license or suspend the activity by a reasoned decision in the following cases: 1- If the license was issued as a result (of the submission) of incorrect data. 2- If the license violates the conditions of the license. 3- If the performance of the activity results in dangerous environmental effects which were unforeseen at the time the license was issued. 4- The emergence of sophisticated technology which may, with minor modifications, be applied, and the use of which would lead to a marked improvement in the environment and the health of the workers. 5- If the EEAA concludes that it is unsafe to handle any of the substances and wastes. The licensing authority in coordination with the EEAA and the Ministry of Health may request the applicant to fulfill such other conditions as it deems necessary to ensure the safe handling of these substances,. In all cases, the applicant for a license may not handle hazardous substances and waste before obtaining the license made out on the relevant form which must be kept by the person in charge of the handling to be presented on request.

Article (28) The management of hazardous wastes shall be subject to the following rules and procedures:

First: Engendering Hazardous Waste: The establishment which engenders hazardous waste shall be held to do the following: 1-Try hard to reduce the rate at which such waste is produced, both quantitatively and qualitatively, by developing the technology used, employing clean technology and

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selecting alternatives for the primary product or the raw material which are less harmful to the environment and public health. 2- Categorize the waste produced, in terms of both quantity and quality, and register it. 3- Establish and operate units to treat waste at source, provided the EEAA approves the treatment system as well as the technical specifications of these units and their operational program. In case of difficulty of treatment or disposal of hazardous waste at source, the establishment producing such waste shall be held to collect and transport it to the disposal sites determined by the local authorities and the competent administrative and environmental bodies. The displacement of such waste shall be subject to all the conditions and provisions prescribed in this respect by these Executive Regulations.

Second: Stage of Collecting and Storing Hazardous Waste: 1-Determine specific locations for the storage of hazardous waste meeting safety conditions to prevent the occurrence of any harm to the public or to those persons exposed to such waste. 2-Store hazardous waste in special containers made of a solid, non-porous, leak-proof material. These containers are to be hermetically sealed and their capacity must be commensurate with the quantity of hazardous waste stored therein or conform to the standards set for the storage of such waste according to type. 3-A clear sign should be placed on the hazardous waste containers to indicate their contents and warning of the dangers which may result from handling them improperly. 4-Lay down a schedule for the collection of hazardous waste so that it is not left for long periods in the storage containers. 5-Producers of hazardous waste shall be held to provide the above-mentioned containers, wash them after each use and not place them in public places.

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Third: Stage of Transporting Hazardous Waste: 1- It is prohibited to transport hazardous waste by other than the means of transport run by the establishments licensed to manage hazardous waste. Those means of transport must meet the following conditions: A-Transport trucks shall be fitted with all safety equipment and shall be in good working condition. B-The capacity of such trucks and their shift schedule shall be commensurate with the quantities of hazardous waste. C-They shall be driven by trained drivers capable of taking independent initiatives, particularly in emergencies. D-They shall bear clear signs indicating the dangerous nature of their cargo and the best manner of dealing with emergencies.

2- Routing of trucks transporting hazardous waste shall be determined and civil defense bodies shall be immediately notified of any changes therein, so as to enable them to act rapidly and decisively in emergencies.

3-Trucks transporting hazardous waste shall be prohibited from passing through residential and other populated areas and through the city Centre during daytime.

4-The address of the garages where hazardous waste trucks are parked, as well as the number and date of their license, must be notified to the competent authority.

5-Trucks transporting hazardous waste must be washed and sterilized after each use in accordance with the directives issued by the Ministry of Health in coordination with the competent administrative body designated in Article (40) of these Executive Regulations.

6- for the permission the passage of ships carrying hazardous waste the following should be followed:

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A-Prior notification is a requisite according to Basel convention and the competent administrative body should permit if there is a potential risk of environmental pollution.

B-In case of permission, all necessary precautions as prescribed in international conventions must be taken, and the ship must have the guarantee certificate referred to in Law No. 4 of 1994.

Fourth: Stage of Treatment and Disposal of Hazardous Waste:

1-The sites selected to house utilities for the treatment and disposal of hazardous waste shall lie at a distance of at least three kilometers from populated and residential areas, and shall be held to meet the conditions and provide the equipment and installations set forth below:

A-The area of the site must be proportionate to the quantity of hazardous waste so that such waste does not remain in storage for extended periods. B-The site shall be encircled with a brick wall standing at least 2.5 meters high. C-The site shall be provided with more than one gate of suitable width, allowing the easy entry of trucks transporting hazardous waste. D-The site shall be provided with a water source and W.C. facilities. E-The site shall be provided with all the protection and safety requirements prescribed in labor and vocational health laws, as well as with a telephone line. F-The site shall be provided with all the mechanical equipment which can facilitate the work process. G-The site shall be provided with warehouses equipped to preserve hazardous waste pending its treatment and disposal. Equipment shall differ according to the type of hazardous waste received by each utility.

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H-The utility shall be provided with an incinerator for burning certain type of hazardous waste. I-The utility shall be provided with the necessary equipment and installations for sorting and classifying certain types of hazardous waste with the intention of reutilizing and recycling them. J-The site shall have a sanitary ditch of an adequate capacity for burying the incinerated remains. 2-Processes for the treatment of hazardous waste which may be reused and recycled shall be carried out within the following framework: 1- Reutilization of some hazardous waste as fuel to generate energy. 2- Recovery of organic solvents and their reutilization in extraction processes. 3- Recycling and reusing some organic substances from hazardous waste. 4- Reusing ferrous and non-ferrous metals and their compounds. 5-Recycling and reusing certain non-organic substances from hazardous waste. 6- Recovery and recycling of acids or alkaline. 7-Recovery of substances used in reducing pollution. 8- Recovery of certain components of ancillary elements. 9- Recovery of used oil and reutilizing it after its refinement, with due consideration to the relationship between environmental and economic returns.

3-Processes for the treatment of hazardous waste which cannot be reutilized and recycled shall be carried out within the following framework:

A- Injecting hazardous waste amenable to pumping into salt mines, wells and natural reservoirs in areas far from residential and populated areas.

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B-Burying hazardous waste in pits specially prepared for this purpose and isolated from the other components of the environmental system. C- Treating hazardous waste biologically by using certain types of living micro-organisms to bring about its decomposition. D-Treating hazardous waste physically or chemically by evaporation, dilution, calcification, assimilation, sedimentation, etc. E-Incineration in special incinerators designed to prevent the emission of gases and fumes into the surrounding environment. F- Permanent storage (such as placing hazardous waste containers inside a mine). 4-Taking all procedures which guarantee abatement and reducing the production of hazardous waste through:

A- Developing and generalizing the use of clean technology. B- Developing suitable systems for the management of hazardous waste. C- Expanding the reutilization and recycling of hazardous waste after treatment whenever possible.

5-Setting a periodic monitoring program for various environmental system components (biotic & abiotic) in the sites of treatment & disposal facilities and their surroundings. Licenses shall be withdrawn and work in the utility suspended upon the appearance of any indications of damage to the eco-systems surrounding the facility.

6-Establishments licensed to handle and manage hazardous substances and waste shall be responsible for any damage caused to third parties as a result of non- compliance with the provisions of these Executive Regulations.

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The EEAA shall be competent to review the hazardous waste schedules, which are subject to the provisions of the Law, with the cooperation of the ministries concerned in regard to the schedules issued by them in this subject.

Article (29) It is prohibited to construct any establishment for the purpose of treating hazardous waste except with a license issued by the competent governorate after consulting the EEAA, the Ministry of Health, the Ministry of Labor and Manpower, and the ministry concerned with the type of waste according to the provisions of Article (25) of these Executive Regulations, after ensuring that such establishment satisfies all the conditions which guarantee the safety of the environment and the staff employed thereat. Disposal of hazardous waste shall be effected in accordance with the conditions and criteria prescribed in Article (28) of these Executive Regulations.

The Minister of Housing, after consulting the ministries of Health and Industry and the EEAA, shall determine the locations and conditions for the disposal of hazardous waste.

Article (30) It is prohibited to import hazardous waste or to allow its entry into or passage through the territory of the Arab Republic of Egypt. It is prohibited, without a license from the competent administrative department in the Ministry of Maritime Transport or in the Suez Canal Authority, each within the scope of its competence, to allow the passage of ships carrying hazardous waste, in the Territorial Sea or the Exclusive Economic Zone of the Arab Republic of Egypt, provided the EEAA is notified withal.

Article (31) Those in charge of the production or displacement of hazardous substances, whether in their gaseous, liquid or solid states, shall take all due precautions to ensure the non

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occurrence of any environmental damage, and shall be held in particular to observe the following: (A) That the site on which such substances are to be produced or stored is selected with due regard to the conditions prescribed according to the type and quantity of those substances.

(B) That the design of the buildings inside which hazardous substances are to be produced or stored conforms to the engineering standards to be observed for each type of such substances, as determined by a decree to be issued by the Minister of Housing after consulting the EEAA. The said buildings shall be subject to periodic inspections by the licensing administrative body.

(C) That the conditions prescribed in respect of the means of transport or the storage sites of such substances are provided so as to guarantee that no harm shall come to the environment or to the health of employees or citizens.

(D) That the technology and equipment used in the production of such substances shall not result in damage to the establishment, the environment or harm to the staff.

(E) That buildings shall be adequately fitted out with safety, alarm, protection, combat, fire-fighting and first aid systems and equipment, in the numbers and quantities determined by the Minister of Labor and Manpower after consulting the EEAA, the Ministry of Health and the Civil Defense Department in coordination with the competent administrative authority.

(F) That an emergency plan is in place to confront any potential accidents which may occur during the production, storage, transportation or handling of such substances, provided the plan is reviewed and approved by the licensing authority after consulting the EEAA and the Civil Defense Department.

(G) That staff in these establishments are subjected to periodic medical checkups and that they are treated for any vocational diseases at the expense of the establishment by which they are employed.

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(H) That establishments producing hazardous substances insure their workers for the amounts to be determined by a decree from the Minister of Manpower in coordination with the Ministry of Insurance and Social Affairs, after consulting the EEAA and the Ministry of Health, provided the amounts of the insurance take into account the degree of danger to which each category of workers is exposed inside each productive unit.

(I) That workers handling such substances are informed of the dangers involved and of the necessary precautions to be taken when handling them, that they are fully aware of all this information and that they have received adequate training in this regard.

(J) That the inhabitants of the regions surrounding the sites where hazardous substances are produced or handled are informed of the possible dangers of these substances and the method of facing such dangers, and that they are familiar with the alarm systems to be used in case of an accident and with the procedures to be followed on its occurrence.

(K) Establishments producing and handling hazardous substances are held to compensate citizens injured in the locations surrounding the production or storage sites for injuries caused by accidents resulting from these activities or from harmful emissions or leakages wherefrom. Those assigned to the production and handling of hazardous substances shall submit an annual report on the extent of their commitment in implementing the necessary precautions.

Article (32) Establishments engaged in the production or importation of hazardous substances shall, when producing or importing such substances, observe the following conditions: Firstly: Container specifications: (A) The type of container in which these substances are placed must be suitable for the type of substance therein, tightly closed and difficult to damage.

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(B) The capacity of the container must be easy to lift or transportation without exposing it to damage or harm. (C) The inner lining of the container must be made of a material that is not affected by storage throughout the period when the substances contained therein are active. Secondly: Container information: (A) Contents of container, their active substance, and the degree of its concentration. (B) Total and net weight. (C) Name of producer, date of production and production number. (D) Nature of danger and symptoms of toxicity. (E) First aid procedures to be taken in case of exposure. (F) Safe method of opening, emptying and using container. (G) Safe storage method. (H) Methods of disposal of empty containers. All the information shall be written in Arabic in a style that is easy for an ordinary person to read and understand, and the words must be legible and prominently displayed on the container. They must be accompanied by diagrams indicating the method of opening, emptying, storing and disposing of the containers as well as by the international symbols for danger and toxicity.

Article (33) The owner of an establishment whose activity results in hazardous waste pursuant to the provisions of these Executive Regulations shall be held to keep a register of such waste and the method of its disposal, as well as of the names of the parties contracted with to receive the said waste, as follows: 1) Name and address of the establishment. 2) Name and job title of the person responsible for filling in the register. 3) The period covered by the current data. 4) The special conditions issued for the establishment by the EEAA. 5) A list of the types and quantities of hazardous waste resulting from the establishment activity.

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6) Method of disposal thereof. 7) The parties contracted with to receive the hazardous waste. 8) Date on which the form is filled. 9) Signature of the officer in charge. The EEAA shall follow up the information in the register to ensure its conformity with reality.

2.6.Pesticides use &handling Article 38: It is prohibited to spray or use pesticides or any other chemical compound for agriculture, public health or other purpose except after observing the conditions, regulations and safety measures laid down in the executive regulations of this Law and in a manner that will not expose humans, animals, plants, waterways and other components of the environment, directly or indirectly, now or in future, to the harmful effects of such pesticides or chemical compounds.

2.7.Law 48/1982 Regulations Article no.10 When ministry of agriculture chooses or uses any types of chemicals & pesticides for pest control they should take precautions not to pollute waterways by the drainage of these chemicals or pesticides either directly during spraying process or mixed with agricultural drain water or by washing spray equipments or containers in the waterways according to agreement between agriculture, health and irrigation ministries 2.8.Law 48/1982 amended executive regulations with decree 92/2013 Article no.4 It is not allowed to transport any hazardous, toxic or radioactive substances across water ways according to the table prepared by ministry of health.

From the Ministry of Health table the following part can be applied in this case (obsolete lindane)

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Substance Hazardous Notices

Groups mentioned in Minister of Agriculture All types of pesticides and decree no.874/1996 (Annex active ingredients which Toxic & harmful for aquatic 2), Minister of Health used in synthesis of environment decree no.55/1996 and pesticides. ministerial decree no.630/2007 Forbidden substances as (DDT, Chlordane, Heptachlor, …etc) or All persistent organic Toxic & harmful for aquatic substances that EEAA and pollutants (POPs) environment ministry of health issued rules regarding it like (PCDD,PCDF, PCBs)

Includes hazardous wastes which stated in law 4/1994 and its executive regulations All types of hazardous Toxic, infected, flammable in addition to lists issued by wastes or oxidizing competent ministries like: agriculture, health, electricity,…

2.9. Agricultural Laws & Ministerial Decrees: Legislation and decrees that control pesticides

Pesticides registration Central agricultural pesticides laboratory The international organizations such as the world health organization (WHO) and the Food and Agricultural Organization (FAO) have been established many guidelines to help countries to improve the process of pesticides management. FAO in its "guideline for legislation on the control of pesticides" stated that 'All countries in which

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pesticides are used should have an effective pesticide registration and control scheme in operation. Such a scheme can assist in ensuring that pesticide use does not result in unreasonable risk to man, livestock and the environment.' Although, the guidelines explain the principle of pesticides management, they left wide space for each country to develop its own system.  The Agricultural Law promulgated by Law No. 53 of 1966.  The Environment Law promulgated by Law No. 4 of 1994 and its Executive Regulations.  Ministerial decree no.90 of 2007 (Annex 3) concerning the criteria for the registration, renewal of registration, and use of agricultural pesticides in the Arab Republic of Egypt.  Ministerial decree no. 630 of 2007 (Annex 4) concerning the lists of agricultural pesticide active ingredients that can be registered, re-registered, or banned inthe Arab Republic of Egypt.

2.10. Ministry of Manpower Law Law 48/1967Requires employers to inform their employees that they are dealing with hazardous waste. Law 137/1981Requirements for labor safety and health in workplaces 2.11. Regional Conventions Bamako convention on the ban of the import into Africa and the control of transboundary 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.

2.12. International Conventions 2.12.1 Stockholm Convention on Persistent Organic Pollutants (Stockholm, 2001) was signed by Egypt in 17/5/2002 and ratified in 2/5/2003. The overall objective of the Convention is to protect human health and the environment from POPs that remain intact in the environment for long periods, become widely distributed geographically, accumulate in the fatty tissue of living organisms and are toxic for humans and wildlife.

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The National Implementation Plan (NIP) for fulfilling the requirement of Stockholm Convention was prepared within the framework of the project enabling activities of early action in the implementation of Stockholm Convention on POPs under GEEf project GEF/EGY/02/22. UNIDO has been designated by the council of the global environmental facility (GEf) as one of executing agencies with expanded opportunities & has been executing the project to help in the enabling activities leading to country’s NIP.

The project GEF/EGY/02/22 was approved in October 2002, EEAA was given the National Lead Agency role a national coordination point (Dr. Tarek Eid Mohamed) was appointed to take care of the implementation of the project, under him a national project coordination unit (NPCU) with full compliment of staff (9), office facilities were established at the Ministry of State of Environmental affairs.

At its fourth meeting held from 4 to 8 May 2009, the Conference of the Parties adopted amendments to Annexes A, B and C to the Stockholm Convention to list nine new persistent organic pollutants (SC-4/10-SC-4/18). Pursuant to paragraph 4 of Article 21 of the Convention, the amendments were communicated by the depositary to all Parties on 26 August 2009. Reference: C.N.524.2009.TREATIES-4. Lindane was added as pesticides from these nine new POPs, it was listed in Annex A

2.12.2 Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (Basel, 1989) was ratified by Egypt in8/1/1993. The goal of the Convention is “environmentally sound management”, the aim of which is to protect human health and the environment by minimizing hazardous waste production whenever possible. Environmentally sound management involves strong controls from the generation of a hazardous waste to its storage, transport, treatment, reuse, recycling, recovery and final disposal.

Amendment to the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal was ratified by Egypt in13/12/2003.

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2.12.3 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) The objective of this agreement is to promote shared responsibility and cooperative efforts between exporting and importing countries for managing chemicals that pose significant risks in order to protect human health and the environment. It also seeks to encourage the environmentally sound management of these chemicals when their use is permitted and to provide and share accurate information on their characteristics, potential dangers, and safe handling and use. The key to the Convention is Prior Informed Consent (PIC), If a member country – generally referred to as a State party – decides not to import a particular chemical or pesticide covered by the PIC procedure, other State parties agree not to export this product to that country. If a country decides to limit the import of a chemical to certain uses, exporting countries agree to respect those limits. Prior Informed Consent promises not only to reduce accidents but also to prevent the accumulation of stocks of obsolete or unwanted pesticides.

Five industrial chemicals and 22 pesticides were included on the initial list of chemicals covered by the PIC procedure when the Rotterdam Convention was adopted; others have already been added, lindane is on the list.

The Convention is one of a series of agreements focusing on chemical safety and is sometimes referred to as a "first line of defense" because it seeks to prevent problems from happening in the first place. Among its companion treaties, the Stockholm Convention is aimed at halting the use of hazardous persistent organic pollutants (POPs) and at coping with their widespread presence in the environment. The Basel Convention targets international trade and the effective management and cleanup of hazardous wastes.

The Rotterdam Convention assists Parties to reduce risks from certain hazardous pesticides in international trade. The Convention, together with the Stockholm and

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Basel conventions and FAO’s voluntary Code of Conduct, promotes a life cycle approach and provides the necessary tools for managing pesticides.

2.13. Determine the policy, legal, and administrative requirements in Egypt; Environmental policy Egyptian environmental policy the strategic objective is to introduce and integrate environmental concerns relevant to protecting human health & managing natural resources into all national policies, plans, programs & projects of the national development plans. The medium term objective is to preserve natural resources, biological diversity, and national heritage with in a context of sustainable development. The short term objective is to reduce current pollution levels, minimize health hazards, and to improve quality of life for citizens & residents of Egypt.

2.14.Strategy and action plan elements of the NIP Policy statement The policy behind Egypt's NIP is to identify and mitigate hazards of chemicals including pops with purpose of protecting the Egyptian environment and human health from risks of these hazardous substances, whether imported or generated locally.

2.15. World Bank Safeguard Policies The World Bank’s commitments to environmental and social protection are reflected in its safeguard policies. The objectives of these policies are to help ensure the environmental and social soundness and sustainability of investment projects to support integration of environmental and social aspects of projects into the decision- making process. Each Bank-supported project is assessed to identify which of these safeguards must be triggered and complied with. The safeguard policies relevant to this project are outlined in the following table.

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Bank Policy Summary of Core Requirements OP 4.00 4.01.Environmental  Screen early for potential impacts and select Assessment appropriate instrument to assess, minimize, and mitigate potentially adverse impacts

4.09.Pest Management  Support integrated approaches to pest management. Identify pesticides that may be financed under the project and develop appropriate pest management plan to address risks.

Safeguards Diagnostic Review: EXECUTIVE SUMMARY

I. In December 2005, the World Bank prepared a Safeguards Diagnostic Review (SDR) for the Use of Country Systems (UCS) in the Egypt Pollution Abatement Project II (EPAP II, EG 33433). Since then, the UCS was implemented in a satisfactory manner, although some actions were delayed in the implementation of some of the gap-filling measures that were identified and agreed upon between the World Bank and the Government of Egypt. The EPAP II is yet to be completed in August 31, 2013 and all of the agreed upon gap-filling measures are very likely to be met and further included in the Egypt Environmental Impact Assessment system.

II. As the use of the country system was applied in EPAP II to address hazardous and non-hazardous emissions from public and private sector entities, the POPs management project will address primarily the hazardous waste which is one of the sources of pollution and both hazardous emissions and waste are affecting public health. It will be therefore appropriate to subject the POPs management project to the same national system as both projects are financed by the World Bank and GEF with the same ministry. In this regards, EPAP II and POPs will mutually reinforce the use of the National EIA system in the World Bank and GEF- financed projects and will strengthen the Government of Egypt's institutional capacity to deal with hazardous and non- hazardous pollution using the national system supplemented by the gaps filling measures identified in this SDR.

iii. This operation will therefore be governed by OP 4.00 on "Piloting the Use of Borrower Systems to Address Environmental and Social Safeguard Issues in Bank-Supported Projects". Therefore, in accordance with this Policy, the World Bank staff, in collaboration with EEAA staff, carried out equivalence and acceptability assessments of applicable Egyptian environmental systems, between September 2010 and May 2012. In doing so, they included all the findings and recommendations of the SDR prepared for the purpose of the EPAP II, including review of the implementation of the agreed upon gap-filling measures.

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iv. The Project Development Objective (PDO) would be to assist Egypt to strengthen its technical and management capacity for minimizing exposure to POPs. The Project consists of four components : a) Component 1: Institutional and Regulatory Strengthening Measures for POPs Management ($4.0 million, including GEF $1.2 million) 1.1 Policy and Legal Framework for POPs Management 1.2 Institutional Strengthening 1.3 Enhancement of National Capacity 1.4 Enabling Activities for Unintentional POPs.

b) Component 2: Management of Obsolete Pesticide Stocks ($ 8.6million, including GEF $ 2.1 million) 2.1 Secure Storage of Pesticides. 2.2 Destruction of High-Risk Stocks 2.3 Development of a Long-term Pesticides Management Strategy c) Component 3: Management of PCBs ($ 9.lmillion, including GEF $ 4.0 million) 3.1. Safeguarding Stocks and Off-Line Equipment 3.2 Decontamination of Medium /Low Risk Contaminated Stocks and Equipment d) Component 4: Project Management ($ 1.9 million, including GEF $ 0.8 million) 4.1 Project Management Unit 4.2 Monitoring and Evaluation (M&E)

v. The total project cost is US$ 23.6 million of which US$ 8.1 million is a GEF Grant and US$ 15.5 million is the in-cash and in-kind contribution of the Government of Egypt.

vi. The proposed POPs Project triggers two environmental safeguards policies: (i) Environmental Assessment, and (ii) Pest Management. The results of the equivalence assessment showed that the World Bank's EA policy and the Egyptian safeguards systems on EA and Pest Management, as amended through 2009, are nearly fully equivalent. The major gaps are to issue a regulation clarifying that all POPs sub-projects will be subjected to an EIA and prepare TORs or specific guidelines for such EIA. Also, the legal and regulatory framework should be brought into full consistency with the Stockholm Convention and other conventions applicable to POPs and to which Egypt is a party. These gaps can be implemented as part of overall Project implementation.

vii. The acceptability assessment shows that significant progress has been made in strengthening the institutional framework related to the EIA process and to monitoring and enforcement. Since the last SDR of EPAP II, EEAA has reorganized and established two additional central departments namely the Central Department for Environmental Inspection & Environmental Compliance "CDEIEC" consisting of a general directorate for compliance and a general directorate for inspection; and the Central Department for the Protection and Improvement Industrial Environmental and Energy. Both departments are fully functional.

viii. About 12 ministries and agencies will be associated with the POPs projects and all of them have expertise and staff in the fields related to hazardous waste. The new EIA guidelines of 2009 which now require public hearings and

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consultation for the projects classified as "C" (equivalent to category "A" of the World Bank) have provided a more prominent and participatory role for civil society. As a result, civil society has been increasingly involved in project implementation, in public debate and also in ensuring compliance with the environmental laws and increasingly vocal whenever public hearings/consultations on EIA has taken place. Similarly the media have contributed largely to this increased awareness and publish regularly the summary description of projects for which an EIA was approved by EEAA. There are also six NGOs which are working on raising awareness on health impacts and proper handling of pesticides and PCBs.

ix. A review of a sample of EIA reports for projects financed by the Government and/or by International Financial Institutions showed a significant improvement in quality and comprehensiveness. The quality of projects in the category "B" (equivalent to Category "B" of the World Bank) for which a Form B should be submitted is however variable and does not include in many cases the preparation of a comprehensive environment management plan as required by the environmental guidelines of2009. Disclosure of the executive summary of the EIA reports and of Forms B (with the exception of the EPAP II subprojects) is still lagging because of lack of resources, staff and inherent reluctance to disclose reports which may raise controversial discussions.

x. An additional monitoring instrument that was institutionalized by EEAA is the preparation of a compliance action plan whenever a polluting enterprise is not in compliance with the national standards but agreed to self-finance its pollution control investments instead of being prosecuted. This led to the establishment by EEAA of a general directorate for voluntary compliance which is assisted by the general directorate for industrial environment.

xi. Despite such progress, there are still some weaknesses in the EIA system and in EEAA's monitoring and enforcement. These are: (a) lack of knowledge related to POPs and PCBs and technologies for their management and disposal, (b) limited staff resources in the department of hazardous waste management, (c) limited inter-ministerial cooperation on hazardous waste management, (d) insufficient public communication and awareness raising on hazardous waste and in particular with POPs, and (e) lack of monitoring and enforcement for obsolete pesticides and PCBs .These weaknesses will be addressed in the components of the POPs project.

xii. A preliminary hazardous waste and risk assessment was also conducted during project preparation in anticipation that two potential Intermediate Collection Centers for obsolete pesticides in the Nasiriya Hazardous Waste Center in the Alexandria Governorate and the ElSaff Storage Site of Obsolete Pesticides in the Guizeh Governorate could be used. The revised design of the project will provide the international operators for collection, transport and disposal of POPs, with the choice to select the appropriate methods and technology and sites, which may not involve the use of these two facilities. However, for any sites selected by the international operators, a comprehensive An ESIA, including an in-depth risk assessment, will be conducted during project implementation xiii. The actions summarized in the following table will be implemented by EEAA to fill in the equivalence and acceptability gaps and sustain acceptability during the implementation of the POPs Project. The proposed timing of implementation for each of the following measures were made in accordance with the project implementation schedule.

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Safeguards Gap-Filling Measures Gaps Actions to be taken Implementation Steps By Whom By When 1. Include in the Project Description in the Operational Manual Operational Manual of the adscription of the roles and responsibilities of the PMU, the two PCUs, roles, responsibilities Environmental Management PMU Director/ coordinating April 2013 Weak Department, CDEIEC and Consultant mechanism, others related to the EIA coordination monitoring and process and the compliance among EEAA follow up for / inspection of Obsolete departments establishing an inter- Pesticides and PCBs involved in sectoral system within EEAA for POPs Official decree issued by coordinating the EIA EEAA on the roles, PMU Director June 2013 process with the responsibilities and compliance/inspectin coordination mechanisms CEO of EEAA process.

Prepare TORs for a comprehensive study to Insufficient 2. Complete the legal harmonize existing POPs and regulatory frame related legislation with Compliance May 2013 with the work for POPs requirements of the Stockholm Convention as requirements management in PMU Director compliance with the described in Annex 15 to of the this SDR Stockholm Stockholm  Contract a legal consultant Convention Convention  Draft legal regulations for December submissions to the Legal 2014 Council of the Government 3. Develop general EIA Review good international procedural guidelines Practices including FAO and PMU June 2013 to include: (a) specific WHO Adapt sector guidelines to criteria, processes Egyptian conditions on and standards to be pesticides, obsolete PMU July 2013 followed in the pesticides and PCB preparation and contaminated equipment Lack of review of EIA for Prepare TORs for POPs and EIA Department October procedural POPs sub projects (b) checklist for reviewing EIA in EEAA 2013 guidelines for detailed TOR for a reports in general POPs projects comprehensive EIA report for POPs including hazardous Approve and publish the risk assessment and guidelines, TORs and EEAA Board of September (c) guidelines for checklist on the website of Directors 2013 environmental EEAA reviewers

Design training program and October 4. Develop and provide PMU develop training materials 2013 Insufficient training to the EEAA Organize and conduct knowledge on staff, RBOs, sector training on TOR and PCB and POPs ministries and NGO’s monitoring and enforcement Bi annually and contract on the use and for EEAA staff and RBO and PMU as of March management applications of (a)the in particular the staff that 2014 specific guidelines will be assigned to monitor the EMSP and Forms.

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and EIA TORs for EEAA Organize and conduct public POPs including PCBs; Department awareness campaigns in Annually as of Hazardous (b)self-monitoring collaboration with local of June 2014 Waste and inspection of NGOs involved in the POPs POPs sires including Management PCB-contaminated sites. Organize awareness campaigns with local NGOs targeting the public Organize and conduct and particularly the training on contract Youth Develop and management and award as PMU January 2014 provide training to well as monitoring and supervision of contracts PMU on monitoring and supervision of contracts of PCBs operators

5. Ensure that existing Update the content of the environmental register by obsolete pesticides PMU April 2014 including questions on OPs and PCB and PCBs contaminated sites maintain an environment Weak register to be Conduct semiannual enforcement inspections based on the EIA July 2014 inspected annually and the environmental for PCBs and by CDEIEC using the register for the major RBO and GDEI semiannually collection center sites for format in Annex 3 of thereafter the Executive which EIAs and Form B were prepared Regulations of Law 9 of 2009

6. Carry out every two TORs for the review of the years, a review of EIA reports prepared and PMU May 2014 consultant selected Lack of the quality of EIA assessment of reports and Forms B the quality of and introduce July 2014 Report on the quality of the the ESIA corrective measures PMU and January EIA reports and Form B reports for sustaining the 2016 improved EIA process

xiv. EEAA will be responsible for the following actions: (a) Satisfactory implementation of gap filling actions set out above to achieve and sustain equivalency and acceptability; (b) Review and approval of the EIA reports related to the intermediate collection centers and Form B for site specific areas for treatment and disposal of obsolete pesticides and PCBs; (c) Disclosure of the EIA reports related to hazardous waste projects particularly those related to obsolete pesticides and PCBs in accordance with the EIA guidelines of 2009; and (d) Performance of annual spot checks and audits of a sample of subproject sites financed the POPs project for their compliance with the relevant

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Egyptian Laws and Regulations, and imposition of corrective actions to achieve compliance.

xv. The World Bank will be responsible for the following actions:

(a) Monitor the implementation of the gap filling measures that are applicable to the types of subprojects financed under the POPs project; (b) Review during the course of semi-annual supervisions the EIA reports and form B related to obsolete pesticides and PCBs; (c) Review the reports on inspection or compliance for all the subprojects to be financed by the Project; and (d) Bi-annual supervision of project implementation, including field visits to subprojects under implementation or commissioning or those completed.

xvi. A public consultation meeting was held on June 13, 2012 and attended by 64 representatives from ministries (Environment, Electricity and Energy, Industry, Planning and International Cooperation), research institutes and universities, 3 media representatives as well 16 NGOs. The workshop was conducted in Arabic. The meeting was chaired by the acting Chief Executive Officer of the Egyptian Environment Affairs Agency (EEAA); a list of the issues raised and comments made by the attendees and reviewers, and remarks/responses to these comments in included as in Section XI to the SDR report.

2.16. Regulations and Ambient Standards/guidelines (air, water, land) governing environmental quality, industrial discharges, health and safety

National Standards Law 4/1994 amended by law 9/2009 is enforced by EEAA Ambient: no standards for ambient water Effluents Occupational Threshold limits of lindane in work place (average concentration in 8 hours) 0.5 mg/m3 (+ skin m2*). * +skin: when absorbing through skin is a factor in increasing exposure, m2: suspected carcinogenic for human.

Law 48/1982 Regarding the protection of the River Nile and Waterways from pollution Ministry of Public Works and Water Resources Ambient: some pesticides are included but lindane is not included

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Effluents of lindane is not included International Standards Toxicological Characteristics WHO a. i. Class II (moderately hazardous) IARC Group 2B (possible carcinogen but inadequate evidence in humans) EU Toxic, irritant

Acute Toxicity Oral LD50 rats 90-270 mg/kg; mice: 55-250 mg/kg; rabbit: 90-200 mg/kg (WHO, 1992) Dermal LD50 rat: 900-1000 mg/kg, rabbit: 200-300 mg/kg (WHO,1992) Inhalation Rat LC50 1500 mg/m3/4 hrs (WHO, 1992) Irritation Eye irritation depends on the inert ingredients more than the active ingredient; lindane is not a primary dermal irritant; negative in the dermal sensitization test.

Administrative bodies/agencies responsible for implementing the regulations, monitoring compliance and enforcement

Egyptian Environmental Affairs Agency （ EEAA ） Reviewing EIAs, Environmental inspection to establishments and notifying MWRI on violation to law 48/1982.

Ministry of Water Resources and Irrigation (MWRI)

Ministry of Health and Population (MoHP)

Ministry of Agricultural and Land Reclamation (MALR)

Central agricultural pesticides laboratory(CAPL)

The Egyptian Agricultural Pesticide Committee (APC-Egypt) APC is the Egyptian governance accountable for the assessment, evaluation and registration of agricultural pesticides, and for their regulation up to and

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including the point of retail sale. It is the highest Government Statutory authority responsible for registering agricultural pesticides based on two major criteria: first to be highly effective against agricultural pests; and second to be highly safe to the public health and the environment. APC is responsible for tailoring, administering and managing the National Registration Scheme and Decrees for agricultural pesticides, which sets out the regulatory framework for the management of pesticides production, import, export and use in Egypt. It administers the legislation scheme in partnership with state and territory governments and with the active involvement of other Egyptian government agencies. Also APC serves as a national focal point that cooperates with international pesticide regulatory authorities for effective use and global safety of plant protection products throughout their life cycles.

Gaps between Egyptian regulations and international regulations as identified in SDR of POPs Project The gaps between Egyptian regulations and international regulations are summarized in Annex 5 It includes the relevant conventions and the World Bank Safeguard Policies. Annex 6 summarizes the proposed gap filling measures, which have been identified in Safeguards Diagnostic Review (SDR) for piloting the use of Egyptian systems to address environmental issues in the proposed GEF-Financed Egypt Sustainable Persistent Organic Pollutants (POPs) Management Project (P116230).

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CHAPTER III DESCRIPTION OF THE PROPOSED PROJECT

3.1. SITE DESCRIPTION The Al Adabeya port storage facility in Egypt was built in 1975 and dedicated for the storage of dry bulk. It is situated about 125 km east of Cairo easily reachable by good condition highway, the nearest larger city is Suez city in Suez governorate (17 km to the North) (Figs. 3.1, 3.2 &3.3). The storage is an open yard designed for temporary storage of shipped goods. The yard has two gates one of them (at the NE corner of the yard) is the emergency gate.

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Figure 3.1: A satellite image for Al Adabeya Port

It is estimated that about 220 tons of obsolete and POPs pesticides, including lindane, has been stored at the Al Adabeya Port since 1998. These obsolete stockpiles are packed in 25 kg heavy paper bags supported by a plastic outer wrapping and stored in 10 standard 20 feet containers occupying an area of 5,850 square meters (225 x 26 m).

Figure 3.2: Rectified satellite image for Al-Adabya Port

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It is understood that the obsolete and POPs pesticides may be stored in a substandard way and limit there may be possibility of emissions as a result of high ambient temperatures; however there are no environmental records. The proposed project involves the handling, packaging, transporting and disposal of these hazardous stockpiled pesticides, as well as the remediation of any site contamination, if required.

Figure 3.3: Full scale GIS layout of AlAdabya Port

3.2. Project Objectives

The scope of the cleanup and disposal activities component of the project involves the environmentally sound disposal of the existing stocks of obsolete pesticides including contaminated containers, and assess the possibility of disposal of contaminated soils, if any.

There is need to undertake an ESIA with a detailed and comprehensive ESMP which assesses the diverse set of factors and risks impacting the project, and which will allow

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the Government of Egypt to make objective decisions on how to address the risks and implement the project in a safe and environmentally sound manner.

In particular, the ESIA will focus on the assessment of environmental and social impacts that will arise from the repackaging, domestic transport, temporary storage, loading and unloading, transboundary transportation including shipping, and overseas disposal of the hazardous waste.

An Environment and Social Management Plan (ESMP) based on the ESIA will be prepared to address these risks and provide the detailed mitigatory measures and methodology for undertaking the project activities. The ESMP will be developed in a manner complying with the requirements, policies and guidelines of the World Bank, GOE/EEAA, international agreements such as the International Maritime Dangerous Goods Code and the Basel Convention on Transboundary Movement of Hazardous Wastes.

The project is classified as a Category A project as per World Bank’s Operational Policies, O.P. 4.01 and Category C following the EEAA guidelines. The fact that the project is a Category A means that a comprehensive ESIA with a detailed ESMP will need to be prepared prior to project implementation.

3.3. Management of the Project

The Program is managed through a Project Management Unit (PMU). A steering committee is set up to oversee project implementation in the country.

3.4. Rationale for conducting ESIA

Pesticide repackaging, storage, handling, transportation, disposal and site remediation activities in country operations are associated with adverse environmental impacts. The Terms of Reference (ToRs) for the Environmental and Social Impact Assessment (ESIA) for Disposal of Obsolete Stockpile from Al-Adabeya Port are followed after EEAA (Annexes).

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Because of the significance of the impacts, Environmental and Social Impact Assessment (ESIA) and Environmental and Social Management Plan (ESMP) need to be prepared for the safeguarding and disposal activities. The major aim of developing the Environmental and Social Impact Assessment (ESIA) and Environmental and Social Management Plan (ESMP) is to put in place a decision making tool for environmentally sound management of obsolete pesticides.

3.5. Scope of the Project

The scope of the ESIA is management of obsolete lindane stockpile and lindane wastes. The detailed management of contaminated soil, lindane contaminated equipments, contaminated structures are outside the scope of this report and for that reason it is not exhaustively addressed in this report. The scope of work will include the following sections:

1. Environmental and Social Baseline 2. Legal and Institutional framework 3. Risk Assessment (Onsite; Road transport ; Temporary Storage at port if required; Loading onto ship; Site remediation; Occupational and public health; 4. Analysis of Alternatives 5. Environmental and Social Management Plan 6. Public and stakeholders Consultations

3.6. Methodology

3.6.1. Data Collection and Consultations – Stage I

The environmental and social impact assessment was carried out using a combination of methods including literature review, desk research, country project documents, extensive consultations with NEMC and other stakeholders, and from information to be collected during the fieldwork.

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Analysis was done using a "process approach" and "activity-impact interaction matrices" to identify, prioritize, and develop mitigation plans. The data collected from the process was analyzed using a structured approach.

Work Plan

The following activities were undertaken in developing ESIA: Baseline Survey – This is a multi-disciplinary site survey conducted prior in the initial stage. The survey included the following: (a) A summary of the previous management activities and lindane disposal initiatives (b) A statement on the causes of accumulation as identified by the documents. (c) All data related to the obsolete lindane stockpile in Al Adabeya Port, including the plot of Environmental and Pesticide Risk Factors. (d) A preliminary register of all containers.

Review of the Egyptian Policies, Legal and Institutional Framework – Area of focus included: (a) National waste management legislation, (b) National transport of hazardous goods regulations (includes repackaging for transportation, loading/unloading trucks, trucking to storage or disposal facility, and possible accidents) (d) Environmental Assessment/ Impact Regulations (e) Permitting of works, etc

Application of FAO Environmental Management Toolkit (EMTK) i.e. Volume 1that is based on the concept of environmental risk assessment and Volume 2provided support in the areas of pesticide storage and transport to guide the Process of Identifying Risks.

Environmental sampling (related to soil and air contamination) and other (testing where necessary) at the site, where the obsolete lindane stockpile stored.

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Public Consultation included the following: Development and implementation of a comprehensive and integrated public awareness, education and consultations program to support implementation of the project.

Analysis of Alternatives - Alternatives disposal options were explored. Several options are open to the project for the disposal of obsolete lindane and lindane wastes.

3.6.2. Development Environmental Management Plan (EMP) – Stage 2

The Environmental Management Plan (ESMP) describes the actions (including mitigation measures, cost, and institutional arrangements) that must be taken in order to ensure that obsolete lindane stockpile program implementation will be undertaken in an environmentally sound manner and without adverse socio-economic impacts.

The ESMP includes formulation of the mitigation measures for each risk category sites and estimation of the associated costs for the selected measures. 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 PMU and the international contractor 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.

The ESMP provide a basis for the development of the detailed and site specific operational health and safety plans. The health and safety plans are very detailed operational work plans that will be developed for all high risks by the disposal contractor. The plan will explain how the operations must be completed, will incorporate all the mitigations measures included in the ESMP, and describe how these mitigation measures will actually be implemented in the field.

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3.7. Basic Information about Lindane

Lindane is an organochlorine insecticide and considered as Persistent Organic Pollutant (POP). Throughout the world there is a shared concern as a result of its ongoing use, potential for release and transformation, long-range transport, widespread distribution, potential to bioaccumulate, and impact on humans and the environment.

Lindane is listed in Annex A of the Stockholm Convention with no specific exemption for production; there is a specific exemption for use as human health pharmaceutical for control of head lice and scabies as second line treatment, which allows existing stocks to be used for such purpose following World Health Organization (WHO) guidelines. Parties that want to continue using lindane for this purpose need to notify the Secretariat. The Secretariat keeps a register for identifying Parties that have specific exemptions that is available to the public.

The Stockholm Convention is a multilateral environmental agreement aimed at protecting human health and the environmental from the risks posed by Persistent Organic Pollutants (POPs). Although initially developed for a list of twelve of these chemicals, the Convention established long-term objectives, including the possibility of listing additional POPs that would be subject to international obligations to reduce or eliminate production and use.

The Persistent Organic Pollutants Review Committee (POPRC), a scientific subsidiary body to the Convention, has completed an extensive review nine new chemicals. The review process included the development of a risk profile and a risk management evaluation for each of the nine chemicals. These provide the supporting evidence of their POPs-like characteristics (persistence, bio-accumulation, potential for long-range environmental transport) and support the conclusion that global action is warranted. According to Paragraph 9 of Article 8 of the Stockholm Convention, based on the risk profiles and the risk management evaluations for these chemicals, the POPRC recommended that the Conference of Parties (COP) consider them for listing in Annexes A, B and/or C of the Convention. In May 2009, the Conference of the Parties

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decided to list lindane (-HCH), -HCH and -HCH and six additional chemicals as POPs in the Annexes of the Convention.

3.7.1. Chemical and physical properties

Lindane is the common name of the gamma isomer (-HCH) of hexachlorocyclohexane, which is used as an insecticide, one of eight stereoisomers of

1,2,3,4,5,6 hexachlorocyclohexane (Molecular formula: C6H6Cl6) with a molecular weight of 564.7 (290.83 grams). It is a white crystalline solid (CAS No. 58-89-9) which is stable in light, heat, air, carbon dioxide and strong acids but it can be hydrolysed at high pH. It is purified from the technical grade mixture of hexachlorocyclohexane.

Synonyms/abbreviations: gamma benzene hexachloride; gamma-BHC

Trade names: Agrocide, Aparasin, Arbitex, BBH, Ben-hex, Bentox, Celanex, Chloresene, Dvoran, Dol, Entomoxan, Exagamma, Forlin, Gallogama, Gamaphex, Gammalin, Gammex, Gammexane, Hexa, Hexachloran, Hexaverm, Hexicide, Isotos, Kwell, Lendine, Lentox, Linafor, Lindafor, Lindagam, Lindatox, Lintox, Lorexane, Nexit, Nocochloran, Novigam, Omnitox, Quellada, Silvanol, Tri-6, Vitron.

Structure:

Lindane is a volatile compound which can be found in remote regions where it is not used, such as the Arctic, and therefore has potential of long-range transport.

The half-life of lindane varies from 2.3 to 13 days in air, 30 to 300 days in water, 50 days in sediments and two years in soil. It degrades very slowly by microbial action

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and is more water-soluble and volatile than other chlorinated organic chemicals. This is why it is found in all environmental media (water/snow, air, soil/sediments).

While lindane has the potential to bioaccumulate in the food chain because of its high lipid solubility, biotransformation and elimination are relatively rapid. It has been found in seabirds, fish and mammals in the Arctic and in other regions of the world.

HCH isomers are produced by photochemical chlorination of benzene, resulting in a product called Technical HCH (CAS No. 608-73-1). Technical HCH is mainly made-up of five HCH 6 isomers; -HCH (53-70%), -HCH (3-14%), -HCH (11-18%), -HCH (6-10%), and -HCH (35%) [Howard 1989]. -HCH was first used in the 1940’s as an efficient and effective insecticide. Pure lindane (99%) is concentrated by treating HCH-isomer mixtures with methanol or acetic acid, and crystallizing. Even pure “lindane” contains small amounts of other HCH isomers.

The physicochemical properties of lindane (-HCH) and two other HCH isomers (- and -HCH) commonly found in the environment are summarized in Table 1. Lindane has a melting point of 112 C, and a boiling point of 323.4 C. A vapor pressure (VP) of 3.83 x 10-3 Pa and water solubility of 2.57 x 10-2 mol m-3 results in a Henry’s Law Constant (Hc) of 0.149 Pa m-3 mol-1 at 20 C. Lindane has a log octanol-water partition coefficient (Log Kow) of 3.5, indicating its potential to bioaccumulate in the lipids of organisms. In field experiments, a bioaccumulation factor (BAF) of 4.1 and bioconcentration factor (BCFs) between 2.26 and 3.85 were recorded. It is persistent in water and resistant to biodegradation (water t½ of 30 to 300 d). A soil half-life is estimated to be about 2 yr with a soil-sorption coefficient (K) of 3.0. Lindane is also persistent in the air (t½ of 2.3 to 13 d) with an estimated residence time of 17 weeks [Mackay et al. 1997]. Lindane and other HCH isomers in vapor form also appear to react with photochemically produced hydroxyl radicals, with a half-life of  2 days, at 5 x 10+5[OH-]/cm3 [Atkinson 1987]. These properties enhance lindane’s persistence, volatilization, long-range transport, wide-spread distribution, and its potential to bioaccumulate in the fatty tissues of living organisms to toxic levels.

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Table 3.1. Physicochemical Properties for Lindane (-HCH),  - and -HCH. Blank values represent no data; water solubility (Cs), vapor pressure (VP), octanol-water partition coefficient (Kow), soil sorption coefficient (Koc), Henry’s Law Constant (Hc), half-life (t½), bioaccumulation factor (BAF), bioconcentration factor (BCF).

Levels of Lindane (-HCH)2 -HCH3 -HCH4 Concern1 Melting Point (°C) 112.5 - 113.5 158 309 Boiling Point (°C) 323.4 288 Density (g cm-3@ 20 °C) 1.87 -1 Cs(mg L @ 20 °C) 7.3 10.1 0.7-5.0 VP (Pa @ 20 °C)  1000 Pa 0.00383 0.00333-0.084 3.73-4.90 x 10-5 3 -1 Hc (Pa.m mol @ 20 °C) 0.149 0.87 0.116 Log Kow  5 3.5 3.8 3.8-4.2 Log Koc 2.38 - 3.52 3.25-4.10 3.36-3.98 air (t½)  2 d 2.3 - 13 d 4 yr3 water (t½) 6 months 30 - 300 d 11.5 yr4 sediment (t½) 1 yr soil (t½)  6 months 2 yr log BAF  3.7 4.1 log BCF  3.7 2.26 - 3.85 1.93-3.38 2.66-3.08 1.Level of Concern values were selected by the Substance Selection Task Force on the basis of the results of a literature review. 2.Quoted by Mackay et al. (1997) 3.Model prediction for Arctic atmosphere [Wania and Mackay 1999] 4.Model prediction for Arctic Ocean [Wania and Mackay 1999] Lindane is used as an insecticide and pesticide with contact, stomach, and respiratory effects on a broad spectrum of crop and crop seed insects, public health pests (i.e., flies, scabies, lice, scorpions, and bed bugs) and animal ecotoparasites (i.e., fleas, ticks, horn flies, and ring worms) [Mackay et al. 1997].

3.7.2. Production of Lindane and other HCH Isomers

Lindane and its precursor technical hexachlorocyclohexane, or technical-HCH, do not

occur as natural substances. The manufacture of technical-HCH involves the photochlorination of benzene which yields a mixture of five main isomers. These isomers and their typical yield are listed in Table 2 below:

Table 3.2. Ratio of Isomers in the Production of Technical HCH

HCH Isomer Percent in synthesis mixture Alpha-HCH 60 -70 Beta-HCH 5-12 Gamma-HCH (Lindane) 10-15 Delta-HCH 6-10 Epsilon-HCH 3-4

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This mixture of technical-HCH isomers is subject to fractional crystallization and concentration to yield 99% pure lindane, produced at a 10-15 percent yield from this mixture. From a waste perspective this means for every tone of lindane that is produced, there are 6 – 10 tones of other isomers that must be disposed of or otherwise managed. As mentioned previously, lindane is the only isomer in the mixture that has insecticidal properties. Because of the waste isomer problem, the production of HCH/lindane has been a worldwide problem for years. One management option reported by industry is to transform the waste isomers into the solvent trichlorobenzene. The International HCH and Pesticide Forum exists in order to bring together experts to solve the myriad of problems associated with the cleanup of former HCH/Lindane production sites.

3.7.3. Production Status of HCH/Lindane

Lindane is no longer produced in North America. Lindane was never produced in Canada or Mexico. Lindane was produced in the United States; however, official records are sparse to non-existent, as production occurred 40-50 years ago. Information from a former lindane production site in Nevada illustrates the scale of the waste isomer problem. A company manufactured approximately 12,000 tones of lindane, and approximately 50,000 tones of waste HCH isomers have been buried at the site since the late 1970s and capped with a clay liner. Only India and Romania currently produce lindane for the world market. China stopped manufacturing lindane in 2003.

3.7.4. Main uses and applications

Lindane has been used as a broad-spectrum insecticide, which acts for both agricultural and non-agricultural purposes. Lindane has been used for seed and soil treatment, foliar applications, tree and wood treatment and against ectoparasites in both veterinary and human applications.

It is estimated that global lindane usage from 1950 to 2000 for agricultural, livestock, forestry, human health and other purposes amounts to around 600,000 tones. The

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next table (Table 3.3.) shows agricultural lindane usage in different continents between 1950 and 2000.

Table 3.3. Lindane usage in different continents between 1950 and 2000. Continent Usage between 1950-2000 (tones) Europe 287,160 Asia 73,200 America 63,570 Africa 28,540 Oceania 1,032 Total 435,500

Lindane is registered for use in 17 countries (CEC 2006). India produces and uses lindane for the control of mites in sugarcane at 200 tones per year, in the United States the only registered agricultural use for lindane is for seed treatment.

In the European Community, all uses of HCH including lindane have been banned. Currently, in the United States and Canada, lindane is allowed for public health purposes as a lice and scabies treatment on humans.

3.7.5. Risk profile

Lindane can be found in all environmental compartments. Levels in air, water, soil, sediment, aquatic and terrestrial organisms and food have been measured worldwide. Detectable levels in human blood, human adipose tissue and human breast milk indicate that widespread human exposure occurs.

The accumulation of HCH isomers, including lindane, in colder climates of the world is of special concern. High concentrations of HCH isomers, including lindane, have been measured in the Beaufort Sea and northern Canadian archipelago. Lindane can enter the food chain and accumulate in fatty animal tissue constituting an important exposure pathway for Arctic or Antarctic animals as well as for humans who rely on these animals for their subsistence diets. Lindane residues can also be found in milk and meat from livestock that has been treated for ectoparasites. Food is the most common human exposure pathway to lindane; a correlation between food intake,

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especially fish, meat and dairy products, and marine mammals, and lindane concentrations in body fat and human milk has been shown.

Exposure of children to lindane is a particular concern since there are several exposure routes and by the ongoing presence of HCH isomers, including lindane, in human tissues and breast milk. Gamma-HCH has been found in human maternal adipose tissue, maternal blood, umbilical cord blood and breast milk. Lindane has also been found to pass through the placental barrier. Medical use of products to treat head lice and scabies applied to children is also of concern, although most adverse effects observed have been the result of misuse. An additional exposure route for children exists in regions where lindane is applied directly to milk and meat producing livestock for pest control. On a body weight basis, children consume more milk per unit body weight than adults, and thus may be exposed to significant concentrations of lindane residues through drinking milk. Another exposure to possibly significant amounts of lindane might occur through household dust in certain conditions.

Lindane is the most acutely toxic HCH isomer. It affects the central nervous and endocrine systems. In humans, effects from acute exposure at high concentrations to lindane may range from mild skin irritation to dizziness, headaches, diarrhea, nausea, vomiting, and even convulsions and death. Respiratory, cardiovascular, hematological, hepatic and endocrine effects have also been reported for humans, following acute or chronic lindane inhalation. Hematological alterations like leukopenia, leukocytosis, granulocytopenia, granulocytosis, eosinophilia, monocytosis, and thrombocytopenia, have been reported, following chronic human occupational exposure to gamma-HCH at production facilities.

The most commonly reported acute effects associated with ingestion of gamma-HCH are neurological; seizures and convulsions have been observed in individuals who have accidentally or intentionally ingested lindane in insecticide pellets, liquid scabicide or contaminated food.

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Numerous studies have demonstrated hepatotoxic, genotoxic, reproductive, developmental and immunotoxic effects of lindane in laboratory animals. The International Agency for Research on Cancer (IARC) has classified lindane as possibly carcinogenic to humans. Lindane is reported to be highly toxic to some fish and other aquatic species.

3.7.6. Regulations at the international, regional and national levels

At the international level, lindane is listed as:

• A “substance scheduled for restrictions on use” in Annex II of the 1998 Protocol on Persistent Organic Pollutants of the Convention on Long-Range Transboundary Air Pollution. It was restricted to the following uses: 1. Seed treatment. 2. Soil applications directly followed by incorporation into the topsoil surface layer 3. Professional remedial and industrial treatment of lumber, timber and logs. 4. Public health and veterinary topical insecticide. 5. Non-aerial application to tree seedlings, small-scale lawn use, and indoor and outdoor use for nursery stock and ornamentals. 6. Indoor industrial and residential applications.

• A chemicals subject to the prior informed consent procedure under Annex III of the Rotterdam Convention on the Prior Informed Consent Procedure.

• A Chemical for Priority Action (updated 2005) under the OSPAR Commission for the Protection of the Marine Environment of the Northeast Atlantic (listing of HCH isomers, including lindane).

At regional level, the Great Lakes Binational Toxics Strategy between the United States and Canada includes HCH (including lindane) as a Level II substance.A North American Regional Action Plan (NARAP) on Lindane and Other Hexachlorocyclohexane Isomers is being implemented under the Sound Management of Chemicals programme, which is an ongoing initiative to reduce the risks of toxic substances to human health and the environment in North America.

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Lindane is also listed under the European Water Framework Directive. This Directive requires all inland and coastal water bodies to reach at least “good status” by 2015.

Lindane is one of the listed priority hazardous substances for which quality standards and emission controls will be set at EU level to end all emissions within 20 years.

Lindane is banned for use in 52 countries, restricted or severely restricted in 32 countries, not registered in 10 countries, and registered in 17 countries (CEC 2006).

3.7.7. Long-Range Transport

Like other persistent organic pollutants, lindane and other isomers of HCH can be transported over long distances by air currents. All HCH isomers vaporize and condense, touching down on oceans and freshwater bodies, where they may begin the cycle again. As a result of these characteristics, lindane and other HCH isomers tend to accumulate in colder climates, where they are trapped by low evaporation rates. Certain HCH isomers are some of the most abundant and pervasive organochlorine contaminants found in the environment, especially in the Arctic.

3.7.8. Persistence and Environmental Fate

Lindane is persistent and mobile. It is resistant to photolysis and hydrolysis (except at

high pH), and degrades very slowly by microbial actions. Once released into the environment, lindane can partition into all environmental media. Lindane is stable in freshwater as well as in sea water. Degradation takes place much faster under anaerobic conditions than in the presence of oxygen. A limited degradability has been

demonstrated in cold areas. Like lindane, the alpha- and beta-HCH isomers are found in air, seawater, seabirds, fish, and mammals in the Arctic food web.

3.7.9. Bioaccumulation

Lindane and other HCH isomers can bio-accumulate easily in the food chain due to their high lipid solubility and can bio-concentrate rapidly in microorganisms,

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invertebrates, fish, birds and mammals, however, bio-transformation and elimination are relatively rapid when exposure is discontinued.

Lindane and other HCH isomers occur in different compartments and trophic levels of the Arctic ecosystem and are accumulated by species at low trophic levels, while the biomagnification potential is low at the upper end of the food web. The beta isomer of HCH is the most persistent and bioaccumulative form and accounts for almost 90% of the HCH detected in human tissues and breast milk.

Experts support the need for additional research to determine why the beta isomer is the most prevalent form of HCH detected in human samples when it only makes up a small percentage of the technical mixture and technical HCH is banned in many countries.

Lindane has a log bioaccumulation factor (BAF) of 4.1, exceeding the level of concern (log BAF>3.7) determined by the CEC's Substance Selection Task Force.Lindane is metabolized fairly rapidly in standard test species (e.g., rainbow trout, rat) under laboratory conditions. In humans, the half-life of lindane after topical application for treatment of scabies is approximately 1 day.

3.7.10. Exposure

There are two significant pathways for lindane to adversely impact human health. These include intake of food and drinking water containing traces of lindane and its isomers as contaminants, and direct exposure, such as agricultural workers (e.g., seed treaters) or persons to whom lindane has been applied as a treatment for head lice or scabies.

General Exposure

The most wide-spread exposure to lindane for the general public is through food consumption or as a topical treatment for head lice and scabies. Currently lindane is allowed to be used as a pre-plant seed treatment in Mexico. This seed treatment use is being voluntarily canceled in the United States. Crops grown from treated seeds may result in dietary exposure. Adverse affects on children’s health are a particular

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concern in regions where lindane is applied directly to milk and meat producing livestock for pest control. This use has been cancelled in the United States and Canada. On a body weight basis, children consume more milk per unit body weight than adults, and thus may be exposed to significant concentrations of lindane residues. Moreover, children’s direct exposure to lindane pharmaceutical products requires careful attention to ensure proper use.

Subsistence Exposure

HCH isomers are the most abundant organochlorines in the Arctic Ocean. The highest concentrations of HCH isomers are in the Beaufort Sea and Canadian Archipelago. The elevated residues of HCH isomers in marine mammals of the Archipelago are likely from the high concentrations of HCH isomers in the water.

There is an important relationship between meat and fish consumption and concentrations of HCH isomers in human milk and body fat. Various mammals, fish and birds that the indigenous people of the North depend on for subsistence have measurable quantities of the persistent, toxic and bioaccumulative HCH isomers.

The indigenous people of the circumpolar Arctic region are concerned that their subsistence diets may increase their exposure to HCH isomers. One reason is that exposure through subsistence diets to HCH isomers that are found in the Arctic food chain result from production and use of HCH isomers in countries outside of North America. Further study is needed to better assess the short and long term effects associated with this exposure pathway.

3.7.11. Human Toxicity A wide variety of toxicological effects are recorded for lindane and other isomers of HCH, such as reproductive and neurotoxic impairments. Lindane has also demonstrated a potential to adversely affect endocrine systems in animals. Effects from acute exposure at high concentrations to lindane may range from mild skin irritation to dizziness, headaches, diarrhea, nausea, vomiting, and even convulsions and death. Toxicological data indicate that chronic exposure to lindane at high

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concentrations can adversely affect the liver and nervous system of animals, and may cause cancer and possibly immune system suppression.

3.7.12. Ecotoxicity

The toxicology of alpha, beta- and gamma-HCH isomers has been studied extensively in mammals and to a lesser extent in fish and insects. Lindane is moderately toxic to birds and mammals following acute exposures. Chronic effects to birds and mammals measured by reproduction studies show adverse reproductive effects at low levels, with some effects indicative of endocrine disruption. Acute aquatic toxicity data on lindane indicate that it is very highly toxic to both freshwater and estuarine species. Chronic aquatic toxicity data for freshwater organisms show that reduced growth and reproduction were the most sensitive endpoints to lindane testing. Similar levels of toxicity are expected for estuarine and marine organisms.

3.7.13. Toxicity and Persistence of other HCH Isomers

As with lindane, all other isomers of HCH cause acute and chronic neurotoxic effects and can produce liver and kidney effects. The alpha isomer also shows some evidence of immunosuppression and blood effects. In past reviews, EPA has classified technical-grade HCH (i.e., predominantly alpha-HCH) as a probable human carcinogen. Beta-HCH has been classified as a possible human carcinogen, while delta-HCH has been designated as not classifiable for human cancer. The International Agency for Research on Cancer (IARC) also has classified technical HCH and alpha HCH as possible human carcinogens. It considers evidence for carcinogenicity in the beta and gamma isomers as limited. Further, EPA has classified HCH as a hazardous waste that must meet certain disposal requirements.

The chronic effects of the beta-HCH isomer are of particular interest because of its predominance among all HCH isomers in mammals, including humans, and its apparent long biological half-life. A half-life of 7.2 years has been estimated for beta- HCH in humans.

Beta-HCH has been described as producing estrogen-like effects through nonclassical

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estrogen-dependent mechanisms of action.The bioconcentration factor is higher and the elimination is slower for beta-HCH than for the other HCH isomers. The reasons for variable compositions of HCH isomers in wildlife tissue are unknown. Possible explanations include “different sources of contamination; different times of exposure; and differences in uptake, metabolism, or storage by various species.”

3.7.14. Evidence for isomerization of lindane

Concern about the potential for conversion of -HCH into other isomers, particularly - HCH, comes in part from the observed high concentrations of the  isomer relative to the  isomer in the northern hemisphere. The ratio of to  in technical gradeHCH varies between 4 and 7 (Iwata et al. 1993b). Therefore, residues of this mixture found in the environment could be expected to reflect that ratio unless some process had changed it. The use of lindane would, in effect, lower this ratio. However, air and water samples far from pesticide application sites have often contained ratios much higher than 7 (Iwata et al. 1993a; Patton et al. 1989; Pacyna and Oehme 1988). Several hypotheses have been suggested to explain why so much of the HCH residue found in the environment is inthe form of the  isomer.

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CHAPTER IV Environmental and Social Baseline data

4.1. DESCRIPTION OF THE ENVIRONMENT

The Al Adabiya port storage facility in Egypt was built in 1975 and dedicated for the storage of dry bulk. It is situated about 125 km east of Cairo easily reachable by good condition highway. The nearest larger city is Suez city in Suez governorate (17 km to the North). The storage is an open yard designed for temporary storage of shipped goods. The site of obsolete pesticide (lindane) containers at Al Adabiya Port, lies at about 17 km to the south of Suez City along the Suez- Ain Sukhna road, Egypt. The site is located at the northwestern side of the Gulf of Suez at the intersection of Latitude 29°52.997' N and Longitude 32°27.968' E (Fig. 4.1).

Fig. 4.1. Landsat ETM image showing location of the obsolete pesticides site.

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4.1.1. TOPOGRAPHY

With the exception of a few prominent highs, the Cairo-Suez district is a country of low relief and poorly-defined drainage lines. The topography is controlled, to a great extent, by its geological structure; the topographic highs are also structural highs. The bolder topographic features are made up of Middle Eocene limestones. The existing obsolete pesticides yard at Al Adabiya port is located in a topographically low coastal plain to the east of G. Ataqa to the northeast of Wadi Hagul. Wadi Ghweiba, which is located to the south of Wadi Badaa (Figs. 4.1, 4.2 and 4.3). All these wadis discharge their drainage water into the Gulf of Suez to the East. This area includes several peaks of elevations ranging from 1000 to 1270 m.

The regional slope of the area is largely determined by the direction of the main course of Wadi Ghweiba and Wadi Badaa (towards east and southeast).

Fig. 4.2. Landforms of the northwestern part of the Gulf of Suez (modified after El Osta et al. 2010).

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Fig.4.3. Topographic map of the Ain Sukhna area.

The slope of the land surface at the obsolete pesticides yard is considered as gentle slope (from 0 to 0.7o). The coastal zone to the east of G. Ataqa ranges in elevation between 40 m and zero (sea level). The ground elevation at the obsolete pesticides yard ranges between 8 and 10 m.

4.1.2. REGIONAL GEOMORPHOLOGY

The Cairo-Suez district which extends between Cairo (Maadi) and Suez (Ain Sukhna) occupies the northern extremity of the Eastern Desert. This district displays geomorphological features which reflect the effect of both arid and wet climatic conditions. The present day landforms have a great effect on the surface and groundwater conditions where watershed areas, water collectors, drainage basins and discharge areas are developed. The district is bounded to the north by the rolling plain which extends from Heliopolis northeast of Cairo to Ismailia on the Suez Canal. It is bounded to the south by a line of east-west disposed

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escarpments that extends from Tura, south of Cairo, to Gebel Ataqa and the northern Galala plateau on the Gulf of Suez. With the exception of a limited area of Cretaceous rocks which are exposed at the extreme eastern end of the district at the foot of Gebel Ataqa and the northern Galala plateau, the district is built mainly of Eocene and younger sediments.

Geomorphologically, this area can be divided by N-W and E-NE faults into the following units:

a) Plateaux The El Qatamiya-G. Ataqa plateau lies in the northwestern part and consists of a series of alternating smaller graben sand horsts, which are mainly controlled by northwest to north-northwest oriented faults. This plateau is mainly capped by Eocene-Paleocene rocks and is divided by faults into three subunits, which are El Qatamiya-G. Akheider, G. Kahaliya-G. Umm Zeila, and G.Ataqa. Khashm El-Galala and the northern Galala plateau lie in the southern and southwestern part of the obsolete pesticides yard (Fig. 4.4 and 4.5).

G. Ataqa Obsolete pesticide containers

Fig. 4.4. A photo showing G. Ataqa to the west of the obsolete pesticides site.

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Northern Galala Khashm plateau El-Galala

Fig. 4.5. A photo showing Khashm El-Galala and the northern Galala plateau(towards south and southwest from the obsolete pesticides yard.

b) Questas In the northern part of this area, G. Ataqa block is structurally subdivided into several sub-blocks. They form questas that resulted from step faulting but with the abundance of uplifted and down thrown sub-blocks.

c) Depressions The lowland areas are represented by grabens between the mentioned faulted blocks. Wadi Ghweiba, Wadi Badaa, and Wadi Hagul are the main structural depressions in the area. The ridges of Gebel Kahaliya-Gebel Umm Zeita ridge, and Gebel El Nuqra-Gebel Akheider divide the depression into three main wadies. Namely; Wadi Hagul, Wadi Badaa and Wadi Ghweiba (from north to south).

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d) Alluvial Fans and Bajada The pediment at the northern faulted scarp margin of El-Galala El-Bahriya plateau is covered by alluvial fans and bajada. The sediments of these alluvial fans form a sequence of sedimentary basin-fill deposits. Away from the scarp front these fans coalesce to form an alluvial bajada.

e) Coastal plains Coastal plain is limited and very narrow due to the vicinity of the structural plateaux to the shoreline of the Gulf of Suez. The scarps bordering the eastern sides of the plateaux terminate abruptly against the Gulf leaving a very narrow coastal plain. The coastal plain is covered with fine sediments and gravel. Some parts are covered by Sabkha.

4.1.3. HYDROPHYSIOGRAPHY

The Northwestern part of the Gulf of Suez can be differentiated into three main hydrophysiographic provinces (Desouki et al. 2006). These are the high tablelands (watershed areas), water collectors, and coastal plain (Fig. 4.6).

The watershed areas The high tablelands with no or little alluvial cover form the major part of the catchment areas of the main wadis in the northwestern part of the Gulf of Suez (Wadi Hagul, Wadi Badaa and Wadi Ghweiba). These include Gebel Ataqa (+870 m), Gebel Kahaliya (+555 m), Gebel Umm Zeita (+245 m), Gebel Akheider (+350 m) and the northern Galala plateau (+1250 m).These main wadis drain surface runoff into the coastal plain and the Gulf of Suez.

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The water collectors The northwestern part of the Gulf of Suez is characterized by several wadis draining from the high tablelands (watershed areas) into Sukhna coastal plain, they are (from north to south) Wadi Hagul which has no flood hazard on the Al Adabiya Port, where it is separated from Wadi Hagul by the Ataqa plateau (Fig. 4.1), Wadi Badaa, and Wadi Ghweiba which is the most important drainage basin to the south of the Sukhna area.

The coastal plain

The surface of the coastal plain is built up of Quaternary sediments occupying the area between the mountainous terrain and the shore line. Its elevation ranges from 6 m to 24 m above sea level and is dissected by many drainage lines directed towards the Gulf of Suez.

The frontal and low coastal plains act as collecting basins for the rainfall and runoff water from the surrounding tableland.

Fig. 4.6. Hydrophysiography of the northwestern part of the Gulf of Suez.

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4.1.4. GEOLOGY

The Al-Adabiya port lies at the extreme northeastern part of the Eastern Desert of Egypt. The northern part of Egypt including, the north Eastern Desert, the north Western Desert, the Nile Delta and north Sinai lie in the unstable shelf area (Said, 1962). The obsolete pesticides yard is located to the east of Gebel Ataqa and to the north of the northern Galala plateau. It also lies to the north of the down streams of Wadi Hagul, Wadi Badaa and Wadi Ghweiba.

4.1.4.1. Surficial Geology of the Obsolete Pesticides Site and the Surrounding Areas

Description of the geology of the area is given referred to the geology of Cairo- Suez district (Said, 1962). The exposed rocks in the Cairo-Suez district are entirely of sedimentary origin built mainly of Eocene and younger sediments (Fig. 4.7). The Middle Eocene rocks are the common and dominant outcrops encountered along the Maadi-Ain Sukhna road. This rocks are represented by Mokattam Group, which predominantly consisting of Observatory Formation that is composed of shallow marine, dense medium bedded limestone with local chert and few nummulites. Gebel Ataqa lies to the west of Al Adabeya port and the northern Galala plateau is located to the south and form a huge Middle Eocene outcrops in this area.

To the west of the Al Adabeya port, the Cairo-Suez Hagul Formation (Late Miocene) crops out in lowland areas of Wadi Badaa and Wadi Hagul and most of the area surrounding Cairo-Suez road. This formation is made up of Upper Miocene fluviatile sand and gravel, which underlain by Hommath Formation of Middle Miocene marine fossiliferous limestone with sandy layers at the base.

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Fig. 4.7. Geological map of the northwestern part of the Gulf of Suez (Compiled after Conoco Coral, 1987).

4.1.4.2. Stratigraphy of the areas surrounding the Al Adabeya port The different stratigraphic units exposed at the Cairo-Suez district including the area of the port and surroundings are mainly of sedimentary origin and ranging in age from Permian to Quaternary (Said 1962, Conoco Coral 1987). They are described from older to younger as follows (Fig. 4.7):

1- Permian Rocks are the oldest exposed rocks in the district and cover the low-lying expanse of foothills extending along the eastern escarpment of the northern Galala plateau. These rocks consist of alternating beds of dark colored sandstone, siltstone and shale with subordinate limestone.

2- Jurassic Rocks are of limited occurrence and are exposed only at Khashm El Galala, which is located at the extreme northeastern end of the northern Galala plateau. The Jurassic sequence is differentiated into cross-bedded sandstone at the bottom overlain by fossiliferous marls and dolomite bands. The upper part of this sequence consists of siltstone and sandstone intercalations.

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3- Cretaceous Rocks crop out at southern scarps of Gebel Ataqa massif, and also at the eastern cliff of the northern Galala plateau as well as the escarpment of Khashm El Galala. The Cretaceous rocks are distinguished into (a) lower Cretaceous rocks (250 m thick): consist of gritty and cross-bedded sandstone interceded with shale and kaolin, and (b) upper Cretaceous rocks (140 m thick): made up of two types of rocks. At the base is a sequence of well-bedded green shales and marls with sandstone interbeds. The upper part is composed of grayish white limestone and marl capped with thick massive dolomite and dolomitic limestone.

4- Lower and Middle Eocene Rocks are composed predominantly of a sequence of thick- bedded limestone with subordinate marl and local chert. They cover large parts of the concerned area and build up the surface cap and topmost part of cliffs of major topographic highs (G. Kahaliya, G. Akheidar, northern Galala plateau and G. Ataqa,). The lithology of the Middle Eocene rocks of the district is not different from that of the Mokaattam Formation known from the Cairo neighbourhood. They are made up of white chalky limestones with occasional marl beds near the top.

5- Upper Eocene Rocks follow on top of the Middle Eocene rocks in different areas in the district and crop out mostly in the lowlands between the highlands, where they are downthrown against the Middle Eocene limestone beds. They are usually made up of sandy brownish limestones with occasional sandstone beds.

6- Oligocene Deposits in the Cairo-Suez district are represented by two different formations: the sands and gravels of the Gebel Ahmar type and the basalt flows and dikes. The Oligocene sands and gravels form dark-colored low hills of a characteristic appearance. They are varicoloured, unstratified, cross-bedded, and coarse-grained. The sands and gravels are usually loose or poorly cemented, but in certain places, especially in the vicinity of faults, uprising silica and iron-bearing fluids caused the formation of hard iron-stained quartzites. The Oligocene sands and gravels unconformably overlie the Upper Eocene sediments and unconformably underlie the

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basal beds of the Miocene. In the depression between G. Ataqa and the northern Galala plateau, the Oligocene sands and gravels cover small patches, which overlie unconformably the Upper Eocene Beds.

7- Miocene Sediments cover a large area of the Cairo-Suez district and form less conspicuous topographic features than the Eocene rocks. Miocene rocks are mainly represented in the Ataqa-northern Galala depression by marls and sandy limestones. This outcrop follows faults, that border the eastern side of Gebel Ataqa massif. They are composed of grits, gravels and sands. The Miocene sediments are divisible into two units: a lower unit made up of richly fossiliferous marine sediments and an upper unit made up of non-marine fluviatile sediments. The Miocene section of the Cairo-Suez district increases in thickness from west to east.

8- Pliocene Deposits form series of gravels capped by a thin (less than 0.5 m) layer of white to grey, hard, very dense, porcellaneous limestone overlies the non-marine Miocene in many areas along the Cairo-Suez district (Shukri and Ayouty, 1956). They are limited and are restricted to the Ataqa-northern Galala depression. They have a patchy distribution and are made up of gravels and sands.

9- Plio-Pleistocene Deposits are represented in the district to the northeast of Cairo by extensive, false bedded, feldspar-bearing, coarse sands that fill the alluvial fans of many of the present day wadis that drain into the Nile and also fill the sides of a number of the major wadis of the area. This indicates that the present day drainage system was already existed during Plio-Pleistocene times.

10- Holocene Deposits are the youngest deposits in the area. They are mainly alluvial deposits; which are developed in the shallow elongated depressions and along the channels of the drainage lines in the form of Wadi fillings. These deposits are loamy deposits composed of quartz sand, silt and clay and gravel is common in the surface soil.

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4.1.5. SOIL PROFILE

The majority of the surficial soils encountered during the site investigation of the wastewater treatment plant (9 km to the north of the obsolete pesticides site) represent alluvial deposits, and typically comprise gravel with sand, plus some cobbles and silt. The alluvial fan stretches from the base of Gebel Ataqa to the west to the Suez-Ain Sukhna Road to the east. This fan has been formed by the erosion and deposition of soil from Gebel Ataqa during infrequent flash floods. These deposits are thought to be underlain by limestone and alternating layers of clay and sand.

A total of 9 boreholes to a maximum depth of 10 m, were drilled at the proposed wastewater treatment plant site by Geogroup (1982) in March 1981. The boreholes, which were predominantly in the east of the site, indicate a highly layered stratigraphy of calcareous sand and gravel, with occasional silt or silty clay strata. Large quantities of cobbles and limestone fragments were encountered throughout the sand and gravel layers. The cohesionless deposits were very dense, and the clay was hard in consistency.

4.1.6. Natural hazard vulnerability The Al-Adabiya port including the obsolete pesticides yard may be exposed to one of the main natural hazards which are earthquakes and flooding. 4.1.6.1. Seismic Activity

Maamoun and Ibrahim (1978) and Kebeasy (1984) divided Egypt into four main trends based on the distribution of historical and recent earthquakes with the major structure trends crossing Egypt (Fig. 4.8). The Al-Adabiya port is located in the Northern Red Sea-

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Gulf of Suez-Cairo-Alexandria Tectonic Trend. This trend is the major active trend inside the land of Egypt and extends along the northern Red Sea, Cairo, and Alexandria toward northwest in the Mediterranean Sea. It is characterized by the occurrences of shallow, micro, small, moderate and large earthquakes. Activity along this trend has increased in recent years. All earthquake foci are limited within the crust. The activity along this trend is mainly attributed to the Red Sea rifting as well as several active faults which have trends NNW parallel to the Red Sea-Gulf of Suez direction and its continuation toward east Mediterranean.

Field observation, landsat images and seismic profiles confirm this suggestion indicating active tectonics in the Eastern Desert between Suez and Cairo.

Site of obsolete

lindane

Fig. 4.8. Epicental distribution of all earthquakes, focal mechanisms of principal earthquakes and active seismic trends (Kebeasy, 1984).

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In addition to these trends there are several areas known to be active such as Wadi Hagul west of the Gulf of Suez. The activity in these areas is of a very local nature. The epicentral distribution map using the collected catalogue through this study (Fig. 4.9) shows a continuation of the activity from the mouse of the Gulf of Suez toward NW into the Western Desert. A close inspection for this part shows that the earthquakes are coincide with the NW-SE faults especially in the area close to the Gulf and NE-SW faults in the area located to the west of the Gulf. These two fault trends are approximately perpendicular.

Fig. 4.9. Epicentral distribution map of earthquakes in the northeastern part of Egypt from 1900 to May, 1997.

The map indicates that Al Adabeya port lies in an area where no earthquake epicenters were recorded. However, the site is located in an active seismic trend where some earthquake epicenters were recorded in nearby areas near Cairo and near the Gulf of Suez, such as Wadi Hagul earthquake in March 19, 1984. This earthquake occurred in Wadi Hagul southwest of Suez and Al Adabeya port. Its magnitude was 4.7 and was felt strongly in Suez, Ismailia and Cairo. Large numbers of aftershocks were recorded by nearby temporary stations. The focal depth is estimated to be 10km. Therefore, the obsolete pesticides yardrequires a site specific ground motion study to determine the likely behavior of the existing soils to ground motion induced by earthquakes to reduce the earthquake hazard.

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Fig. 4.10. Surface drainage network of the Adabiya area extracted from the enhanced satellite ETM+7 images and topographic map (Arnous et al. 2011).

4.1.6.2. Flash Flood Hazards

The coastal plain of Ain Sukhna is dissected by a number of wadis, initiating from the topmost part of Gebel Ataqa and the northern Galala plateau and trending easterly to debouch into the Gulf of Suez. Al Adabeya port lies to the north of the downstream portions of Wadi Ghweiba, Wadi Badaa, and Wadi Hagul, therefore, the site is not affected by the flash flood hazard from these wadis. On the other hand, the site of obsolete pesticides at Al Adabeya port lies between W. Abou Syeala to the north and W. El Maghra El Bahry and W. El Maghra Hadyera to the south (Fig. 4.10). These wadis run from NNW and E-W and their input into the Gulf of Suez. According to Arnous et al. 2011, flood hazard sites are located at the end of the main trunk of Wadi Maghra Hadyera at longitude 32°:27′:29″ E and latitude 29°:49′:13″N and Wadi. Maghra El- Bahry located at longitude 32°:28′:17″ E and latitude 29°:50′:19″ N.While, W. Abu Syeala at longitude 32°:25′:58″: E andlatitude 29°:54′:15″ N (Fig. 4.11)

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Fig. 4.11. Flash flood risk area map of the Adabiya area (Arnous et al. 2011).

4.1.7. GROUNDWATER RESOURCES

The freshwater environment is characterized by the hydrological cycle, including floods, and droughts, which in some regions such as arid lands have become more extreme and dramatic in their consequences. The source of groundwater (recharge) is through precipitation or surface water that percolates downward. Approximately 5-50% (depending on climate, land use, soil type, geology and many other factors) of annual precipitation results in groundwater recharge.

4.1.7.1. Hydrometeorology

The Eastern Desert of Egypt is characterised by an arid to hyper-arid climate, with long hot summers, short cold winters and scarce rainfall of less than 50 mm per annum on the average. Climatic conditions of the Eastern Desert are usually controlled by the setting of the region with regard to the general circulation of the atmosphere, the proximity of the Red Sea, the orientation of the coast and the orography. The following sections describe the climate of the northern part of the Eastern Desert based on the data from the Suez meteorological station.

Obsolete pesticide site

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4.1.7.1.1. Air temperature The region in which the obsolete pesticides yard is located displays a typical hyper-arid climate (Fig. 4.12). Differences between the average monthly maximum and minimum temperatures are around 10oC only. This may be due to the nearness of the climatic stations to the sea.

Fig. 4.12. Average monthly air temperature and relative humidity from 1945-2000 for Suez, meteorological station (Meteorological Authority of Egypt).

4.1.7.1.2. Relative humidity Figure 4.12 shows the air humidity compared with air temperature for Suez station. It is observed that the values of relative humidity mostly inverses with the change in air temperature. It reaches highest values during the winter season and the lowest values during the summer season.

4.1.7.1.3. Evaporation

Figure 4.13 shows the average daily evaporation at Suez station. The figure shows the maximum average daily evaporation that is recorded during the summer season, while the lowest average evaporation values are observed during the winter.

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Compass Direction

W 70 60 50 40 30 20 10 10 20 30 40 50 60 70 E

Fig. 4.13. Average daily potential (pan) evaporation for the climatic stations in the Gulf of Suez and Red Sea Coast for the period 1945-2000 (Meteorological Authority of Egypt).

4.1.7.1.4. Wind speed The Red Sea Coast particularly at the Gulf of Suez is one of the windiest areas of the world. The mean wind speed of the Gulf of Suez is 34.2 km/h (DEWI Magazine 2000). There are two main wind directions: the coastal (mostly from the Gulf of Suez and Red Sea) and the inland desert direction. The first type is dominant and strong, while inland winds are dry and dusty. From the available recorded data for Suez station, the prevailing wind direction all over the year is the northerly wind especially in August and September followed by the northwestern and southern directions (Fig. 4.14).

Fig. 4.14. Percentage frequencies of annual wind direction and their resultant from 1926- 1945 for Suez station.

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4.1.7.1.5. Rainfall Rainfall in the northern part of the Eastern Desert occurs close to the coast but may extend few kilometres inland. The rainy season starts with infrequent showers in October, which increasing infrequently in November, December and January and extends to May. However, some few showers may occur during summer. The average annual rainfall amount on the coastal zone recorded in the Suez climatic station, for the period of 56 years (1945-2000), is 17.4 mm (Fig. 4.15). Rainfall represents the main source of recharge of groundwater in this area, where rainfall intensity is about 20 mm/year. It infiltrates downward rapidly through fissures in the limestone tableland (Mohammed, 2001)

Fig. 4.15. Average monthly rainfall distribution through the year from average of 56 years (1945-2000) on the Gulf of Suez and Red Sea coast (Meteorological Authority of Egypt). 4.1.8. Groundwater Aquifers

The important groundwater aquifers in the Ain Sukhna area are classified into the following categories (Desouki et al. 2006):

The Quaternary aquifer represents the main water-bearing strata in the Ain Sukhna area. The groundwater is pumped by the companies, factories and tourism villages distributed in the area. It is built up of sand and gravel with clay and limestone intercalations. Groundwater in the Quaternary aquifer occurs under free water table condition. The

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depth to water ranges between 6.20 m and 60.20 m and the water flow direction is being towards the Gulf of Suez.

The Pliocene aquifer is detected in Wadi Badaa. It is mainly composed of limestone, clay, sand and gravel with dolomite. The Pliocene rocks are distributed in a large part of Wadi Ghweiba. The Pliocene aquifer is mainly recharged from the Quaternary aquifer through direct infiltration as well as up leakage from deep aquifers. The depth to water ranges from 4.9 to 12 m.

The Miocene aquifer is encountered at depths of about 100 m and its thickness is about 20 m. It is composed of sands, sandstones, gravels with green marl interbreeds. The Miocene water-bearing formation has a wider spread over the Ain Sukhna area and has a higher groundwater potential.

The Eocene aquifer is manifested in the area at the foot of Gebel Ataqa near Suez town. However, the aquifer was encountered at a relatively great depth where it is tapped at a depth of 635m (Abdel Daiem, 1971).The Eocene water-bearing formation has a less groundwater potential.

The Cretaceous aquifer discharges El Sukhna hot spring Diab (1969). The groundwater freely flows by upward rising of the deeply circulating Nubian water through the fissures and fractures under high pressure head. It is mixed with normal seawater intrusion in the Quaternary aquifer.

4.1.8.1. Groundwater Conditions and flow directions

From the hydrological point of view, the aquifer unit at the Al Adabeya Pport is represented by the local and moderately to low productive aquifer of the Oligo-Miocene sands and gravels interpreted from the hydrogeological map of Egypt (scale 1: 2.000.000).This Aquifer unit receives insignificant surface recharge, with limited subsurface recharge, and the main

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type of recharge is through inter-aquifer recharge. The Aquifer unit composed primarily of sands and gravels and siltstones.

Due to the absence of groundwater wells in the area surrounding the obsolete pesticide site at the Al Adabeya port we referred the groundwater conditions to the nearest site with available information which is likely to be extended under the investigated site. This site is located at about 9 km north of the obsolete pesticides site at Al Adabeya port (in the new wastewater treatment plant) where the groundwater level appears to be approximately at the same elevation as the sea level. The groundwater is highly saline where total dissolved solids range from 19550 to 30810 mg/l, suggesting that it is in hydraulic contact with the sea. At the obsolete pesticide yard the ground is paved with an asphaltic layer, which prohibits infiltration of any surface water or water spills in the yard. Moreover, high evaporation rates and very low amounts of rainfall don’t allow accumulation of any surface water.

4.2. Environmental Biology 4.2.1. Ecology of the obsolete pesticide yard hinterland The obsolete pesticide site at the Al Adabiya port lies to the east of G. Ataqa on the Gulf of Suez coastal plain and to the north of the Ain Sukhna area. However, the name traditionally designates a much larger region encompassing the wide coastal plain wedged between Gebel Ataqa (871 m) in the north and Gebel El Galala El Baharya in the south, and including the coastal portion of the latter mountain range (Baha El Din, 1999). Based on literature review and on a walk-over survey of approximately 60 km along a north-south segment of the study area.

4.2.2. Ecology of the obsolete pesticide site The site has a rectangular shape occupying an area of 5,850 square meters with dimensions of 225 × 26 m. It is currently paved and surrounded by about 3 m walls.

Most of the site seems to have been subject to heavy equipment movements. The location also seems to have been levelled and subjected to cut and fill. These activities may have impacted the vegetation cover.

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Flora

The vegetative cover of the site could be considered very scarce, with large areas completely devoid of vegetation. Sporadic shrubby vegetation was observed outside Al Adabeya port to the west of the site. Vegetation mainly included shrubs.

Fauna

No mammals, birds, reptiles or insects were observed during the visit. Tracks of feral dogs and/or foxes were also observed. Other species expected to occur at the project site include lizards such as Bosc’s Lizard (Acanthodactylus boskianus), passer birds from nearby areas as well as rodents, for example the Lesser Egyptian Gerbil (Gerbillus gerbillus).

4.2.3. Biodiversity Value FLORA

The scattered vegetation outside the site is mostly composed of common species which are widespread in the Eastern Desert. Therefore, clearing of site vegetation will constitute an insignificant impact.

Fauna

Some protected species such as the Egyptian Dabb Lizard, the Cape Hare, Rüppell’s Fox and, possibly, the Dorcas Gazelle (Gazella dorcas) and the Nubian Ibex (Capra ibex nubiana) are reported to be present in the region although they are not present in the storing area due to human disturbing activities.

Ain Sukhna is included among the “Important Bird Areas” (IBAs) of Egypt according to a set of criteria developed by Bird Life International Secretariat. In fact, Ain Sukhna is situated along a major flyway for Palearctic migrant birds. Large birds of prey (passive flyers) concentrate in significant numbers, particularly in spring. Although no systematic counts have been carried out at Ain Sukhna, numerous single-day counts indicate that the area is a bottleneck where over 100,000 large birds of prey may pass through it every year.

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Project location

Tourism area Industrial area

Protectorates Declared marine protected area

Turtle nesting sites Flyway for major bird migrations Most productive fishing ground Coral reefs

Sea grass beds

High potential for navigation hazards

Fig. 4.16. The wealth and natural biodiversity in the area of the Gulf of Suez, including the route of migratory birds (EEAA/DANIDA/Governorate of Suez, 2004)

4.3. Socio-Economic context:

4.3.1. Geographical location: The project area is located at El Adabeya Port which geographically belongs to Suez Governorate. Suez is one of the governorates of Suez Canal Region, located in the east of Delta, north of Suez Gulf by the southern waterway of Suez Canal. The governorate's area reached 9002.21 km2. The governorate's population reached 0.61 million people. Suez

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governorate is bordered in the North by Ismailia, in the North East by North Sinai governorate, in the South by the Red Sea governorate, in the East by Suez Gulf and in the West by Cairo governorate (Figure 4.17). It is one of the four urban governorates of Egypt.

Suez has some natural resources such as: limestone, dolomite, coal and oil. It is also famous for a number of economic activities including: oil distillation, processing and packing of cement, textiles industry, medicine glass bottles, fertilizers and chemicals, shipping and unloading goods, marine services and fishing. The development of northwest of Suez Gulf is one of the mega projects in Egypt.

4.3.2. Population features: Suez Governorate is number 22nd of the governorates of Egypt in terms of population size. It is total population is 607,260 individual according to the 2010 population estimates (Table 4.1). The females comprise about 49.06% of Suez population while the males represent 50.94% of the total population. The population density is 0.07 thousand persons/km2. This population density is much smaller compared to the values of the whole country.

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Figure 4.17: Administrative divisions of Suez and its surroundings.

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Table 4.1: Population features, 2010.

Item Unit Value Total population Thousand Persons 607.26 Average of family members (2006) Person 4.15 Birth rate Live Birth/ Thousand Persons 30.30 Mortality rate Dead Person/ Thousand Persons 5.70 Population natural growth rate Per Thousand Persons 24.60 Population density in the total area Thousand Persons/ km2 0.07

The Suez population is characterized by a large segment of the population below 15 years. The people older than 65 years represent only 2.47% of the total population. This indicates that the families in Suez Governorate are characterized by large number of young families which is emphasized by the values of other cohorts (Table 4.2).

Table 4.2: Age distribution, 2010.

Age group Age distribution (%) Less than 15 31.07882

15 – less than 25 22.0108

25– less than 35 15.72042 35- less than 65 27.71646

More than 65 2.47

4.3.3. Labor force: Suez Governorate has considerably high unemployment rate which is about 15% in 2010 (Table 4.3). It is much higher than unemployment rate of Egypt which was 9.38% and reached 13.4% of the labor force by the end of 2013 according to the reports of the Central Agency for Public Mobilization and Statistics (CAPMAS). This is actually contradicts with the governorates large gross domestic product (GDP) which has always been in the top five governorates of Egypt in the last 10 years. Suez Governorate also has very high Human

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Development Index (HDI) compared to other governorates in Egypt. The governorate ranked the second according the United Nations Development Programme (UNDP) Human Development Report of Egypt in 2010. Therefore, the only reason of high unemployment rate in Suez Governorate in spite of its high economic and development performance must be related to the fact that most of the employed workers in its large and diverse economic activities are not resident in the Suez but coming from other governorates.

Table 4.3. Labor force, 2010.

Labor Parameter Unit Value Total labor force Thousand Persons 175.90 No. of employed persons Thousand Employed 149.00 No. of unemployed persons Thousand Unemployed 26.90 Labor force (% of population) % 28.97 Rate of unemployment % 15.29

4.3.4. Education features: Suez Governorate is characterized by low illiteracy rate compared to Egypt. The illiteracy rate was 17% of individuals older than 10 years which is about half the value for the whole country (Table 4.4). The governorate is ranked the fourth in the highest literacy rate of all governorates of Egypt. Suez Governorate has comparatively better education quality for the pre-university education. According to the government reports and UNDP Human Development Report of Egypt in 2010, Suez Governorate has basic and secondary education enrolment of more than 98%. This is among the highest compared to other governorates of Egypt. It should be noted that these percentages of not only enrolment but also degree holders are very similar for the male and female groups of the Suez population.

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Table 4.4: Literacy, 2010. Literacy Unit Value No. of targeted illiterates Thousand Persons 4.06 No. of enrolled in literacy classes Thousand 6.80 Enrolled (% of targeted illiterates) Persons % 167.71 No. of literates Thousand Persons 3.70 Literates (% of enrolled) % 54.35 Illiteracy rate (10 years+) (2006) % 17.14

4.3.5. Health features: The governmental health infrastructure and facilities belonging in Suez Governorate is not sufficient especially when considering the fast population increase (Table 4.5). The number of hospitals in Suez Governorate is very low considering the size of its population, the presence of large number of industrial facilities and the scale of trade activities as the governorate has four of the most important ports in the country. It should be noted that most of the health services in the governorate is provided by private sector as the governorate has 19 private hospitals.

Table 4.5.: Health infrastructure, 2010.

Parameter Unit Value No. of hospitals of the Ministry of Health Hospital 0 No. of public and central hospitals Hospital 1 No. of specialized hospitals Hospital 3 Hospitals of health insurance authority Hospital 1 Private sector hospitals Hospital 16 Other hospitals Hospital 2 No. of inhabitants per bed Inhabitant/ Bed 434.69 No. of working physicians Physician 414 No. of inhabitants per physician Inhabitant/ Physician 1466.82 No. of working nursing staff Nurse 807 No. of inhabitants per nurse Inhabitant/Nurse 752.49 No. of working dentists Dentist 75 No. of working pharmacists Pharmacist 72

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4.3.6. Sanitary sewage: Suez Governorate has limited problems related to the sufficiency of the sanitary sewage service. More than 90% of the governorate population is connected to the sanitary sewage network (Table 4.6). This situation is much better than most of the governorates of Egypt.

Table 4.6. Sanitary sewage service, 2010.

Parameter Unit Value Capacity of sanitation Thousand m3/ Day 439.30

Per capita sanitation capacity Liter. day/ Person 723.41 % of households with access to % 90.02 sanitation (2006)

4.3.7. Energy supply: The electricity supply is very sufficient as indicated by the number of subscribers in the governorate (Table 4.7). 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 4.7. Energy supply service, 2010.

Energy Indicator Unit Value

Total consumption of electricity: Million k.w.h yearly 1394.05

Electricity consumption for lighting Million k.w.h yearly 479.24

Electricity consumption for industrial utilization Million k.w.h yearly 914.81

Per capita consumption of electricity for lighting k.w.h yearly/ Person 789.18

4.3.8. Potable water supply: The potable water supply is one of the best services present in Suez Governorate. Almost all households have supply to drinking water network (Table 4.8). The per capita quantity of supplied drinking water is more than three times compared to national average (Figures 4.18

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& 4.19). The drinking water supply is also higher than the per capita consumption which significant indication of sufficiency of the water supply in the governorate. The per capita dirking water consumption is much high than the national average. It is actually more than 3.5 time higher the Egyptian average.

Table 4.8. Potable (drinking) water supply, 2010.

Parameter Unit Value Production of potable water Thousand m3/ Day 675.70 Consumption of potable water Thousand m3/ Day 595.00 % of households with access to water (2006) % 99.94 Per capita water consumption Liter.day/ Person 979.81 Per capita water production Liter.day/ Person 1112.70

Figure 4.18. Per capita potable water production (2007-2009)

4.3.9. Description of the area surrounding the storage site: Attaqa district contains the locations of the El-Adabeya port where the Lindane storage site is found. It is the largest of the four districts of Suez Governorate in terms of surface area which is about 8827.88 km2 representing 89% of the total surface area of the governorate. However, it represents only 19% of the governorate population size. It has, therefore, one of the lowest population densities in Suez. Most of the residential areas in Attaqa district are

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unlicensed low quality buildings. This is reflected in the limited residential areas located in the vicinity of the Lindane storage site. Even though, the closest area is more than 1 km away from the storage site. It is characterized by the presence of scattered houses which are characterized by very low population density. Nevertheless, the area subjected to several problems related to the low availability of many services particularly those related to health care (State Information Service, 2011).

Figure 4.19. Per capita potable water consumption (Liter. Day/person) (2007-2009)

Attaqa district is one of the largest industrial areas not only in the Suez governorate but also in Egypt in general. It has more than 15 food industrial facilities working with activities such as preparation and packing of food products. Some of these industrial facilities such as Savola are located very close to the Lindane storage facilities in El-Adabeya port. This would increase the need for the disposal of the pesticide using the most cautious approaches to avoid any releases that could reach these sensitive facilities working with food production for human consumption. There also more than chemical industrial facilities located in Attaqa district with a number of these facilities located in the area surrounding the storage site. The district contains also 28 industrial facilities for metal industries such as the production of spare parts and metal structures for automobiles in addition to appliances factories. The area surrounding the storage site is also known to have cement, petroleum and petrochemical industrial facilities. The district has the largest power generation plant in the

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governorate in terms of production, fuel use and emissions of pollutants. Accordingly, Attaqa is considered one of the most polluted districts in Suez Governorate. This is manifested in the comparatively high value of most air pollutants particularly nitrogen oxides, suspended particulate or PM10 exceeding the allowed limits.

The low quality of healthcare services in addition to the high levels of pollutants would subject not only the inhabitants but all those working in the area. It would increase the sensitivity of the situation of the workers in the Lindane storage who have additional factor related to the impacts of Lindane exposures. However, it is worth noting that most of the workers in Lindane site have their permanent residency outside Attaqa district. Nevertheless, the significant period which they spend in the site would contribute significantly to exposure to the high levels of pollutants recorded in Attaqa district.

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4.4 Radiometric survey of obsolete lindane containers

Based on the preliminary examination and radiometric survey for the ten containers of obsolete pesticide (lindare) stored in “Al Adabeya area-Suez Port” on Wednesday 18/6/2014, the Scientific consulting team (authorized experts in radiation field) from the Radiation Physics Laboratory, Physics Department, Faculty of Science, Alexandria University (Annex 7 &8).

All the investigated containers consist of powder material (lindane) in paper sacks packed in other plastic bags. The bags take a label on each one “Synexa 25 H.C.H 3% Isomere Gamma Procida Net 25 kg” and there are no details about the origin, manufactory, production date,… etc. All containers are in a good order from outside and each one has a serial number.

Project location A C GSTU284426/4 XTRU208051/1 GSTU590988/3 GSTU230845/1 B D E GATU015560/8 EACU417206/2 GSTU230867/8 MAEU286369/3 MAEU293609/0 TEXU324762/6

By using the survey meter “Rad Eye G-10”, which is a sensitive instrument for radiation measurements and used to measure the exposure radiation doses in the background area and around each container before the opening and after the opening process at certain selected positions (A, B, C, D, E and F) on the container surface. A, is the front container position and F, is the back container position, while B, C, D and E, are the two side container positions as shown in the diagram above. The background radiation dose rate is found to be [0.08 μSv/h] in the surrounding areas. The readings on the surface of each container in (μSv/h) are given in the next table.

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Radiation Dose Rate (μSv/h) After Serial Number A B C D E F Opening (μSv/h) 1 GSTU284426/4 0.09 0.09 0.09 0.09 0.09 0.09 0.15 2 GSTU590988/3 0.10 0.11 0.11 0.10 0.11 0.11 0.11 3 GATU015560/8 0.13 0.13 0.13 0.15 0.14 0.14 0.13 4 GSTU230867/8 0.08 0.08 0.09 0.08 0.09 0.10 0.16 5 MAEU293609/0 0.14 0.11 0.12 0.14 0.14 0.14 0.14 6 XTRU208051/1 0.11 0.10 0.12 0.12 0.11 0.12 0.10 7 GSTU230845/1 0.14 0.13 0.13 0.14 0.15 0.15 0.11 8 EACU417206/2 0.10 0.11 0.11 0.10 0.10 0.10 0.15 9 MAEU286369/3 0.20 0.29 0.22 0.28 0.08 0.09 0.30 10 TEXU324762/6 0.10 0.08 0.08 0.09 0.09 0.08 0.11

The Scientific consulting team collected sample (about, 200 gm) from each container and will keep it in a closed bottle till reach the radioactivity equilibrium, 28 days, then high resolution HPGe detector will be used to make a quantitative and qualitative analysis to know the radioactive elements and their concentrations, if any. The team has an initial conclusion till the final analysis by HPGe detector is made available.

Conclusion:

This conclusion confirms the results that have been drawn by the team of the Chemical Weapon Sector of the Ministry of Defence in its radioactive survey that has been done in 2013.

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4.5. Inspection of the condition of containers by COMIBASSL

In order to avoid damage during shipment of obsolete lindane containers, the container should, however, be properly inspected. Comibassl International has been inquired to carry out full inspection to ensure that the containers are suitable for carrying this shipment.

The condition of the containers has been visually verified by surveyors of COMIBASSL and found to be structurally sound and suitable for carrying shipment of lindane. The complete report of Comibassl International is attached with this report ( Annex 9).

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CHAPTER V ENVIRONMENTAL AND SOCIAL IMPACTS

5.1. Introduction Since the introduction of chemical pesticides in the 1940s and 1950s to control disease and crop production, they have also caused many, varied and widespread adverse impacts on human health and the environment. Examples of these adverse impacts include death and disability among pesticide users and the communities around them, global transport and bio-accumulation of pesticides, contamination of local water supplies and loss of income to farmers whose produce contains unacceptable levels of pesticide residues.

Improved understanding of the health and environmental hazards associated with pesticides has led to the development of sophisticated regulatory and control systems designed to control pesticide trade, management and use. Examples include the Rotterdam and Stockholm Conventions, the International Code of Conduct on the Distribution and Use of Pesticides and the Organization for Economic Cooperation and Development (OECD) Pesticides Working Group. Further many other mechanisms designed to address chemical management include pesticides among their concerns.

Nevertheless, the problems caused by pesticide mismanagement persist with particularly powerful impacts in developing countries. Where agriculture is the mainstay of the economy, pesticides constitute the majority of chemicals in use. The infrastructure controlling and managing pesticides throughout their life-cycle are often weak and under resourced, and the end users of pesticides are usually untrained and poorly equipped to use them safely. As a result, 99 percent of the estimated three million people poisoned by pesticides each year are in poor countries and the most serious and persistent problems associated with environmental contamination from pesticides are also in the developing world.

Mismanagement has also led to the gradual creation of problems that appear to be unsolved such as the accumulation of vast quantities of pesticides that have become

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unusable over the years, and contamination from pesticides that cannot be removed from the environment.

Stockpiles of obsolete pesticides (OP) are often in a severely deteriorated condition, poorly stored and located close to habitation or water supplies, and thus represent a serious risk to human health, ground and surface water, land use, and the environment in general. The impact is often greatest on the poor as abandoned pesticide stockpiles and dumps tend to be located in poorer communities where people scavenge for “recyclables” with no awareness of the dangers involved.

5.2 Obsolete Pesticides (lindane in Al Adabeya Port) According to the inventory carried out for the lindane stockpile temporary stored at Al Adabeya Port since 1998, about 220 tons of obsolete lindane is packed in 25 kg heavy paper bags supported by an outer plastic wrapping bags (880 bags) stored in 10 standard 20 feet containers. The stockpile is classified high risk based on toxicity, quantity, surrounding environmental conditions and the security of the store. The categorization of the site followed the FAO Environmental Management Toolkit in which Environmental Factor (Fe) values higher than 50 have been considered problematic (as it will be discussed in details later on of this chapter). A criterion related to the risk posed by the type and quantity of the OP (Fp) was also used whereby a value of above 50,000 was considered to be a high risk factor. In addition to the WHO class, the condition of the packaging and whether the active ingredient is known was considered during the evaluation. The overall obsolete lindane disposal plan has three main components of safeguarding, transferring to a temporary storage area to the vicinity of the ships (gate of exit) and finally loading onto a ship to the shipping port to the disposal facility.

Therefore, the environmental and social impacts analysis will cover two main phases that is as per existing stockpile conditions and during the safeguarding and disposal operation.

5.3 Impacts as per existing conditions of the lindane stockpile

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In order to establish environmental and social impacts, the lindane stockpile at Al Adabya Port was visited. This section dwells on environmental and social impacts from the site considering only the currently prevailing conditions.

5.3.1 Environmental Impacts

The site is located at the extreme southern part of Al Adabeya Port near the outer fence of the port, which is parallel to the Cairo-Suez high way and Gabel Ataqa about 17 Km from the City of Suez. The site area is flat, paved and occupying an area of 5,850 square meters (225 x 26 m). This area belongs to the General Company for Silos & Storage (GCSS).

The site of the stockpiling of obsolete lindane visited is in very good condition in terms of the paved ground and the location relative to the activities in the port. In terms of security, the site, where the stockpile is located, is completely fenced. The 10 lindane containers are safely stacked on the paved ground. In each container, the obsolete lindane bags are stacked in such a way that the upper one third of the container is free. Most of the containers were sealed intact, while each of the 10 containers contains one or two damaged bags which are not efficiently sealed or repacked and kept haphazardly due to the opening during previous sampling activities carried out by the Chemical Weapon Sector and the Egyptian Atomic and Energy Authority (EAEA), thus giving a bad smell (Fig. 5.1).

A storekeeper assigned by Al Adabya Port Authority manages the store regularly checks the lindane containers at least once per week. The guard or security is provided almost 24 hours a day. In terms of safety, no fire safety equipment was visible neither were the first aid kits or PPE for the storekeeper to use, except at the shaded store to the vicinity of the stockpile (230 m), which is belonging to the General Company for Silos & Storage (GCSS).

Environmental assessment was carried out to cover potential impacts of the obsolete lindane stockpile in Al Adabeya Port on the environment. The assessment was carried out in three main steps, as follows:

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1. Identification of potential impacts

2. Evaluation and assessment of the impacts in terms of their significance

3. Identification/ proposing mitigation measures for minimizing the affects of the significant impacts (described in Chapter VII).

5.3.2 Identification of Potential Environmental Impacts Potential impacts of the obsolete lindane stockpile in Al Adabeya Port are identified during the current situation of the storage of the 10 containers and during the safeguarding activities. The resources and receptors susceptible to impacts categorized as physical, biological and socio-economic environment. Identified resources and/or receptors were:

• Air quality • Noise level • Soil • Marine water quality • Surface and Groundwater quality • Aquatic life • Terrestrial life • Public health • Employment • Workplace health and safety 5.3.2. Evaluation and Assessment of Impacts Interaction between the different activities and the environmental receptors, identified through the baseline information, was carried out.

Based on the analysis of the baseline environmental conditions and the nature of the receiving environment, some aspects were found to be irrelevant to specific activities of this particular project. These are identified as "scoped out impacts ”Potential impacts were subject to a process of impact evaluation, based on the analysis of the proposed project components and activities, in order to determine the significance of the different impacts. The evaluation process takes into account the information

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collected in the field, available in the literature and/or based on the professional judgment of the consulting team, public consultation as well as environmental modeling activities.

Impact evaluation is based on pre-set criteria including, impact magnitude, duration, built in mitigation measures, regulatory standards and sensitivity of environmental receptors.

5.3.3. Mitigation Measures Mitigation measures are incorporated through environmental management and monitoring measures. By implementing the mitigation measures, the residual impacts, which are those potentially remaining after implementing the mitigation measures, will be minimal/insignificant/ acceptable. Based on the impact identification and evaluation process, Irrelevant impacts are scoped out of the assessment process, mitigation measures are proposed for significant impacts.

5.3.4. Impact Identification Scoped out Impacts Potential impacts in the Leopold matrix were identified in relation to the effects on potential receptors. This step would facilitate eliminating and scoping out irrelevant impacts taking into consideration the following:

- Location - Characteristics of the surrounding environment. - Receptor sensitivity or importance: depends on its nature, value, scarcity etc. There are three types of receptors: • On site receptors encompassing soil and workplace. • Receptors surrounding the site such as ambient air, humans, plants and animals. • Final sinks/receptors such as surface and groundwater. Examination of the environmental setting of the area has shown that the following impacts are irrelevant: Impacts on “surface and groundwater”.

 Referring to the results of the Site Survey (Annex 10: Form 2: Inventory of pesticides

in store and calculation of FP) and (Annex 11: Form A3: Questionnaire and calculation

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of FE), the different activities related to obsolete lindane stockpile in Al Adabeya Port will have no contact with surface and groundwater.

5.4. Potential Negative Impacts After exclusion of the irrelevant impacts, the remaining “potential negative impacts” were assessed based on the following criteria: - Magnitude of the impact. - Duration: period of time that impact lasts. - Mitigation measures; implemented as management measures. - Adherence to regulatory standards according to Egyptian legal and regulatory framework (described in Chapter II). - Public concern and perception 5.4.1. Potential Negative Impacts During Storage The main negative impacts will be on workers due to inhalation gases that are released by the obsolete lindane. This is mainly due to the fact that some of the pre opened bags are not sealed intact and an odor or faint smell is felt around the vicinity of the containers especially when doors are open.

Table 5.1 presents a summary of the information on risk category, conditions of obsolete lindane and the stockpile surroundings, and impacts from the different categories of the stockpile discussed in preceding text.

Table 5.1aSummary of environmental and social impacts Obsolete Risk Condition of Potential Potential Lindane Category Pesticides environmental health Stockpile & impacts impacts Surroundings Al Adabeya High Remarkable Nuisance Respiratory (problematic stockpile) smell diseases

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Figure 5.1. Damaged bags due to the opening during previous sampling activities

5.4.2. Potential Negative Impacts During Safeguarding Activities

A variety of environmental and social impacts are likely to occur during safeguarding, transportation and final disposal of the obsolete lindane stockpile at Al Adabeya port. These are appropriately listed in Table and presented in Chapter Seven.

Table 5.1b: Impacts during safeguarding, transportation and disposal

Activity Main impact Verification  Health of operators due to contact with lindane / Public health Repackaging  Health of operators due to contact with lindane  Air pollution due to a fire  Contamination of soil and groundwater due to spill  Air contamination due to release into air Road transportation  Soil and water contamination due to an accident inside the port  Air pollution due to an accident Storage at a temporary  Soil and marine water pollution due to spill storage area to the  Air pollution due to a fire vicinity of the ships Transportation by Sea  Marine pollution due to sinking of containers or ships Disposal  Air, water and soil pollution

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5.5. Socio-economic and health impacts: The impacts presented below are combined from the results of the socio-economic survey as expressed by all stakeholders and derived by the project team from the public consultations, site visits and analysis of the project activities. It should be noted that these impacts would be limited to workers in the storage site with very limited impacts, if any, on the general public. It is mainly because there are no urban agglomerations or any other types of settlement close enough to the project’s site to be subjected to the impacts of its proposed activities as described by the risk analysis and simulation for the worst case scenario. The nearest significant urban site is about 6.5 km North Northeast to the project site which is in the directions of the upwind side (Figure 5.4). There is a very small number of scatter houses about 1.36 km in the North Northwest of the project’s site (Figure 5.4). They are also outside the impact area as shown by the risk simulation.

5.5.1. Positive impact: 5.5.1.1. Health impact:

. Eliminate the risks of environmental pollution that would occur from the existence of these pesticides containers . Eliminate the health impacts of the exposure to this pesticide especially on the workers at the site. . Improve the work conditions at the site and reduce the occupational health hazards on the workers at the site. . Get rid of the nuisance effects such as the repulsive smell spreading around the site of the Lindane containers. . Avoid the chances of health hazards that could occur because due to any spills or accidents related to the Lindane containers such as fires which could spread the impacts of the Lindane to wider area affecting the surrounding industries and storage hangers in the port especially that most of these industries are food industries and El-Adabeya Port is one of the main port of importing materials for food industries.

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. Reduce the impacts on the natural environment especially that since the arrival of these containers birds and other animals were not noticed in the site. Some stakeholders actually observed dead dogs, rats and birds in the vicinity of the containers 5.5.1.2. Socio-economic impact:

. Eliminate the probability of the illegal use of these pesticides in the country because as long as they exist there could be a possibility of trafficking them outside the port especially that the agricultural activities in Suez Governorate are increasing rapidly. . Eliminate the chances of crop contamination that could occur by the use of these pesticides. . Eliminate the financial loss of not paying the rent of the space occupied by the containers and the safety distance surrounding them, as there is no rent paid for the container occupied space since late 1990’s which is estimated by more than 7,000,000 L.E. . Use the space for other purposes which would generate more revenues for GCSS. . Increase the sense of security for the workers in their working environment. . Reduce the financial loss for GCSS as many client refuse to store their shipments in the site. This also has implications for the workers who complained that the work activity in the site decrease significantly as the news of the presence of Lindane containers spread in the port. . Improve the knowledge and experience of the stakeholders in dealing with similar situation. . Set an example for the concerned authorities so they can deal better with handling similar situations in other places in the country. . Stimulate the political well to take more stringent measure to avoid the occurrence of similar situation. 5.5.2.. Negative impact: The negative impacts were expressed by very limited number of stakeholders:

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. Increase emissions from the Lindane packs during the processes of their loading which would increase the health impacts on the site workers. . Increase accidents risks during their transportation from the storage site to the shipping pier and vessel which would represent increased risks on the port’s workers and the surrounding environment. . The activities in the storage site would be limited as results of the project activities especially during the repacking phase which would incur GCSS economic losses.

5.6. Impacts on natural habitats

Surveys have shown that areas in vicinity of the obsolete lindane stockpile have already been disturbed by human activities and lack to natural habitats status. Therefore, this project will not trigger OP 4.

Impact of the lindane storage site on the route of migratory birds can be explained by zooming in the regional map showing these routes (Figures 5.2 and 5.3). This map shows that the distance between the lindane storage site and the nearest point on nearest eastern route is about 9.781 km which far exceeding the 88.415 m distance resulting from the air dispersion model for lindane concentration of 5 µg/m3, which will be indicated at the end of this chapter, and also exceeding the distance of 5552.576 m for the lowest safe lindane concentration of 0.008 ng/m3 as shown, respectively, by yellow contour line and green plume in Figure 5.28. Thus, the lindane storage site has no impact on the bird species migrating along the eastern route crossing the Sukhna area.

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Fig. 5.2 Map showing the location the lindane storage site relative to the nearest point on nearest eastern route of migratory birds (9.781 km).

Fig. 5.3 Map showing the Interpolation of the Lindane concentration in the air samples a maximum distance of about 88 m.

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Figure 5.4 . The distance from the storage site to the nearest residential area in Suez Governorate.

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Figure 5.5. The distance from the storage site to the nearest residential area in Suez Governorate.

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5.7. Environmental risk Analysis

5.7.1. Introduction The U.S. Environmental Protection Agency (USEPA) defines risk assessment as a qualitative or quantitative evaluation of the risk posed to human health and the environment due to the actual or potential presence of pollutants. Risk assessment involves the characterization of the nature, magnitude and likelihood of adverse effects on human health or ecosystems as a result of exposure to pollutants through various pathways.

Environmental risk assessments typically fall into one of two areas:  Human health risk assessments: the process of estimating the nature and probability of adverse health effects in humans who may be exposed to chemicals in contaminated environmental media, immediately or in the future  Ecological risk assessments: the process of evaluating how likely it is that the environment may suffer adverse impacts as a result of exposure to one or more environmental stressors such as chemicals, changes in land use, disease, invasive species or climate change

Risk assessment is a scientific process with risk depending on the following three components:  Contaminant: a substance with the potential to cause serious effects on an organism, ecosystem or environment  Exposure pathway: a route or series of routes or means by which a receptor can be exposed to a contaminant  Receptor: an individual or an ecological system that could be adversely affected by a contaminant

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Figure 5.6 Environmental risk components

Figure 5.6 illustrates environmental risk as the overlapping region between contaminants, exposure pathways and receptors. Risk is expressed as the probability that the three components will overlap. If a risk is found to be probable, effects resulting from exposure may be eliminated by reducing the concentration of the contaminants to an acceptable level. Lindane is an Organo-chlorine insecticide and fumigant which has been used on a wide range of soil-dwelling and plant-eating (phytophagous) insects. It is commonly used on a wide variety of crops, in warehouses, in public health to control insect-borne diseases, and (with fungicides) as a seed treatment. Lindane is also presently used in lotions, creams, and shampoos for the control of lice and mites (scabies) in humans.

Technical Lindane is comprised of the gamma-isomer of hexachlorocyclohexane, HCH. Five other isomers (molecules with a unique structural arrangement, but identical chemical formulas) of HCH are commonly found in technical lindane, but the gamma- isomer is the predominant one, comprising at least 99% of the mixture of isomers. Lindane may also be found in formulations with a host of fungicides and insecticides. It is available as a suspension, emulsifiable concentrate, fumigant, seed treatment, wettable and dustable powder, and ultra low volume (ULV) liquid.

Lindane is a moderately toxic compound in EPA toxicity class II. Labels for products containing it must bear the Signal Word WARNING.

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Some formulations of Lindane are classified as Restricted Use Pesticides (RUP), and as such may only be purchased and used by certified pesticide applicators.

Lindane is no longer manufactured in the U.S., and most agricultural and dairy uses have been cancelled by the EPA because of concerns about the compound's potential to cause cancer.

Stocks of obsolete, unwanted and banned pesticides (Lindane) represent a serious public health and environmental threat. Food and Agriculture Organization (FAO) supports national management teams in establishing strategies for completing national assessments of obsolete pesticides that result in the environmentally sound management and final disposal of the pesticides. The Environmental Management Tool Kit (EMTK) forms an integral component of that technical support. It is part of a series of guidelines and systems designed to assist countries in assessing the scope of the obsolete pesticides problem and implementing effective prevention and disposal. For ease of application, EMTK is presented in three volumes: Volume 1 focuses on issues related to inventory and the prioritization of stores based on environmental risk; Volume 2 focuses on the selection and management of stores and collection centers and the transport of waste pesticides to these points; and Volume 3 focuses on the development of country environmental assessments and environmental management plan (EMPs). The three volumes of EMTK can be used as a planning system to assist governments and cooperation agencies in planning all the steps of a disposal programme for obsolete pesticides that may have an adverse impact on the environment and the health of the general public. The tools aim to: • Provide better knowledge about the fundamentals of environmental management planning associated with the inventory, storage and transportation of obsolete, unwanted and banned pesticides;

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• Increase project teams’ awareness of the public health and environmental risks from obsolete pesticides; • Improve protection of the public and the environment from the hazards posed by obsolete pesticides by facilitating the implementation of risk assessment, control and mitigation strategies through step-by-step guidelines; • Provide project administrators with the outputs necessary to develop integrated and standardized procedures that protect both human health and the environment.

5.7.2. Problem formulation The problem formulation process, which defines the objectives and scope of the risk assessment, is based on the three environmental risk components — contaminants, exposure and receptors. It specifies the issues that must be evaluated. The parameters to be identified include:  identification of contaminants of concern  identification of potential receptors

 identification of exposure pathways

Identification of Contaminants of concern It is estimated that about 220 tons of obsolete POPs pesticides, including Lindane, has been stored at the Al Adabeya port since 1998. These obsolete stockpiles are packed in 25 kg plastic bags supported by a heavy paper outer wrapping and stored in 10 standard 20 feet containers occupying an area of 5,850 square meters (225 x 26 m).

Identification of Exposure Pathways An exposure pathway is the link between the contaminant source and receptor. During the formulation of the problem, all the media (i.e., groundwater, soil, surface water, sediments, air and biota) should be considered. The means of exposure include:

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 Inhalation directly or after ingestion through drinking water or food,  Dermal adsorption through skin. It should be noted that these mechanisms can occur directly or after modification in the environment, e.g., biological uptake by plants, dissolution in water.

Identification of receptors Receptors can be identified from a review of the fate, transportation and potential release of contaminants. Receptors can be individual organisms, groups, or communities that are exposed to a contaminant.

The end-product is a conceptual model that includes sources of contaminants, routes of transport, contaminant media, routes of exposure, and endpoint receptors (USEPA, 1997).

Table 5.3 contains a typical checklist (Health Canada, 2004a) that can be used to identify land use, receptors and exposure pathways for the storage site.

Table 5.3: Problem formulation checklist Receptor Group Exposure Pathways Land Uses (s) Agricultural Employees (on √ Soil ingestion Residential/urban site workers) Soil dermal parkland absorption Commercial with General/ public √ Particulate √ √ daycare /Critical inhalation Commercial Receptors Vapor inhalation √ without daycare (Infant, Toddler, Industrial √ Child, Teen, Groundwater Adult) ingestion Other (specify) Other (specify) Water dermal absorption Produce ingestion Fish ingestion Wild game ingestion Other (specify)

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5.7.3. Site Investigations/Survey/observations A site investigation visit/survey was carried out by a Multi-disciplinary Experts to establish the Environmental and Social Impact Assessment (ESIA) for the Disposal of Obsolete Pesticide Stockpile from Al Adabeya Port (Figs 5.7 - 5.12) Based on interviews/meetings and site survey, a detailed site plan and map were available.

Figure 5.7. The Multi-disciplinary Experts interview with EEAA & Al-Adabeya Port representatives

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Usage and activities of site and adjacent areas

A Stockpile of 10 Containers of Obsolete Lindane Pesticide

Figure 5.8. The Storage area (an open Yard)

Figure 5.9. Fence surrounds the Storage area (an open Yard)

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Figure 5.10. A Stockpile of 10 Containers of Obsolete Lindane Pesticide

Figure 5.11. Signs/Labels on the 10 Containers of Obsolete Lindane Pesticide

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Figure 5.12. Site Investigations/Survey Current use of site and the surrounding area It is estimated that about 220 tons of obsolete Lindane pesticides, has been stored at the Al-Adabeya port since 1998. These obsolete stockpiles are packed in 25 kg plastic bags supported by a heavy paper outer wrapping and stored in 10 standard 20 feet containers occupying an area of 5,850 square meters (225 x 26 m). The storage is in an open yard. The total amount of obsolete and POPs pesticides irrespective to their functional groups reaches up to 220 tones including Lindane, excluding soil and waste. Detailed inventory is attached and all the containers have been inspected.

The storage is an open yard designed for temporary storage of shipped goods. The yard is surrounded by a good quality fence. The yard has two gates one of them (at the NE corner of the yard) is the emergency gate. Pesticides can be smelled in the vicinity of the containers. The way the pesticides are stored is illustrated in Figure 5.8.

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5.7.4. The suggested transport route inside the port The transport route has been assessed and selected as the safest and most direct.

Figure 5.13: The suggested transport route inside the port between the current site of the containers of obsolete lindane and the recommended temporary storage area on the gate of shipment. 5.7.5. Environmental Risk Assessment Conceptual Site Model The following basic questions were answered when preparing the model:  What are the contaminants on the site and what is their concentration?  Is it possible for the contaminants to come into contact with site users? How?  Who are the site users?

Based on the site survey the following tasks were achieved:  a qualitative evaluation of contaminant release and its transport  identification of contaminants of concern  identification of potential receptors  identification of exposure pathways

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Figure 5.12 illustrates a conceptual model that includes sources of contaminants, routes of transport, contaminant media, routes of exposure, and endpoint receptors (USEPA, 1997).

Source of Risk Vapors & Particulates

Exposure Pathways Dermal / inhalation

Figure 5.14. Environmental Risk Assessment Conceptual Site Model

5.7.6. The Risk Assessment of Obsolete Pesticides Environmental Risk Assessment (ERA) of obsolete pesticides is just one of many steps in an effective management cycle. It is a critical stage in the overall project design process. Without accurate inventory and data, it will not be possible to plan any subsequent safeguarding and disposal activities.

Tool A: Environmental Risk Assessment This tool utilizes the data collected via the FAO standard inventory data collection forms developed for use with the FAO Pesticide Stock Management System (PSMS), the tool also requires that data be collected to facilitate appraisal of the environmental and public health risks associated with each obsolete pesticide storage location. It includes an easy-to-use questionnaire for gathering information that is relevant and as objective as possible from each store. In association with tool B, tool A also allows the user to rank and prioritize stores according to their levels of risk, and to characterize the situation prevailing in each store as lower-priority, problematic or critical. FAO finalized the model proposed in this tool after extensive field tests in several countries. The tool is based on the risk assessment associated with the chemicals

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(pesticides), the physical and management conditions of the store, and the environmental conditions prevailing in and at the store. Field trials have shown the methodology to be robust, easily understood and easy to use.

Tool A: Methodology The basic assumption of this tool is that it is possible to gather – easily and rapidly – the essential information for appraising the environmental and public health risks associated with any stock of obsolete pesticides and identifying the stores with the worst conditions in terms of current or potential impacts on public health and/or the environment. The aim of the tool is to gather sufficient information to provide decision-makers, experts, project managers and planners with the data necessary for: • Ranking the stores and characterizing the situation in each according to simple environmental and public health risk criteria; The more pesticides contained in a store, the more toxic those pesticides are and/or the worse the condition of the packaging materials in terms of leakage, the higher the associated risk.

This tool can be applied to calculate the Risk FactorFP, which represents the risk related to conditions associated with the pesticides (i.e., the conditions

prevailing inside the store). FP has a linear progression; the greater the value

of FP, the higher the associated risk. • Ranking the stores according to the conditions of each store structure and to the storage conditions inside and the environmental conditions outside the store; The worse the conditions associated with the store structure and the greater the store’s relationship with or proximity to critical areas, the higher the risk or potential risk to public health and the environment in case of an accident at the store.

The Risk Factor FE is calculated for each store, based on the results of a simple questionnaire completed for each location.

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• Characterizing the general situation prevailing in each store by combining the

two risk factors FP and FEand plotting them on a single graph, divided into four quadrants: This provides a comparative analysis based on the sample population of stores included in the survey. Depending on the position of a store on the graph, the situation prevailing in that store relative to the other stores in the survey can

be characterized as lower-priority, problematic (when either FPor FE is high) or

critical (when both FPand FE have high values).

Description of the tool Figure 5.15 represents the structure of tool A which includes step-by-step guidelines for calculating the risk factors, explanation boxes, and the following three forms:

• Form A1 Helps the user to gather basic information on the store and its location: region, district, name, etc. If possible, the store’s map coordinates and altitude should be precisely recorded, using a global positioning system (GPS) device in association with a Geographic Information System (GIS), which locates a store precisely on a map and provides relevant environmental information. The form also guides the collection of data related to: the structure of the store (roof, walls, floor, ventilation); and the management and organization of the store (security, safety and management procedures).

• Form A2

Aims to calculate FP by collecting information about the pesticides located at or inside the store(s), including the quantity, the World Health Organization (WHO) toxicity class and the packaging conditions of each pesticide.

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• Form A3 Guides the collection of information on the environment around the store, including proximity to human settlements, water sources, agricultural and livestock activities, wildlife and biodiversity. Information on the structure of the store is important because the store constitutes a physical barrier that may contain a potential pollution incident. Storage conditions are also important because proper management can significantly reduce the level of risk. Information on conditions outside the store allows assessment of the impact of a potential release of obsolete pesticides into the environment. Tool A: Collecting information and calculating the risk factors for each site

Form A1 Form A2 Form A3

General Information on Information information the store and on pesticides on the site the environment

Calculation Calculation

of FP of FE

Each site is characterized

by a pair (FE; FE)

To be used in

Tool B: Characterizing and prioritizing the sites

Figure 5.15: Structure of tool A

5.7.7. Calculating the risk factors FP and FE

• Step 1: calculating FP (see Box A1, use Form A2)  List all the pesticides contained in the store (Annex 12: Pesticide Form), ONLY Lindane).  For each pesticide, note the WHO toxicity class (of the formula, not the active ingredient):Class II pesticides; Moderately Hazardous.

 Assess the conditions of the containers and calculate a score, SP.

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 Calculate FP as the sum of all the SP scores calculated for the individual pesticides in the store.

For each pesticide encountered in a store: (ONLY Lindane), a score SP is calculated.

SP = (3ST + SC) x Q Where:

(3ST + SC) is a risk coefficient dependent on the Toxicity (ST) of the pesticide and the

Conditions (SC) of the containers in which it is stored.

 ST is a toxicity score that depends on the WHO toxicity class of the pesticide:

ST is 1 for class U pesticides; 2 for class III pesticides; 4 for class II pesticides (Lindane); 8 for class Ib pesticides; and 16 for class Ia pesticides.

 SC reflects the condition of the containers: SC is 1 if none of the containers are damaged; 8 if fewer than 50 percent of them are damaged; and 16 if more than 50 percent are damaged.  Q is the quantity of the pesticide in the store, and is measured in kilograms irrespective of the physical state of the pesticide (liquid or solid), for the purposes of the calculation, it is assumed that all pesticides have a specific density of 1. The total quantity of Lindane is (220 tons = 220,000 kg) packed in 25 kg plastic bags supported by heavy paper outer wrapping and stored in standard 20 feet container occupying an area of 5850 m2 (225 X 26 m)

SP = (3ST + SC) x Q

SP = (3 X 4 + 1) x 220,000

SP = (12+1) X 220,000

SP = 2,860,000

The risk factor FP is the sum of all the SP scores.

In theory, FP can reach any value because it depends on the quantity of pesticides stored.

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Then the risk factor FP = 2,860,000

Annex 10: Results of the Site Survey

(Form 2: Inventory of pesticides in store and calculation of FP)

• Step 2: calculating FE (see Box A2, use Form A3)  Fill in the environmental and public health risk questionnaire (Box A2).  For each question, apply a score 0 or 1 as indicated in the questionnaire.  Multiply all the scores by the appropriate weighting factor.

 Calculate FEas the sum of all the weighted scores.

Annex 11: Results of the Site Survey

(Form A3: Questionnaire and calculation of FE)

5.7.8. Calculation of FP and FE when there are several stores at the same site

By using tool A it is possible to characterize each store with two risk factors, FP and FE. For both factors, the higher the value, the higher the risk associated with the pesticide

(as represented by FP) and the environment (as represented by FE) posed by the store.

Tool B: Prioritization of Stores Tool B helps government agencies and project management teams interpret the data collected by tool A to identify the most dangerous stores. Tool B facilitates analysis of all available data to identify a group of stores that should be considered as critical and that pose the greatest immediate threat to public health and the environment.

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Objectives of the tool B The main objective of tool B is to identify clearly the stores that pose a comparatively high level of risk to the general public and the environment. It aims to provide a methodology for recognizing the most critical stores and prioritizing them based on risk. The net result will be the development of a justified work plan based on sequential minimization of the risk posed by obsolete pesticides at the national level.

A simple process must be used to identify the critical stores. It should be remembered that the process detailed in the following is based on a comparative analysis of all the stores in a country. The tool does not provide an absolute scale for the risk factor associated with the

pesticides (FP), because the stocks can theoretically be of any quantity. The tool does provide a means of comparing all the stores in a country or region and allows country teams to divide them into the following broad categories (Fig. 5.16):

100

Problematic Critical

Fp* 50 Lower-priority Problematic

0 50 100 FE

Figure 5.16: Store prioritization based on a graphic approach

• Critical stores: are stores with high scores for both FP and FE. These stores contain chemicals that belong to the most hazardous WHO classes and/or are stored in large quantities and/or are badly packaged or in packages that

are leaking (resulting in a high value for FP).

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In addition, the containment offered by stores in this category would result in a serious

impact for the environment or the general public (a high FE). These stores must be considered to be of very high priority in any remediation strategy. All stores that plot in this quadrant should be studied and the reasons for their high risk factors clearly defined (large quantity, high toxicity, near water sources, poor storage construction, etc.).

• Problematic stores: are those with a high score for either FP or FE. The data relating to these stores should be studied in detail to determine what factors

make them a relatively high risk for either FP or FE. Based on these factors (the reasons for a high risk factor), the project management team must decide the relative importance of each store. The risk of an immediate incident at one of these stores may make that store a high priority, requiring it to be addressed as a matter of urgency.

• Lower-priority stores: are stores with low scores for FP and FE. These stores present less risk for the environment and human health than stores in the other categories. Stores can be considered as lower priority when the impact on public health and/or the environment is low. Typically this is because the stores: − contain smaller quantities of less hazardous pesticides that are generally well packed; − are located in more favorable environments.

5.7.9. Calculating FP*

For each store, FP has been calculated using tool A: FP is the sum of all the scores SP,

Where SP = (3ST + SC) x Q

The Pesticide (Lindane) Risk Factor FP = 2,860,000

In theory, FP can reach any value because it depends on the quantities of pesticides stored.

However, it is more practical to frame the value of the risk factor from 0 to 100.

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This can be done easily by attributing to the highest FP score, max.[FP], a value of 100

and recalculating FP for all the other stores in the data set to give values of FP* as follows:

FP* = (FP/max. [FP]) X 100

As there is ONLY ONE pesticide type (Lindane) with only one (FP = 2,860,000),

The FP* = 100 The store for which FP* > 50 should be considered problematic or critical owing to the pesticides they contain: high toxicity pesticides, damaged containers and/or large quantities of pesticides.

From tool A, The Risk Factor (FE): 18 (from 0 to 100)

The store for which FE> 50 should also be considered problematic owing to the conditions of the store, packaging and/or the environment.

From Figure 5.16 which represents the store prioritization based on a graphic approach

Conclusion:

Referring to the FP (2,860,000), FP* = 100 and FE (18), the Al-Adabeya Port (Store) is considered as (problematic) store/site.

Figures from 5.17 to 5.20 show the satellite imges and GIS layout of Al Adabeya Port together with the land use map of the port.

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Figures from 5.17 to 5.20 show the satellite images and GIS layout of Al Adabeya Port together with the land use map of the port.

Figure 5.17.: A satellite image for Al-Adabeya Port

Figure 5.18: A rectified satellite image for Al-Adabeya Port

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Figure 5.19: Full scale GIS layout of the Al-Adabeya Port

Figure 5.20: The Land use of the Al Adabeya Port

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5.8. Sampling Locations Figures from 5.21 to 5.23 show the sampling locations and sampling techniques.

Figure 5.21: Sampling locations

Figure 5.22: Ground Sampling

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Figure 5.23: Air sampling

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5.9. Analytical results

Table 5.4: Analytical results of the Lindane concentration in the air and ground samples -HCH -HCH -HCH -HCH Without activity (before opening the containers) ng/m3 PM10 0.3 0.3 1.4 1.3 TSP 0.0002 ND 0.0009 0.0007 PUF 0.35 0.006 0.80 0.27 During sampling from containers (After opening the containers) PM10 2.0 0.3 3.2 9.3 TSP 0.2 0.1 1.5 4.2 PUF 6.0 0.25 8.4 5.1 Soil (ng/g) Soil 1 1.2 0.87 7.0 35.5 Soil 2 1.67 6.3 19.3 113.7 Average of 4 Raw Samples from the materials stored in the containers (%) Raw Samples 6.5 11.3 13.5 68.7

The chlorinated pesticides of the collected samples were analyzed by gas chromatography/Mass Spectrometery andgas chromatography using an electron capture detector (ECD) at the accredited labs of the Oceanography Department of Rhode Island University.

The QA/QC procedures included analyses of matrix spikes, duplicates and laboratory blanks (Wade and Cantillo, 1994). The complete analytical procedure was validated by analyzing the reference material NIST 1941b. Results for the reference material were within the range of certiﬁed values speciﬁed for the target compounds. Control standards were included throughout the sample analysis to check instrument performance.

HCH consists of eight isomers (Safe 1993). Only γ-HCH, α-HCH, β -HCH, and γ -HCH are of commercial significance and considered in this study.

The pesticide lindane refers to products that contain >99% γ-HCH. The α-, β-, and δ- isomers, as well as technical-grade HCH are not synonymous with γ-HCH (Farm

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Chemicals Handbook 1993). Technical-grade HCH is not an isomer of HCH, but rather a mixture of several isomers;it consists of approximately 60–70% α-HCH, 5–12% β- HCH, 10–15% γ-CH, 6–10% δ-HCH, and 3–4% ε-HCH (Kutz et al. 1991).

The results of the analysis of the air (PM10, TSP as well as the vapor phase), the collected soil samples and raw samples from the containers (Table 5.4 and Figures 5.24-5.27) indicate that the contamination is due to aged technical grade HCH mixture and β-and δ-HCH are significantly higher thanα- and γ-HCH. However, according to the physico-chemical properties of the HCH isomers, concentrations of β- and δ-HCH should have close concentrations in an aged mixture. Surprisingly, this was not the case for the analyzed samples, since all samples, especially the collected soils, have high concentrations of δ-HCH. These results may suggest that the obsolete pesticides stored in the containers are not a pure lindane technical mixture.

The analysis of the samples collected from the containers supported this idea, since it was found that the concentration of lindane in the raw samples is less than 3%. This result is not validated with the previous reported data provided by the Central Labs of Chemical Weapon, Egyptian Armed Forces, which indicated that the concentration of lindane is ranged between 10-15% in the raw samples collected from the containers.

The isomeric composition of HCH of the raw samples from the containers, which have been analyzed at Rhode Island University, USA, indicates that the δ-HCH isomer is the dominant isomer in the raw samples and the isomeric composition is similar to that of the soil samples. Accordingly, this confirms that the OP stored in the 10 containers is impure lindane.

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Figure 5.24: PM10, TSP and PUF Distribution of the Lindane in the air samples (Before opening the containers)

Figure 5.25: PM10, TSP and PUF Distribution of the lindane in the air samples (After opening the containers)

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Figure 5.26: Interpolation of the Lindane concentration in the air samples (Before opening the containers)

Figure 5.27: Interpolation of the Lindane concentration in the air samples (After opening the containers)

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5.10. Standards and Regulations 1. IMMEDIATELY DANGEROUS TO LIFE OR HEALTH (IDLH) :50 mg/cu m [REF-5, p.186]

2. ACCEPTABLE DAILY INTAKES (ADI):  Ten day health advisory for a 10 kg child who consumes 1 liter of water/day is 1.2 mg/l. [REF-125, p.9]  Long-term health advisory for a 10 kg child who consumes 1 liter of water/day is 0.033 mg/l. [REF-125, p.9]  Long-term health advisory for a 70 kg adult who consumes 2 liter of water/day is 0.12 mg/l. [REF-126, p.9]  Lifetime health advisory for a 70 kg adult who consumes 2 liter of water/day is 10 ug/l. [REF-126, p.11]  FAO/WHO is 1 ug/kg/day. [REF-57, p.C-34]  FAO/WHO ADI: 0.008 mg/kg [REF-127]

3. ALLOWABLE TOLERANCES (AT) : Tolerances are established for the residues of the insecticide Lindane (gamma isomer of benzene hexachloride) in or on raw agricultural commodities as follows: 7 ppm in or on the fat of meat from cattle, goats, horses, and sheep; 4 ppm in or on the fat of meat from hogs; 3 ppm in or on cucumbers, lettuce, melons, mushrooms, pumpkins, squash, summer squash, and tomatoes; 1 ppm in or on apples, apricots, asparagus, avocados, broccoli, brussel sprouts, cabbage, cauliflower, celery, cherries, collards, eggplants, grapes, guavas, kale, kohlrabi, mangoes, mustard greens, nectarines, okra, onions (dry bulb only), peaches, pears, peppers, pineapples, plums (fresh prunes), quinces, spinach, strawberries and Swiss chard; 0.01 ppm (negligible residue) in or on pecans. [REF-128]

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4. OSHA STANDARDS: Permissible Exposure Limit: 8-hr Time-Weighted Average: 0.5 mg/cu m. Skin Designation. [REF-129]

5. NIOSH RECOMMENDATION: 10 hr Time-Weighted Average: 0.5 mg/cu m., Skin Designation [REF-5, p.186]

6. THRESHOLD LIMIT VALUE: 8hr Time Weighted Average (TWA) 0.5 mg/cu m, skin [REF-130, p.45]

7. OTHER OCCUPATIONAL PERMISSIBLE LEVELS : Australia: 0.5 mg/cu m, skin (1990); Federal Republic of Germany: 0.5 mg/cu m, short-term level 5 mg/cu m, 30 min, once per shift, skin (1991); United Kingdom: 0.5 mg/cu m, 10 min STEL 1.5 mg/cu m, skin (1991) [REF-36, p.860]

8. ATMOSPHERIC STANDARDS : Listed as a hazardous air pollutant (HAP) generally known or suspected to cause serious health problems. The Clean Air Act, as amended in 1990, directs EPA to set standards requiring major sources to sharply reduce routine emissions of toxic pollutants. EPA is required to establish and phase in specific performance based standards for all air emission sources that emit one or more of the listed pollutants. Lindane (gamma) is included on this list. [REF- 131]

9. FEDERAL DRINKING WATER STANDARDS :EPA 0.2 ug/l [REF-132]

10. FEDERAL DRINKING WATER GUIDELINES : EPA 0.2 ug/l [REF-132]

11. STATE DRINKING WATER GUIDELINES : ARIZONA 0.2 ug/l [REF-132]

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12. CLEAN WATER ACT REQUIREMENTS : Designated as a hazardous substance under section 311(b)(2)(A) of the Federal Water Pollution Control Act and further regulated by the Clean Water Act Amendments of 1977 and 1978. These regulations apply to discharges of this substance. [REF-133]  Criterion to protect freshwater aquatic life is 0.080 ug/l, As a 24 hr average and the concentration should not exceed 2.0 ug/l at any time. [REF-57, p.B-9]  For saltwater aquatic life, the concentration of Lindane should not exceed 0.16 ug/l at any time. [REF-57, p.B-9]

5.11. Evaluation of Results with Respect to Goals and Standards

When a POP-contaminated site has been identified and an initial characterization of the nature, extent and magnitude of contamination at the site has been completed, it must be determined whether the results exceed the generic guidelines.

If contaminant concentrations at the site do not exceed established guidelines, no further action is required. If contaminant concentrations exceed the generic guidelines, however, it is necessary to develop an appropriate management strategy, i.e., a remediation strategy and/or a risk management strategy. While a remediation strategy will establish the most appropriate cleanup objectives for a contaminated site, a risk management strategy will determine whether remedial action is required at all.

While the stock pike containers still closed/sealed, comparing the analytical results to the standards (IDLH, ADI, AT, OSHA, TLV …), minor environmental risk may occur (Pesticides can be smelled in the vicinity of the containers).

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Major health risk appears in case of opening the containers as the concentration of lindane exceed the standards levels.

Risk management is the decision-making process in which an action is developed once a remediation level has been determined. It integrates a remediation strategy with technical, political, legal, social and economic considerations to develop risk reduction and prevention strategies. Generally, it involves one or more of the following:  contaminant removal or reduction  modifying or limiting use by receptor  interception or removal of exposure

5.12. Simulation of the Worst Case Release Scenario

Simulation Assumptions: Referring to the EPA, the inputs data for air dispersion model are as follows:

Chemical Data Name Lindane CAS number 58 - 89 -9 Molecular weight 290.85 g/g-mole Melting point Approximately 113 C IDLH 50 mg/m3 ADI 1 ug/kg/day TLV 0.5 mg/m3

Meteorological Data Name EPA Worst case weather conditions Ambient temperature 25.0 ° C Ambient pressure 1.0 atm Relative humidity 50 % Wind direction 45 degrees Wind speed 1.5 m/s Stability class 6 (F)

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Two simulated scenarios were prepared according to the release type of the Lindane vapors (Figures 5.28– 5.30). Scenario (I) Scenario (II) Source type Gas release Release type Instantaneous Continuous Total amount released 0.01 kilograms 0.01 kilograms/min

Simulation Outputs Height of interest 1.6 m Lower contour (according to the analytical results of air samples) 0.008 ng/m3 Middle contour (ADI = 1 ug/kg/day X 5 = 5 ug/kg/day) 5 ug/m3 Upper contour (Immediately Dangerous to Life and Health Limit (IDLH) 50 mg/m3

Outputs of the Continuous release: maximum distance to minimum concentration

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Figure 5.28: Continuous Release

Concentration Maximum Distance (m) 0.008 ng/m3 5552.576 5 ug/m3 88.415 50 mg/m3 74.731

Figure 5.29: Starting Instantaneous Release

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Figure 5.30: Ending Instantaneous Release

Outputs of the Instantaneous release: maximum distance to minimum concentration

Concentration Maximum Distance (m) Elapsed Time(sec) 0.008 ng/m3 3674.219 2460 5 ug/m3 244.481 180 50 mg/m3 87.991 60

5.13. Risk Management Options Remediation through risk management deals with eliminating or controlling one or more of the three risk components: (i) contaminant, (ii) exposure pathway, and (iii) receptor. Figure 5.31 illustrates each risk component and its corresponding management options.

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For the current situation/case the Best Available Techniques (BAT) and the Best Environmental Practice (BEP) method to manage the problem is the complete removal of a contaminant source from contact with the receptors.

Figure 5.31: Risk Management Options

5.14. Conclusion and Recommendations

Based on the following activities:  Site/Field observations/Investigation  The Analytical results

 The risk factors FP and FE

The Multi- disciplinary Experts concluded that:

 There is a smell of Lindane Pesticides odor in the vicinity of the storage containers  Lindane Pesticides pose a hazard threatening the onsite workers of the people in the nearby plants

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 The situation also is a hazard for the environment POPs are entering our environment and will end up in the food chain.

 Referring to the FP (2,860,000), FP* = 100 and FE (18), the Al Adabeya Port Store is considered as (Problematic) store/site.

The Multi- disciplinary Expertsrecommended that:

 An immediate appropriate Risk Management Strategy is needed for safe shipping/disposal of the 10 containers of the obsolete lindane pesticide stored in the Al Adabeya Port.

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CHAPTER VI ENVIRONNEMENTAL and SOCIAL MANAGEMENT PLAN (ESMP)

6.1 General Context

It ratified the Stockholm Convention for the management of Persistent Organic Pollutants (POPs) in May 2003 and drafted a National Implementation Plan which includes: (1) the management and environmentally sound disposal of PCBs and obsolete pesticides; (2) institutional and regulatory strengthening measures as well as (3) awareness building and stakeholder involvement activities.

The project aims to support the GOE in the management of obsolete pesticides and POPs and PCBs, and proposes to invest in some pilot sites as demonstration of good practices. Al Adabeya Port is one such identified pilot site.

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The project is essentially a clean-up project which brings substantial environmental and health benefits. However to ensure that all project activities are undertaken in an environmentally and socially sound manner, there is need to undertake an Environmental and Social Management Plan (ESMP) for each activity.

6.2 Objective The objective of the Environmental and Social Management Plan (ESMP) is to provide a strategy for the management of obsolete lindane stockpile in Al Adabeya Port with a specific focus on safeguarding and environmentally sound final disposal of the obsolete lindane stockpile and lindane contaminated bags and to assess the possibility of disposal of contaminated soils, if any.

The ESMP shall cover all aspect related to the safeguarding and disposal operations. It will focus on the assessment of environmental and social impacts that will arise from the repackaging, domestic transport, temporary storage, loading and unloading, transboundary transportation including shipping, and overseas disposal of the hazardous waste.

The ESMP will be developed in a manner complying with the requirements, policies and guidelines of the World Bank, GOE/EEAA, international agreements such as the International Maritime Dangerous Goods Code and the Basel Convention on Transboundary Movement of Hazardous Wastes.

To ensure that all current and potential future impacts of the obsolete lindane stockpile in Al Adabeya Port are covered, the ESMP will be implemented in two steps. Step 1 will focus on mitigation of effects of the current situation while Step 2 will focus on mitigation of effects of safeguarding and disposal operations.

To prevent public health and environmental hazards from getting out of hand at obsolete lindane stockpile and contaminated site that are in critical conditions,

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emergency safeguarding will be carried out while awaiting the main safeguarding and disposal measures. With respect to the treatment and final disposal of obsolete lindane and its related contaminated materials and the clean-up of obsolete lindane contaminated sites, the ESMP specifically focuses on obsolete lindane, lindane contaminated bags, if discarded, and OP safeguarding and cleaning wastes.

6.3 Environmental and Social Management Plan Background and Considerations

The ESMP builds up on the general approach described in the FAO “Operational Manual” particularly “Tool G” Safeguarding” and “Tool H” Disposal. The ESMP has been prepared by adopting an interactive approach including the following steps. The first stage is to take the information presented under Chapters One to Six of this report and provide details on how the potential risk posed by obsolete lindane will be reduced or eliminated.

This is presented with the following:

(i)Safeguarding Strategy (ii)Disposal Strategy (iii)Activities related to safeguarding

6.4 Mitigation Measures for Current Impacts

Before executing the main operation of safeguarding of obsolete lindane of Al Adabeya Port, it is a matter of urgency to implement emergency measures in the site of stockpiling of obsolete lindane which has been identified as problematic risk site. These activities are mainly fencing off the area and posting of warning signs to keep passersby off the site.

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Emergency and safeguarding measures

Before the main planned safeguarding operations commence, emergence safeguarding measures need to be taken to put an end to health and environmental risks from obsolete lindane stockpile.

The emergence safeguarding measures will be similar to the ones previously carried out according to the FAO Environmental Management Tool Kits for OPs at various OP stores in other countries. They include repackaging of lindane whose bags are damaged. The emergency safeguarding measures include fencing off obsolete lindane stockpile and pesticide contaminated areas. The types and extents of the emergence safeguarding measures will be assessed using data obtained from surveys carried out by the scientific team. The emergence safeguarding measures will be undertaken by trained workers. Table6.1 illustrates the emergency safeguarding measures that can be taken with respect to obsolete lindane stockpile from Al Adabeya Port.

Environmental and social management activities, their impacts as well as their preventive and mitigations measures, institutional responsibilities, implementation schedules, and pertinent cost estimates are outlined in Table6.4.

Table 6.1: Emergency safeguarding measures that can be taken with respect to the current site of obsolete stockpile of lindane.

Site name Risk Condition of Potential Emergency safeguarding category pesticides & impact measures surroundings Al Adabeya High Remarkable Respiratory Fencing off the affected area lindane stockpile smell diseases and posting signs to warn passersby of imminent hazards

Rehabilitation work which is required to be done on the current site of OP stockpile (lindane) to making it meet minimum acceptable health and environmental protection standards is estimated to cost about US$ 7,000.

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6.5 Strategy 6.5.1 Safeguarding activities

The below proposed strategy for management of the OP of lindane at Al Adabeya Port follows the approach which has been introduced by FAO and the World Bank in similar cases in Africa and Eastern Europe. It includes the following activities:  Safeguarding – Rehabilitation work on the current site of the lindane stockpile.  Repackaging – if required repackaging will take place.  Transportation of containers packaged in accordance with international standards from the site of the OP stockpiling to a temporary storage area to the vicinity of the ships and finally loading onto a ship.  Disposal – disposal through high temperature incineration at approved installations. Ideally, safeguarding of obsolete lindane stock must involve proper containerization and labeling of OPs, cleaning these containers off the pesticides, and placing these containers in a safe and secure place that would meet the international requirements for safe storage of hazardous wastes/pesticides.

The decision on whether or not to repackage of obsolete lindane, will be based on:

 Condition of containers  Size of containers  Type and quality of containers (for example, obsolete lindane in containers made of delicate materials that are liable to leak will be repackage whereas OPs in robust containers will not necessarily be repackaged).

However, where information on the condition and quality of OP bags is not conclusive, the OP has to be repackaged. It should be recognized that new bags will need to be provided to replace leaky bags. Consequently, the pesticide contaminated leaky bags will need to be disposed of alongside the 880 obsolete lindane bags.

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The main activities that will be involved in safeguarding will be: verification of the stockpile, repacking (if needed), transportation (loading, transport, unloading), storage at a temporary storage area to the vicinity of the ships, and finally loading onto a ship.

6.6 Safeguarding impacts

7.6.1 Impacts during Disposal Operation

A number of environmental and social impacts are likely to occur during safeguarding, transportation and final disposal of the obsolete pesticides. The impacts for main activity with corresponding mitigation measures are summarized in Table6.2.

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Table 6.2: Impacts and related mitigation measures during safeguarding, transportation and disposal Activity Impacts Preventive Measure Mitigation Verification Health operators due  Before opening the shipment containers of lindane for  There is a first aid kit in the vehicle. to contact with verification, the verification team should review the  The verification team has identified the nearest pesticides previous inventory carried out by the Military Chemical hospital or clinic and notified them of their activities; Weapon, from outside, review the actual condition of Project staff members have medical checks, including the interior of the 10 containers. Then undertake a blood tests to determine if there are adverse impacts Task Based Risk Assessment to determine the from working with pesticides. Where impacts are appropriate Personnel Protective Equipment required found, the operators are assigned to activities that do undertaking the verification. not involve contact with pesticides. Public health  The public and workers of Al Adabeya Port are informed about the verification activity and instructed to stay away from the containers of obsolete lindane. Repackaging Health of operators  The ESIA team undertakes a Task Based Risk  Regular medical checks; due to contact with Assessment of the hazards of materials that will be  Emergency shower set up at the site. pesticides repackaged and the nature of the repackaging activity.  Full-time presence of project nurse This determines the type of Personal Protective  The nearest hospital or clinic has been identified Equipment required. and notified about the project team's activities in  The specification of repackaging material, such as PVC each given area, zone or location. bags, has been selected such that it minimizes the necessity for contact with pesticides.  The site is zoned off with, hazard tape (or fencing) with warning signs.  The working space outside the containers used for the repacking activities should be covered by PVC sheets to prevent the escaping of fine dust and vapor to come in contact with the pavement area around the containers.

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Activity Impacts Preventive Measure Mitigation Air pollution due to a  All electrical and other equipment used is flame proof;  The fire service is notified about the activities taking fire  Where possible flammable materials are excluded place at the site so they are in a state of preparedness. from the repacking area.  Fire extinguishing equipment is part of the emergency response kit carried by the team.  Appropriate and recommended substances are made available for extinguishing given materials in case of fire outbreaks. Soil and/or water  The areas where lindane bags are repacked are  Where escaping occurs, the team carries emergency contamination protected with plastic sheeting; spill kits. resulting from  The new bags are specified to UN standards for the  The PVC sheets covering the repacking areas are accidental spill materials to be filled into them. cleaned immediately by vacuuming.  The floors are cleaned by sweeping and/or vacuuming. Air pollution due to  The working space outside the containers used for the  Where escaping occurs, dust suppression techniques release repacking activities should be covered by PVC sheets to such as sprinkling with water are used. prevent the escaping of fine dust and vapor to come in contact with the paved area around the containers.  The site is zoned off with fencing. Road Soil and/or water  The transport route has been assessed and selected as  The escort vehicles carry emergency spill kits in the transportation contamination the safest and most direct; event of an accident. inside the port resulting  The maximum speed of the vehicles is set to 40km/hr. from accidental spill Air pollution resulting  Dust suppression techniques such as sprinkling with  The convoy of containers is escorted by vehicles within from accidental spill water are used. emergency response spill equipment and police  The transport route has been assessed and selected as vehicles. the safest and most direct;  The maximum speed of the vehicles is set to 40km/hr. Activity Impacts Preventive Measure Mitigation

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Storage at a Soil and marine water  The temporary storage area should be selected on the  Spill kits are made available at the temporary storage temporary pollution due to spill basis of their specification which includes impervious area to the vicinity of the ships. storage area to floors and their proximity to all necessary health and the vicinity of the safety provision facilities; ships Air pollution due to a  Electrical wiring should be intrinsically safe.  The fire service should develop an evacuation plan for fire  Where possible flammable materials are excluded the area around the temporary storage area to the from the temporary storage area. vicinity of the ships.  Adequate number of the extinguishers should be available at the temporary storage area. Transportation by Marine pollution due  The storage of lindane bags within the containers is  Marine salvage would be required to rescue the Sea to sinking of containers such that the materials should not leak. containers. or ships Disposal Air, water and soil  The incineration facilities are equipped with state of  Facilities have action and evacuation plans to conform pollution the art pollution abatement technology; to the EU Seveso directive  The emissions are analyzed to conform that they meet specification;  The facilities have fail-safe emergency shutdown procedures to stop waste burning if a serious failure in the process occurs.

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6.7 Safeguarding Management Aspects

The following activities should be considered when performing the safeguarding of the obsolete lindane stockpile in Al Adabeya Port.

Organization

Management The overall management of the safeguarding project shall rest with the project management unit (PMU). The PMU will be responsible for all liaisons with national stakeholders not working as part of the safeguarding team. The Project Coordinator will liaise with the Executive Director of EEAA to ensure all national legal obligations are met.

Technical support and supervision The national safeguarding team shall be supported by the Technical Advisor (TA). The TA shall work with the national staff to develop the necessary resource plan and work plan to ensure safe implementation of the project. Instructions on how to proceed shall be developed based on FAO procedures and training modules for the environmentally sound management of obsolete pesticides. The TA will work with the Safeguarding Team to develop the necessary managerial and supervisory capacity within the national team to ensure safe implementation of the safeguarding project.

Annex 13 shows the qualification and experience together with the selection criteria of the TA.

Site Supervision The day-to-day supervision of the safeguarding activities shall be undertaken by the leader of the safeguarding team under the supervision of the Project Manager and the TA. The safeguarding leader shall be responsible for establishing safe working area (zones) as described below the maintenance of safe working practices through on-the-spot supervision of the safeguarding team.

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Implementation

The safeguarding activities shall be completed by a team of staff from the involved institutions who previously have been involved in the inventory and have received training related to Personal protection Equipment. Further training related to entry and exit to the working area, zoning of the work place, use of equipment and general safety procedures shall be conducted before the work commence. During the operations a nurse with necessary first aid material shall be on site.

The staff shall be briefed daily on the activities to be completed and allocated roles and responsibilities by the Safeguarding team leader.

A description of the work procedures shall be prepared before commencing the safeguarding operations in order to have a complete picture of what is required during the works. These shall as a minimum include the following:

 Establishment of site  Zoning of site  Repackaging of lindane into new bags  Labeling and registration  Site Decontamination.

All containers which are used for the safeguarding shall be UN approved. Repackaging for safeguarding or consolidation for eventual transport shall be done according to the standard operating procedures specified in EMTK Volume II Tool F.

Zoning of Site In order ensure the safety of the workers and not causing pollution outside the storage a procedure for dividing the area into a number of zones shall be established. As a minimum the area shall be divided into 3 zones as described below.

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Zone 1: Commonly termed the “Hot” or “Dirty” zone

 Characterized by close proximity to the lindane containers;  Typically high risk of exposure when working;  Activities focus on repackaging of waste into new bags;  Control measures for decontamination of workers;  High levels of supervision and control;  Close monitoring of workers and work methods based on operating procedures;  High levels of PPE and environmental protection.

Zone 2: Commonly termed the “Intermediate” or “Buffer” zone

 Lower risk of exposure when working;  Typically focus on interim storage of repackaged bags;  May include removal of residual contamination on outside of containers;  Labeling of new bags;  Lower levels of PPE and environmental protection.

Zone 3: Commonly termed the “Clean” zone

 No or minimal risk of exposure;  Typically focus on storage of materials pending removal from site;  PPE related to handling of new, clean packages;  Use of bag handling equipment to move items to reduce risk.

In connection with the safeguarding activities the following measures shall be taken:

 All management and supervisory staff plus all laborers shall have complete pre and post project medical inspection including blood analysis. This action provides a documented record of the health of all project staff both before and after the implementation of project activities. The medical check also provide

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a method of assessing the application of safe working methods during implementation including the correct use of personal protective equipment (PPE) and supervision of laborers by competent staff.  A medical inspection should be carried out on a monthly basis from the beginning of the safeguarding project.  The site shall be established in such a way that it provides workers' facilities for showering, taking breaks and storing their non working clothes.

Alternatively, operation with a Workers' Decontamination Enclosure System and Waste and Equipment Decontamination Enclosure System can be adopted. In this option, the first enclosure will be for worker entry into and exit from the work area whereas the second enclosure is for decontamination of wastes (bags) and equipment taken out of the work area.

Management of lindane stockpile

Management of the obsolete lindane containers is important to maintain safe storage of the lindane. It shall involve security, routine inspections, and maintenance of the containers.

It is proposed that all storage siteis equipped with security guards and that a local representative is appointed store manager. The store manager shall be given the obligation to report to PMU on a monthly basis regarding the condition and situation at the store. The estimated manpower cost for the site is US$ 15,000.

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Communications

It is proposed that the purpose and activities related to the safeguarding is communicate on a local basis to the communities and organizations around the storage site to increase awareness towards the risk and hazard posed by the obsolete lindane. The PMU shall develop a communications package to brief the administration of the town and the nearest neighbors. The package should include details such as:  Description of the work;  instructions to keep away from the site throughout the period of the work;  a map showing the area of the work, and the area of restricted access;  safety instructions of what to do in an emergency (such as a fire at the site)  emergency contact details of the PMU

Routine and emergency telecommunications will normally be undertaken by mobile phone. The PMU, TA, the Safeguarding team leader shall all have mobile phones. A satellite phone has also to be available during the safeguarding activities in case of emergency and there is no available mobile network.

Transport

All movement of hazardous waste inside the port will be coordinated and supervised by the PMT. Specific transport rules shall be applied following the international rules including:

 Safety Equipment in vehicles  Driver Training  Transport documentation including information on hazards and emergency actions  Vehicle Inspections  Driver Briefing  Escort vehicle with response equipment

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 Speed limit 40 kph on the port route  Planned route based on risk assessment

It is noteworthy that, under ideal condition where potential transport routes differ only in terms of distance, the selection of transport routes could make use linear programming with a view to optimizing the selection. The use of linear programming, which is theoretically sound, is practically untenable in the context of this project mainly because the potential transport routes differ in other complicated ways in addition to differences in distance. The main additional differences are: security (safety), quality and reliability of the roads, availability and reliability of supporting services.

The selection of appropriate routes which are not passing through highly sensitive areas is a factor which shall be considered when moving the obsolete lindane. However with the limited number of roads in the port there may be limited options.

Disposal

Local Disposal

Disposal operations will involve different types of wastes which may require different types of treatment to render them harmless. Such wastes include the obsolete lindane, contaminated soils, old bags, and old equipment. Disposal aspects considered in accordance with the scope of the ESIA encompasses obsolete lindane and contaminated lindane bags. Egypt does not have a hazardous waste disposal facility suitable for obsolete pesticides in compliance with the required emissions standards as defined by European Union and US EPA legislation. Under such conditions, the only alternative for the disposal of obsolete pesticides and contaminated empty bags and containers is to export and dispose of them at a licensed facility overseas in compliance with the requirements of the Basel and Stockholm Conventions. International Disposal

Inclusions of international disposal companies in OP disposal operations have been applied in a number of cases in Africa and Eastern Europe. In Egypt the EEAA has no previous experience with the disposal operations.

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There are a number of mainly European companies who have taken on the task of collecting, transporting and disposal of OP at high temperature in compliance with international regulations. It is considered that all potential companies provide a safe disposal option.

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Table 6.3: Environmental and Social Management Plan Institutional Duration Cost Mitigation responsibilities (including after Activity Impact Preventive Measure estimates Measures enforcement contract (US$) &coordination) signing Verification Health operators  Before opening the shipment  There is a first aid kit in the  EEAA, 3 Weeks 30,000 due to contact containers of lindane for vehicle.  Local health facilities, with pesticides verification, the verification team  The verification team has  EEAA trained staff, should review the previous identified the nearest  POPs Project Officer, inventory carried out by the Military hospital or clinic and  Hazmat Officer. Chemical Weapon, from outside, notified them of their  Local contractors review the actual condition of the activities; Project staff  International contractor interior of the 10 containers. Then members have medical  Al Adabeya Port Police undertake a Task Based Risk checks, including blood  Al Adabeya Maritime Assessment to determine the tests to determine if there Transport Officer. appropriate Personnel Protective are adverse impacts from  Red Sea Ports Authority. Equipment required undertaking the working with pesticides. verification. Where impacts are found, Public health  The public and workers of Al the operators are assigned Adabeya Port are informed about to activities that do not the verification activity and involve contact with instructed to stay away from the pesticides. containers of obsolete lindane. Repackaging of Health of  Implementation of ESMP and health  Regular medical checks;  EEAA, Four months 800,000 lindane and operators and safety emergency plan as  Emergency shower set up  Local health facilities, packaging of due to contact elaborated in EMTK Vol. II. at the site.  EEAA trained staff, contaminated with  The FM undertakes a Task Based  Full-time presence of  POPs Project Officer, bags and lindane lindane Risk Assessment of the hazards of project nurse where there is  Hazmat Officer. contaminated materials that will be repackaged no hospital nearby.  Local contractors and the nature of the repackaging  The nearest hospital or  International contractors activity. This determines the type of clinic has been identified for repackaging

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Institutional Duration Cost Mitigation responsibilities (including after Activity Impact Preventive Measure estimates Measures enforcement contract (US$) &coordination) signing cleaning wastes, site Personal Protective Equipment and notified about the  Al Adabeya Port Police cleaning and required. project team's activities in  Al Adabeya Maritime decontamination  The specification of repackaging each given area, zone or Transport Officer. equipment, such as bag handling locations  Red Sea Ports Authority.  Health and safety equipment, has been selected such  Provide decontamination  Environmental that it minimizes the necessity for enclosures protection contact with pesticides.  Equipment  The site zoned off with fencing,  Public consultation hazard tape and warning signs.  Management and  The working space outside the planning containers used for the repacking  Sustainability activities should be covered by PVC  Budget planning sheets to prevent the escaping of fine dust and vapor to come in contact with the paved area around the containers.

Release to air  All electrical and other equipment  The fire service is notified  Fire Department, through a fire used inside the store is flameproof; about the activities taking  EEAA,  Where possible flammable materials place at the site so they are  Local health facilities, are excluded from the store; in a state of preparedness.  Local contractors  Incompatible materials are not  Fire extinguishing  International contractor mixed together. They are either equipment is part of the  Al Adabeya Port Police completely separated or segregated emergency response kit  Al Adabeya Maritime and where necessary adequate fire carried by the team. Transport Officer. and physical barriers are erected  Appropriate and  Red Sea Ports Authority. between dangerous chemicals recommended substances

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Institutional Duration Cost Mitigation responsibilities (including after Activity Impact Preventive Measure estimates Measures enforcement contract (US$) &coordination) signing are made available for extinguishing given chemicals in case of fire outbreaks according to EMTK Tool N. Spillage  All spillage cases should be handled  Where escaping occurs, the  EEAA, contaminates soil according to SOPs described in team carries emergency  Local health facilities, and EMTK Tool L; spill kits.  EEAA trained staff, groundwater  The new bags are specified to UN  The PVC sheets covering the  POPs Project Officer, standards for the materials to be repacking areas are cleaned  Hazmat Officer. filled into them; immediately by vacuuming.  International contractor.  The floors are cleaned by sweeping  Al Adabeya Port Police and/or vacuuming.  Al Adabeya Maritime Transport Officer.

Release to air  The working space outside the  Where escaping occurs,  International contractor, containers used for the repacking dust suppression  EEAA, activities should be covered by PVC techniques such as  Al Adabeya Port Police sheets to prevent the escaping of sprinkling with water are  Al Adabeya Maritime fine dust and vapor to come in used. Transport Officer. contact with the paved area around the containers.  The site is zoned off with fencing.  Dust suppression techniques are used.

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Institutional Duration Cost Mitigation responsibilities (including after Activity Impact Preventive Measure estimates Measures enforcement contract (US$) &coordination) signing Loading onto vehicles Air, soil  Safe systems of work to be  Spill kits are made available  International contractor, One week 10,000 contamination employed plus supervision of at the gate of loading and  PMU, EEAA resulting trained staff. onboard.  Al Adabeya Port Police from dropped  Controlled crane movements, use of  Drivers to receive training / loads. banks man etc. Good manual instruction on risks. handing technique, handling aids  Driver to remain in cab (or in such as forklift, trolleys etc. welfare unit) during loading. Road transportation Soil and/or water  The transport route has been  The escort vehicles carry  International contractor, Two days 10,000 inside the port contamination assessed and selected as the safest emergency spill kits in the  EEAA, resulting and most direct; event of an accident.  Al Adabeya Port Police from accidental  The maximum speed of the  Traffic police spill vehicles is set to 40km/hr.  Al Adabeya Maritime  Stowage of materials within the Transport Officer. shipping containers strictly conforms to IMDG standards. Air pollution  Dust suppression techniques such as  The convoy of containers is  International contractor, resulting from sprinkling with water are used. escorted by vehicles within  EEAA, accidental spill  The transport route has been emergency response spill  Al Adabeya Port Police assessed and selected as the safest equipment and police  Traffic police and most direct; vehicles.  Al Adabeya Maritime  The maximum speed of the Transport Officer. vehicles is set to 40km/hr.

Storage at a Soil and marine  The temporary storage area should  Spill kits are made available  International contractor, Maximum 20,000 temporary storage water pollution be selected on the basis of their at the temporary storage  PMU, EEAA three days area to the vicinity of due to spill specification which includes area to the vicinity of the  Al Adabeya Port Police the ships impervious floors and their ships.

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Institutional Duration Cost Mitigation responsibilities (including after Activity Impact Preventive Measure estimates Measures enforcement contract (US$) &coordination) signing proximity to all necessary health and  Al Adabeya Maritime safety provision facilities; Transport Officer.  Navy, Ports Authority. Air pollution due  Electrical wiring should be  The fire service should  International contractor, to a fire intrinsically safe. develop an evacuation plan  PMU, EEAA  Where possible flammable materials for the area around the  Al Adabeya Port Police are excluded from the temporary temporary storage area to storage area. the vicinity of the ships.  Adequate number of the extinguishers should be available at the temporary storage area. Loading onto ship at Marine water, soil  Safe systems of work to be  Spill kits are made available  International contractor, One week 20,000 Al Adabya port contamination employed plus supervision of at the gate of loading and  PMU, EEAA resulting trained staff. onboard.  Al Adabeya Port Police from accidental  Controlled crane movements, use of  Drivers to receive training / spill, dropped banks man etc. Good manual instruction on risks. loads. handing technique, handling aids  Driver to remain in cab (or in such as forklift, trolleys etc. welfare unit) during loading. Transportation by Marine pollution  The storage of lindane bags within  Marine salvage would be  International contractor, Two months 200,000 Sea due to sinking of the containers is such that the required to rescue the  EEAA, containers or materials should not leak. containers.  Al Adabeya Port Police ships  Navy  Red Sea Ports Authority. Disposal of Emissions to  The incineration facilities are  Facilities have action and  International contractor, One month 700,000 obsolete lindane, atmosphere, equipped with state of the art evacuation plans to  Host country contaminated water pollution abatement technology; conform to the EU Seveso enforcement institutions

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Institutional Duration Cost Mitigation responsibilities (including after Activity Impact Preventive Measure estimates Measures enforcement contract (US$) &coordination) signing obsolete lindane and soil  The emissions are analyzed to directive or EMTK bags, soils conform that they meet Guidelines and cleaning wastes specification;  The facilities have fail-safe emergency shutdown procedures to stop waste burning if a serious failure in the process occurs. NOTES: 1) Other activities that will need to be undertaken at the site of the lindane stockpile such as checking labels, placing new labels on lindane containers, and cleaning containers which are not directly stated in the Table will be implemented in accordance with EMTK. 2) Cleanliness of the lindane stockpile will be ensured so that clean lindane bags are not recontaminated during repacking activities. 3) Wastes generated at the site of lindane stockpile, including site cleaning wastes/rags, disposable PPE, and used plastic and other covering materials will be handled in the same way as the empty bags.

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As a general observation in connection with Table6.3, all personnel entering the obsolete lindane management work areas must have gone through health and safety training, and must have read the material safety data sheets (MSDS) for the lindane and learned the related hazards, the preventive measures, and what to do in case of exposure to lindane. All this is in accordance with EMTK Vol. 2.

6.8 Adopted Implementation Strategy

Taking into account all the issues discussed in the preceding subsections of this section and building up on Chapters Six, the safeguarding, transportation, and final disposal of the obsolete lindane will have to encompass a number of features that need to be clearly spelled out. On the whole, as noted earlier, there will be one main stockpile of lindane. From this site it will be hauled inside the port to a temporary storage area to the vicinity of the ships to wait about for sea freighting to their final disposal

destination outside the country. 173

Taking into consideration the chemical nature and current conditions of the obsolete lindane stocks and based on findings from Chapter Six, it is apparent that the safeguarding, transportation, and final disposal of the obsolete lindane stockpile will need to involve several public and private authorities and entities. Of these the most important are the PMU together with its teams, international contractors, and local contractors.

The distribution of the roles between the PMU together with its working teams on the one hand and contractors on the other regarding various obsolete lindane

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safeguarding and transportation obligations will be guided by the relationship schematically illustrated in Figure 6.1.

It is apparent from Figure 6.1 and it should clearly be noted that the PMU together with its working teams are largely responsible for all activities related to the obsolete lindane. The PMU's responsibility stops when the contract of the international contractor shall come into effect (on the date the contract is signed). The international contractor is responsible for handling obsolete lindane stockpile, repacking and safeguarding activities, loading, site cleaning and decontamination, in-country transportation of lindane and associated waste to the gate of exit in Al Adabeya Port and from the port of arrival to the disposal facility.

6.9. Cost Considerations for obsolete lindane Safeguarding and Disposal

Table 6.4: Estimated cost of safeguarding and destruction of obsolete lindane, contaminated soils and other contaminated material

Waste stream component Quantity (tones) Estimated cost (USD)

obsolete lindane 220 1,498,000

Contaminated soils 0.6 30,000

Other contaminated material 1.2 22,400

Total 221.8 1,650,000

174 In Tables6.4 "other contaminated material" includes pesticide contaminated bags and all wastes generated during the safeguarding and destruction operations. The costs are based on all inclusive average unit rates accounting for all costs involved from the obsolete lindane stockpile in Al Adabeya to the final disposal place outside Egypt. The average unit rate is derived from similar cases with adjustments that take into consideration prevailing conditions.

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Obsolete lindane PMU stockpile (10 containers) Transfer of ownership from Verification PMU to contractor

Repacking

Site cleaning and decontamination

Loading . . .

Road transportation inside Al Adabeya Port to the gate of exit International

Unloading Contractor

Storage at a temporary storage area to the vicinity of the ships

Loading to the ship 175

Maritime and road Transportation to International final disposal Contractor destination Figure 6.1 Schematic illustration of roles of PMU and contractors with respect to clean up, safeguarding, transportation of obsolete lindane stocks from Al Adabeya

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6. 10. Environmental and Social Management Training Requirements Egypt currently has a touch capacity in the area of management of obsolete pesticides. This capacity will be developed as a result of training and field experience gained from the current initiatives in Egypt. One of the main objectives of the GEF project is to build on the existing capacity and to establish new capacity in each of the key components of the project. Specifically, those who will be involved in safe guarding and disposal activities as elucidated in this ESIA document need to be properly trained to enable them discharge their duties effectively, safely and in an environmentally friendly manner. In view of this, capacity needs to be developed in the following areas:

(vii)Health and safety, (viii)Environmental protection, (ix)Equipment supply, (x)Public consultation, management, (xi)Environmental policies and programs (xii)Management, planning and budgeting

Training objectives will be achieved by organizing induction courses and training workshops as detailed in Table 6.5.

Table 6.5: Environmental and social management training requirements

Training topic Participants Types of Training Training Cost training content scheduling Estimates(USD) Health and -EEAA staff, Health and EMTKs One month 7,000 176 safety -MALR &C safety -Theory on after staff, pertinent occupational beginning -Field safeguarding safety and workers, of obsolete health theory -Truck lindane pertinent to drivers stockpile (as safeguarding derived and disposal from the -Practical's on H&S plan) occupational safety and health pertinent to safeguarding and disposal Environmental -MALR &C Environmental EMTKs -Two 1,500

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protection staff (zonal management months coordinators pertinent to Environmental after and field safeguarding impacts and beginning managers) as derived management from relevant needs of EMTK pesticides use

Emergency EEAA staff, -Emergency -EMTKs -Three 4,000 planning and -MALR &C Planning and -Operating months response staff, response Guidelines after -Field aspects For disaster project workers, response beginning -Truck drivers

Equipment - -Training -World Bank -One 500 supply procurement workshop procurement month management procedures after unit -Egypt beginning public procurement procedures and regulations

Public -EEAA staff -Training -Stakeholders -Two 1,000 consultation -MALR &C workshop Identification, months staff Mobilization after -NGO staff and beginning (selected) Involvement - Management, EEAA -Training -Project -One 1,000 planning and project workshop management month budgeting coordinating and planning after 177 team -Budget beginning planning

Environmental EEAA -Training - 1,000 policies and project workshop Environmental -One programs coordinating policies month team - after Environmental beginning programs

6.11. ENVIRONMENTAL AND SOCIAL MONITORING PLAN

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6.11.1. Overview

Monitoring is needed to check if and to what extent the impacts are mitigated benefits enhanced and new problems addressed. Plans for monitoring have been included in the Environmental and Social Monitoring Plan (Table6.6). The monitoring plan as for ESMP also assigns responsibilities for monitoring activities.

Monitoring of safeguarding activities shall be undertaken by members of the Project Management Unit (PMU), local government officials will be involved in the monitoring exercise. Non-governmental Organizations and other Community Services Organizations will constitute the monitoring team for the safeguarding activities. It is anticipated that use of NGO monitors will provide an impartial assessment of the effectiveness of the proposed mitigation measures. The PCT shall identify the most appropriate national NGO to fill this role. FAO technical Support Missions monitoring and simultaneously provide backstopping advices and follow up from the FAO Headquarters etc.

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Table 6.6: Environmental and Social Monitoring Plan Cost Data and/or Institutional Estimates Proposed Measurements Parameter to Frequency of responsibilities (equipment Activity Impact Preventive Measure Mitigation Location (including be Monitored Measurement (including review & Measures methods & &reporting) individuals) equipment (US$) Repackaging of Health of  Implementation of ESMP and  Regular Number of Medical Observation of Before working  EEAA, 20,000 lindane and operators health and safety emergency plan medical checks; medical facilities medical records and after every  PMU, packaging of due to as elaborated in EMTK Vol. II.  Emergency checkups within Al month  Port health contaminated contact  The Field Manager (FM) shower set up Adabeya facilities, bags and with undertakes a Task Based Risk at the site. Port  Local lindane lindane Assessment of the hazards of  Full-time contractors contaminated materials that will be repackaged presence of  International cleaning wastes and the nature of the repackaging project nurse contractors activity. This determines the type where there is for  Health and of Personal Protective Equipment no hospital repackaging safety required. nearby.  Environment  The specification of repackaging  The nearest al protection equipment, such as bag handling hospital or  Equipment equipment, has been selected clinic has been  Public such that it minimizes the identified and consultation necessity for contact with notified about  Management pesticides. the project and planning  The site zoned off with fencing, teams activities  Sustainability hazard tape and warning signs. in each given  Budget  The working space outside the area, zone or planning containers used for the repacking locations activities should be covered by  Provide PVC sheets to prevent the decontaminati escaping of fine dust and vapor to on enclosures come in contact with the paved area around the containers.

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Cost Data and/or Institutional Estimates Proposed Measurements Parameter to Frequency of responsibilities (equipment Activity Impact Preventive Measure Mitigation Location (including be Monitored Measurement (including review & Measures methods & &reporting) individuals) equipment (US$) Release to  All electrical and other equipment  The fire service Number of At the site Observations  International 15,000 air used inside the store is flameproof; is notified fire of contractor, through a  Where possible flammable about the incidences lindane  PMU fire materials are excluded from the activities taking stockpile  Fire store; place at the Department,  Incompatible materials are not site so they are  EEAA, mixed together. They are either in a state of  Al Adabeya completely separated or preparedness. Port Police segregated and where necessary  Fire adequate fire and physical barriers extinguishing are erected between dangerous equipment is chemicals part of the emergency response kit carried by the team.  Appropriate and recommended substances are made available for extinguishing given chemicals in case of fire outbreaks according to EMTK Tool N.

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Data and/or Institutional Cost Proposed Measurements Parameter to Frequency of responsibilities Estimates Activity Impact Preventive Measure Mitigation Location (including (equipment be Monitored Measurement (including review Measures methods & & individuals) &reporting) equipment (US$) Spillage  All spillage cases should be handled  Where escaping Number of At the site Physical Weekly  International contamin according to SOPs described in occurs, the spills of Observations contractor. ates soil EMTK Tool L; team carries Number and lindane  EEAA, and  The new bags are specified to UN emergency spill types of stockpile  PMU ground- standards for the materials to be kits. emergency  Local health water filled into them;  The PVC sheets spill kits facilities,  The floors are cleaned by covering the  Al Adabeya sweeping and/or vacuuming. repacking areas Port Police are cleaned immediately by vacuuming. Release to  The working space outside the  Where  International air containers used for the repacking escaping contractor, activities should be covered by PVC occurs, dust  EEAA, sheets to prevent the escaping of suppression  Al Adabeya fine dust and vapor to come in techniques Port Police contact with the paved area around such as  Al Adabya the containers. sprinkling with MTO  The site is zoned off with fencing. water are used.  Dust suppression techniques are used. Road Soil  The transport route has been  The escort Number of In the Physical During  International 20,000 transportation and/or assessed and selected as the safest vehicles carry incidences of Transport- observations transportation contractor, inside the port water and most direct; emergency spill spills, ation  PMU, contamin  The maximum speed of the kits in the event leakages, route  Port Police ation vehicles is set to 40km/hr. of an accident. accidents and  Traffic police resulting  Stowage of materials within the injuries  AlAdabya from shipping containers strictly MTO& accidental conforms to IMDG standards.  NGOs spill

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Cost Data and/or Institutional Estimates Measurements Proposed Parameter to Frequency of responsibilities (equipment Activity Impact Preventive Measure Mitigation Location (including be Monitored Measurement (including review & Measures methods & &reporting) individuals) equipment (US$)

 Dust suppression techniques such  The convoy of  International Air as sprinkling with water are used. containers is contractor, pollution escorted by  PMU, resulting  The transport route has been vehicles within  from assessed and selected as the safest emergency Port Police accidental and most direct; response spill  Traffic police spill  The maximum speed of the equipment and  Al Adabya vehicles is set to 40km/hr. police vehicles. MTO Officer.

 Spill kits are  Physical Daily Before  International Soil and  The temporary storage area should  contractor, Storage at a marine made available Number of observations and be selected on the basis of their at the spill kits At  Afterlindane  PMU, temporary water specification which includes temporary Calculation of storage area to temporary  Risk factors risk factors stockpile is  Port Police 10,000 the vicinity of the pollution impervious floors and their storage storage area to (FE and Fp) area using the moved to the  MTO ships due to proximity to all necessary health vicinity of the spill and safety provision facilities; the vicinity of method in FAO  Navy the ships. EMTK -I ships  Port Authority.

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 The fire service should develop an evacuation plan for the  International  Electrical wiring should be area around Number of contractor, the temporary fire  Air intrinsically safe. storage area to extinguishers At PMU temporary pollution  Where possible flammable the vicinity of Physical Daily  Fire 20,000 due to a materials are excluded from the storage observations Department, fire the ship. Adequacy of area temporary storage area.  Adequate an evacuation  Al Adabya Port number of the plan Police extinguishers should be available at the storage area.

Cost Data and/or Institutional Estimates Proposed Parameter to Measurements Frequency of responsibilities (equipment Activity Impact Preventive Measure Mitigation Location (including Measures be Monitored Measurement (including review & methods & &reporting) individuals) equipment (US$)  Spill kits are made available at Marine the gate of water loading and contaminat  Safe systems of work to be employed Number of  International onboard. incidences of ion plus supervision of trained staff.  Gate of contractor, Loading onto ship resulting  Drivers to receive spills, Physical During loading at Al Adabeya Controlled crane movements, use of training / loading  10,000 from banks man etc. Good manual handing leakages, observations onto ship PMU, EEAA Port accidental instruction on onto ship  Al Adabeya technique, handling aids such as risks. accidents and spill, forklift, trolleys etc. injuries Port Police dropped  Driver to remain loads. in cab (or in welfare unit) during loading.  International Marine  Marine salvage Adequacy of In the sea Technical pollution transporta During Advisors Transportation by due to  The storage of lindane bags within the would be marine Physical Sea sinking of containers is such that the materials required to tion transportation (ITAs), 50,000 should not leak. rescue the salvage observations containers facilities routes  International or ships containers. contractor

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 The incineration facilities are equipped  Facilities have Disposal of with state of the art pollution action and obsolete lindane, Emissions abatement technology; evacuation contaminated to  The emissions are analyzed to conform plans to  Host country lindane atmospher that they meet specification; conform to the enforcement 60,000 containers e, water  The facilities have fail-safe emergency EU Seveso and institutions and soil shutdown procedures to stop waste directive or contaminated burning if a serious failure in the EMTK cleaning wastes process occurs. Guidelines

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Table 6.7: Implementation and Supervision roles to the management and monitoring teams and the means of carrying out supervision

Institutional responsibilities Activity Impact Institutional responsibilities for Responsibility of direct Means of implementation supervision supervision Repackaging of lindane and Health of operators  EEAA,  PMU Manager (PM)  Coordination packaging of contaminated due to contact with  Local health facilities,  Reviewing bags and lindane contaminated lindane  EEAA trained staff, progress reports cleaning wastes  POPs Project Officer,  Reporting to the  Hazmat Officer. National Project  Health and safety  Local contractors Director (NPD).  Environmental protection  International contractors for repackaging  Field inspection  Equipment  Al Adabeya Port Police  Public consultation  Al Adabeya Maritime Transport Officer.  Management and planning  Red Sea Ports Authority.  Sustainability Release to air  Fire Department,  PMU Manager (PM)  Field inspection  Budget planning through a fire  EEAA,  Evaluating the  Local health facilities, results of  Local contractors reviewing and  International contractor auditing  Al Adabeya Port Police  Reviewing  Al Adabeya Maritime Transport Officer. complaints  Red Sea Ports Authority. received Spillage  EEAA,  PMU Manager (PM)  Field inspection contaminates soil and  Local health facilities,  Reviewing lab groundwater  EEAA trained staff, measurements  POPs Project Officer, results  Hazmat Officer.  Coordination  International contractor.  Al Adabeya Port Police  Al Adabeya Maritime Transport Officer.

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Institutional responsibilities Activity Impact Institutional responsibilities for Responsibility of direct Means of implementation supervision supervision Release to air  International contractor,  PMU Manager (PM)  Coordination  EEAA,  Field inspection  Al Adabeya Port Police  Reviewing lab  Al Adabeya Maritime Transport Officer. measurements results

Road transportation inside the port Soil and/or water  International contractor,  PMU Manager (PM)  Coordination contamination resulting  EEAA,  Field inspection from accidental spill  Al Adabeya Port Police  Traffic police  Al Adabeya Maritime Transport Officer. Air pollution resulting  International contractor,  PMU Manager (PM)  Coordination from accidental spill  EEAA,  Field inspection  Al Adabeya Port Police  Reviewing lab  Traffic police measurements  Al Adabeya Maritime Transport Officer. results Storage at a temporary storage area Soil and marine water  International contractor,  PMU Manager (PM)  Coordination to the vicinity of the ships pollution due to spill  PMU, EEAA  Field inspection  Al Adabeya Port Police  Al Adabeya Maritime Transport Officer.  Navy, Ports Authority. Air pollution due to a fire  International contractor,  PMU Manager (PM)  Coordination  PMU, EEAA  Field inspection  Al Adabeya Port Police  Loading onto ship at Al Adabya port Marine water, soil  International contractor,  PMU Manager (PM)  Coordination contamination resulting  PMU, EEAA  Field inspection from accidental spill,  Al Adabeya Port Police dropped loads.

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Institutional responsibilities Activity Impact Institutional responsibilities for Responsibility of direct Means of implementation supervision supervision Transportation by Sea Marine pollution due to  International contractor,  International  Undertake sinking of containers or  EEAA, contractor internal and ships  Al Adabeya Port Police external high level  Navy communication  Red Sea Ports Authority.  Reporting to the National Project Director (NPD). Disposal of obsolete lindane, Emissions to  International contractor,  International  Undertake contaminated obsolete lindane bags, atmosphere, water  Host country enforcement institutions contractor internal and soils and cleaning wastes and soil external high level communication  Reporting to the National Project Director (NPD).

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6.12. Terms of Reference of the (TOR) Project Team  National Project Director (NPD) A senior manager in the waste management division of EEAA will be selected as the National Project Director and will dedicate approximately 50 percent of his/her time to the POPs PMU. The National Project Director will report directly to the Chief Executive Officer of EEAA on project matters. The National Project Director will have the following responsibilities: - Appointment and performance evaluation of all PMU staff - Oversight of all project activities and provide guidance - Approval and signature of quarterly and annual project reports - Following the disbursement status - Approval of procurement decisions

 PMU Manager (PM) - Managing staff and overseeing the day-to-day activities of the PMU related to the management and implementation of the Project. - Overall supervision of project activity. - Participate and represent the PMU as non decision-making member in the PSC and serve as secretary of the committee. - Undertake external high level communication. - Prepare, or as appropriate supervise the preparation of, progress reports, annual reports, project completion report and other reports that may be required by the stakeholders - Prepare, or as appropriate supervise the preparation of, annual work plans and budgets and present to the PSC for approval - Supervise PMU staff in the performance of their respective duties and ensure the efficient functioning of the unit - Represent the PMU and the project in general to national and international audiences in Egypt and internationally. - The Manager will report directly to the CEO of EEAA, which will facilitate resolution of any internal delays to implementation.

 Procurement Specialist. - The Procurement Specialist will be responsible for overseeing all aspects of the procurement process for contracts financed by the project, including preparation and supervision of the procurement plan, preparation of TORs and requests for World Bank no-objections. - Organization of bidders’ conferences and bid evaluations, oversight of contractual obligations, etc. In cooperation with the NPD, PM and other PMU staff, - Preparation and submission of periodic procurement progress reports including the updated Procurement Plan. With respect to the procurement of the main component of the Project (component 2),

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- The Procurement Specialist will work closely with the Implementing Agencies or Project Working Groups (PWG) carrying out the engineering design and bid documents, providing support during the procurement and contracting phase as well as carrying out the construction supervision.

 Financial Specialist - Development and monitoring of annual Project budgets. - Reporting on the status of Project accounts and the disbursement of funds. - Liaising with the external auditor. - Handling the Project flow of funds (disbursements to project contactors/suppliers and withdrawals from the Project accounts). -  Monitoring and Evaluation Specialist - Developing an M&E evaluation scheme & preparing the periodic project progress reports, including reporting progress on general implementation and progress against agreed indicators (mid-term review & completion report). - Monitor the implementation of the environmental safeguards requirements of the World Bank and of the Egyptian Environmental Affairs Agency. - Monitor the implementation of the site specific Environmental and Social Management Plans (ESMP). - Monitor the implementation of the environmental mitigation measures, monitoring plan, and institutional/training requirements of the EMP, and will be responsible for environmental reporting responsibility within the PMU. - Sets out the key indicators for measuring the achievement of project outputs and outcomes - Propose a system for monitoring the project performance indicators (including needs for field monitoring and data processing needed for quarterly project reporting) - Evaluate project performance at the end-of-year report and propose any needed changes for the following year. - Emphasis on assessing progress made towards achieving the PDO and the sustainability of project interventions.

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 A Project Steering Committee (PSC) The Project Steering Committee (PSC) is established at the inception of the project to provide strategic guidance on the project implementation, and to facilitate the coordination of various Government authorities. EEAA / CEO will act as the chair of the PSC. To ensure sustainability, strategic relevance and appropriate national coordination, the PSC is established with the participation of the key stakeholders. The PSC will meet every six months, unless required for ad-hoc meetings, with the mandate to:

- Approve progress reports, including the inception report.

- Oversee and supervise project planning and implementation processes, submit the appropriate guidance for the PMU and recommend correction actions if needed

- Approve and provide strategic guidance for the work plan for the coming 12 months

- Approve major changes in the project document in terms of outcomes, outputs, and budgets.

- Take initiative to ensure sustainability and avoid duplication of activities

- Take initiative to mobilize all relevant stakeholders and partners

- Provide recommendations to the project in terms of relation to specific priorities not foreseen at the time of writing the original project document.

- Maintain the joint coordination among different implementing entities and resolve/remove any problem/obstacles that hamper the smooth implementation of the project

The Project Steering Committee will be made up of representatives of all agencies which are involved in implementation directly or which have a legal or regulatory stake in project outcomes or implementation as permanent members and would have the right to invite ad-hoc experts. 6.13 Project Team Monitoring and Reporting

6.13.1 Field Managers

The day to day monitoring of the field activities shall be undertaken by the FMs and M&E officers. A variety of standard forms to communicate and monitor activities which among others include the list of the following and each of which are maintained in the database within the project office and files and electronically both for reference, follow up and auditing. Forms and details concerning:

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 Daily Briefing  Project checklists  Daily Progress Reports  Weekly Progress Reports  Work Plans

The blank forms for these documents are included in Annex 14 and are summarized below:

Daily Briefings

The field managers provide daily briefings to the operational staff in the field. These briefings include the principle activity for the day, a review of progress, Task Based Risk Assessment, and PPE requirements and issues that need addressing.

Project Check lists

The field managers have a project check list to ensure that all items are in place to undertake the day to day activities safely. The list includes sections on:

 Documentation required;  Working areas;  Worker training;  Daily briefing given to Regional Administration, counterparts, hired laborers, drivers;  PPE (correct use) by counterparts, hired laborers, and visitors;  Storekeeper (on time, co-operative);  Variations to work plan;  Packages and labeling;  Health monitoring.

Daily Progress Report

 List of project staff;  Planned activity for the day;  Actual activity undertaken.

Weakly Progress Report

 Principle tasks undertaken;  Progress against work plan;  Safety issues;  Update risk assessment  Variation;

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 Instructions issued;  Operations planned for the following week.

Work Plans

 Weekly plan with detail for each day;  Zone work plan with summary detail.

Forms and details related to each of the activities are given in Annex 14 to show a better picture of what is going on in addition to the above generic type of listing.

6.13.2 NPM and IC Monitoring

The National Project Manager and International Consultant should undertake regular visits to the field to observe the teams‟ activities. The frequency of these observation missions should be such that each team is observed as often as necessary. To ensure that normal behavior is observed, the observations should be unannounced. The NPM also monitors the effectiveness of the Contactor.

6.14. Monitoring of the PMU

It is proposed that a suitably qualified independent consultant be procured to monitor and evaluate the performance of the PMU. The consultant should necessarily be well qualified in important aspects of OP management based on both academic training and experience acquired through undertaking similar assignments.

6.15. Project level grievance/complaint management system Grievance mechanisms provide a way to reduce risk for projects, offer communities an effective avenue for expressing concerns and achieving remedies, and promote a mutually constructive relationship. A well-functioning grievance mechanism: 1. Provides a predictable, transparent, and credible process to all parties, resulting in outcomes that are seen as fair, effective, and lasting. 2. Builds trust as an integral component of broader community relations activities. 3. Enables more systematic identification of emerging issues and trends, facilitating corrective action and preemptive engagement. Grievance or complains from local, endemic people and stakeholders on the project during implementation will handle by the project team as given briefly in the Annex 15 & 16

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CHAPTER VII ANALYSIS OF ALTERNATIVES

7.1 Obsolete lindane Safeguarding Alternatives

This section assesses the project alternatives for dealing with the current obsolete lindane stockpile in Al Adabeya Port. These alternatives have been extensively discussed during the project preparation. The two major alternatives, which have been proposed during this study and have been discussed with the stakeholders during the public consultation workshop in May and June 2014, are: "without project" and "with project". Both alternatives are discussed below in more detail. The GEF project alternative will support on-the-ground investments for environmentally safe disposal of lindane; 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; sitting of facilities; methods of collection, repackaging and storage; institutional & socio-political risks. It must be stated that the alternative disposal options for obsolete lindane stockpile are largely the same; however, all notable differences are highlighted below.

In principle, safeguarding is required for obsolete lindane stock, pesticide contaminated empty containers, contaminated equipment, lindane contaminated wastes, and contaminated soil.

With respect to the safeguarding needs of the obsolete lindane, implications of three alternatives were considered and analysed. The alternatives are: i) no safeguarding action, ii) safeguarding at the current location, iii) safeguarding at the main pesticides storage facility of the Ministry of Agriculture (obsolete lindane stock should be transferred from Al Adabya Port).

Results of the Strengths, Weaknesses, Opportunities, and Threats (SWOT) analysis is summarized in Table 7.1.

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Table 7.1: SWOT analysis of alternatives for safeguarding obsolete pesticides Alternative Strengths Weaknesses Opportunities Threats

No Safeguarding and Existing Environmental and safeguarding Transportation environmental and health impacts could action costs are not health effects will worsen due to incurred. continue at the deterioration of current storage site containers and Transportation is and in their external influences completely voided. neighborhood. such as natural and anthropogenic disasters. Safeguarding Risks during Repackaging costs There is a Availability and at current Transportation of are still incurred. potential of full timely disbursement store location obsolete lindane Management of utilization of field of funds may be stocks from current obsolete lindane at managers trained constrained. site to the main the current site will during previous collection centre is be rather emergency avoided. demanding. safeguarding Transportation of efforts. This obsolete lindane would add stockpile from the value to the current location to impact of temporary storage their training area to the vicinity of the ships is still needed. Safeguarding Management needs Concentration of There is a Location of the large at the main are reduced and risks during the potential of full collection center may pesticides management transportation from utilization of field incite resistance and storage facility effectiveness Al Adabeya Port to managers trained protest by local of the Ministry enhanced because the main pesticides during previous Communities in the of Agriculture the problems due storage facility of emergency neighborhood of the and Land to the handling and the MALR. safeguarding stores. Reclamation repacking at the efforts. This Availability and (MALR) (OP current location of Higher cost due to would add timely disbursement stocks should containers on the the need to value to the of funds may be be transferred yard of the port are construct new impact of constrained. from Al completely or improve their training Adabeya Port) avoided. existing stores Transportation of to meet the pesticides from minimum the main pesticides requirements storage facility of and standards MALR to the shipping port can Higher cost due to be optimized. the transportation Risks from from the port and obsolete lindane back to the port for are completely the final shipment. avoided at the Condition of current location of infrastructure and the containers in roads from site to the port. the main storage facility in Cairo.

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This Alternative arrests the Risks associated progression of with accidents, environmental and spills, fire during health impacts handling, from the handling transportation, and and repacking on loading etc. the yard. Assessment of the management systems and procedures in place by port and transportation authorities, including licenses, clearances, driver safety requirements, conditions of containers, conditions of transport vehicles, labeling of the freight containers and the transport vehicles etc. Requirements related to official GOE clearances for transportation of hazardous waste. Risks associated with occupational health and safety of workers

It is noteworthy that in Table 7.1, unlike the options of safeguarding at the current temporary storage locations of the obsolete lindane on the yard, the option of no safeguarding action does not present any meaningful opportunities. This is understandable because the no action option simply maintains the status quo whose deficiencies are the very reason for carrying out this project.

Considering the discussion on the rationale for establishing safeguarding at the main pesticides storage facility of the Ministry of Agriculture and Land Reclamation (obsolete lindane stock should be transferred from Al Adabeya Port), and based on the SWOT analysis presented in Table 7.1, it is evident that the safeguarding at current store location on the yard is most favorable. This is the one recommended for adoption in subsequent decisions in this project.

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Table 7.2: SWOT analysis of alternative transport means for obsolete pesticides from shipping port to disposal facility outside the country Alternative Strengths Weaknesses Opportunities Threats Air freighting Generally fast Generally very The fact that air Prohibitive expensive. freighting is faster insurance costs A shortage of can accelerate and compliance appropriately the execution requirements. equipped transport as a There may be a planes for whole. shortage of willing transporting airline companies. the pesticides Environmental and Lack of health effects are experience in not easy to predict handling or contain in case hazardous wastes of accidents. of this kind. Some airports may refuse planes carrying pesticides to and. Sea Comparatively Generally slow, so Experience from Exorbitant freighting very cheap. transportation similar previous insurance costs Ships have takes a long time. project can be and compliance provision for used. requirements. transporting There may be a hazardous wastes shortage of willing of this kind. shipping companies. Some ports of call may refuse ships carrying pesticides permission to dock.

It is evident from the SWOT analysis presented in Table 7.2 that, for transporting obsolete lindane from the shipping port to the ultimate disposal place, sea freighting is the favorable option. There is no doubt that the advantages of sea freighting over air freighting are not disputable.

7.2 Pesticide and Pesticide Containers Disposal Alternatives

With a view to objectively determining the best options for the disposal of the obsolete lindane and their containers, identification of disposal alternatives was done on the basis of where rather than how the obsolete lindane could best be disposed of. It was assumed that proven and established disposal technologies as well as appropriately competent and experienced disposal contractors would be employed. The options for disposing of the obsolete lindane within the country and shipping to another country for

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eventual disposal were considered and analyzed as summarized in Table 7.3. Similarly, the options for disposing of obsolete lindane within the country and shipping to another country for eventual disposal were considered and analyzed as summarized in Table 7.4

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Table 7.3: SWOT analysis of alternatives for disposal of obsolete lindane Alter Strengths Weaknesses Opportunities Threats nativ e Dispo The shipping component of the Lack of suitable There is a Funding sal cost is avoided. Hazardous waste potential for constraints withi There is capacity building in disposal utilization of may derail n obsolete pesticide management. technology and cement kilns that disposal the There is contribution to the local equipment. available in the efforts. count economy. Inadequate country. Potential ry suitable human protests and resources to carry resistance out disposal from operations. communities A lack of in the institutional neighborhood system for of disposal guiding, facilities. overseeing, monitoring disposal operations. Delays due to necessity of acquiring and installing disposal facilities. Dispo Disposalexperts,technology Disposal costsare There is an Long sal andequipment areavailable. generallyhigher opportunity shippingtime outsi System fordealing with due toshipping forgainingexperti may de Obsoletepesticides(contractors,re costsand seandexperience delaycommen the gulators,emergencyresponders) higherlabor costs. forlocalcontracto cementof count isin place andeffective. Does not rs disposal ry The pesticide buildlocal andpersonnelwor operations. Disposalproblem obsoletepesticide king handin hand Exorbitantinsu iscompletelyeliminated. disposalcapacity. withforeign rance Disposal canbe carried Does contractors. costsand outimmediatelyafter arrival notcontribute compliancereq ofpesticideswithout delays,hence tothe uirements. areduction inliabilityperiod. localeconomy. There may be Possible ashortage delaysdue to the ofwillingshippi needto wait ngcompanies. forsuitableshippin Some ports gfacility. ofcall may Long refuseships shippingtime may carryingpestici delaycommence des mentof permission disposaloperation todock. s. The lack of suitable hazardous waste processing and disposal technology and equipment asserted in Table 7.3 is attested to by the fact that incinerators suitable for destroying

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hazardous wastes such as OP stocks, especially on the scale required in this project does not exist in Egypt. Although there are incinerators used for destroying medical wastes, these are generally small and designed to suit only relatively small quantities of medical wastes. Most importantly, the incinerators do not conform to any recognized standards. Additionally, the use of cement kilns for destroying the obsolete lindane stockpile is also out of the question. Apart from the technical limitations associated with this option, recent consultations with the owners of the kilns indicate that they are firmly against the idea of using their kilns for destroying obsolete lindane stockpile.

In view of the preceding discussion and the SWOT analysis summarized in Table 7.3, it is more advantageous to carry out the final disposal of obsolete pesticides outside the country than within the country.

In addition to the above, it can be noted that due to the lack of incinerators that are large enough and compliant with recognized standards, destruction of obsolete lindane stockpile, empty bags, and other types of wastes by incineration in Egypt, is currently not possible.

7.3 Comparison of options for the involvement of PMU and contractors in obsolete lindane management aspects

In consideration of the fact that the different tasks involved in safeguarding, transportation, and disposal of the OP can be carried out by EEAA and its supporting and entities, on the one hand, and contractors, on the other, a comparison the options involved is important. The alternatives are: i) PMU alone, ii) contractors alone, and iii) PMU together with contractors. Results of the Strengths, Weaknesses, Opportunities, and Threats (SWOT) analysis is summarized in Table 7.4.

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Table 7.4: SWOT analysis of alternatives for safeguarding obsolete pesticides Alternative Strengths Weaknesses Opportunities Threats

PMU alone Is experienced Has There is an Current in emergency insufficient opportunity deficiencies safeguarding manpower for acquiring in PMU may Is familiar with Lacks the expertise, delay the the local required experience whole project administrative, infrastructure and For project social - and technologies technology components economic, and Has limited taking place environmental Technical outside the needs competence in country, PMU Generally some aspects. may have to cheaper than Has no team up with contractors jurisdiction international outside contractors Egypt anyway Contractors Have requisite Are generally Utilization of Local competence, ignorant of local contractors technology, and the local personnel and will still need infrastructure conditions subcontractors Have Are generally will lessen experience expensive for some from similar managing weaknesses undertakings small OP stocks PMU and Will benefit Some There are Pursuance of contractors from the operation opportunities some public strengths of regulations of for both to as well as both PMU and the public learn from one private contractors PMU may another and interests may hinder joint reinforce one be efforts in another compromised some aspects

Table 7.4 reaffirms the idea presented earlier that some tasks are best handled by the PMU while others are best handled by contractors because neither the PMU nor the contractors are best suited to handle all the OP management work.

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CHAPTER VIII PUBLIC CONSULTATION AND STAKEHOLDERS ANALYSIS

8.1 Introduction The aim of this chapter, as part of the Environmental and Social Impact Assessment (ESIA) for the Disposal of Obsolete Pesticide Stockpile from Al-Adabeya Port, Suez, is to follow the required Egyptian and international standards and guidelines, ensuring that stakeholders experience project benefits, are protected from potential negative impacts and adopt the project, with limited risk to themselves and the project implementation team, and with sufficient ‘ownership’ to support security and sustainability. The study was conducted from May – June 2014, is the first part of the process to ensure that the impacts on the project are properly and fully understood and accounted for.

The objectives of public consultations are divided into three categories as follows:

1. The fulfillment of the requirements of ESIA as indicated by the EEAA’s guidelines which is mandated by the Law No. 4 of 1994 and its amendments of Law No. 9 of 2009. The public consultation is also required by FAO’s Environmental Management Toolkit for Obsolete Pesticides which are the main guidelines used for this study as required by the government in addition to Basel Convention and Stockholm Convention standards and guidelines. 2. The stakeholder engagement process includes both dissemination of project information, and consultation on stakeholders’ opinions and priorities, working together in an iterative process. This is vital because the information to be disseminated and the information collected through consultation each inform the other. 3. The stakeholders’ consultation activities ensured that stakeholders targeted for engagement are representative of all concerned and related populations and organizations including national and international as well as governmental and nongovernmental. Special emphasis was done to tackle the issues related to the most vulnerable stakeholders who might be more exposed to negative project impacts, less able to access project benefits and more difficult to engage in project decision-making processes.

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The activities of the public consultation and stakeholder’s analysis were divided into three phases:

 The preliminary stakeholders’ consultation which is required to identify stakeholders, disclose project information and discuss stakeholders’ concerns. It is would allow for better formulation of the activities of the following deeper analysis of stakeholders and the project’s social impacts as well as economic and health impacts.  The stakeholders analysis which was done to provide an in-depth analysis of the stakeholders characteristics and a true image about the expected impacts of the project on its associated stakeholders  Public hearing which was conducted to disclose project results, provide a forum for all stakeholders to discuss their concerns, allow for the study team to answer questions and evaluate public attitudes towards accepting the study results and proposed project activities.

8.2 The prelim inary stakeholders’ engagement and consultation

The preparation of the stakeholders’ consultation started by communicating the concerned authorities such as EEAA the main office and the Suez Regional Branch in, Ministry of Defense, the General Authority for Red Sea Ports (GARSP) which is a part of the Maritime Transport Sector (MTS) – Ministry of Transport, the Suez branch of the General Company for Silos and Storage (GCSS) – Ministry of Supply and Internal Commerce and representative of non-governmental organizations in Suez with environmental concerns and activities.

8.2.1 Methods and tools Consultation and engagement with stakeholders was undertaken using a number of methods and tools. These were adapted to the tight timetable for the project duration. The tools used for the preliminary stakeholders’ consultation were as follows: . Stakeholder Group Discussions were used to disseminate project information and consult stakeholders. Where questions were raised during discussions for which the ESIA team did not have information, these questions were noted and

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follow up information obtained from documents and phone communications with the main stakeholders such as the EEAA main office and Suez regional branch. . Site visits were used as an initial scoping tool, to view physical boundaries of the storage site, and observe the different land uses being carried out on the storage sites, as well as to observe the neighboring facilities and activities. It was done using a specially constructed site identification form (Annex 17). . Semi-structured Interviews were carried out with as a means to raise awareness about the project and foster support for the detailed social survey especially among the stakeholders with less authority and awareness such as the site workers. It also served the purpose of collecting general information about the stakeholders and their general views and perception which are crucial in designing the questionnaires for the detailed survey.

8.2.2 The process of the preliminary stakeholders’ consultation The location of the public meeting planned for the preliminary stakeholders’ consultation was selected as close to the targeted stakeholders’ places of work and/or residences as possible and made easily accessible to those expected to attend. Accordingly, the project team agreed to make this meeting in Suez Governorate and preferably at Al-AdabeyaPort itself. GARSP offered that the meeting would take place in its administration building which was convenient for all other stakeholders. The project team communicated the different authorities and organizations that are related or having working tasks or activities related to the Lindane storage site at Al-Adabeyaport. Through these communications representatives from all concerned organizations were appointed to attend the stakeholders’ group discussion. Twenty one people attended this meeting beside the project’s team. It included:

. representatives and from GARSP . representatives from the EEAA – Suez Regional Branch . representatives of environmental NGOs in Suez

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. representatives of the GCSS administration as well as the company’s employees responsible of the storage hanger where the Lindane is stored

The main categories of information to be presented to the stakeholders and collected during the activities of the preliminary stakeholders’ consultation are shown in Figure 8.1.

Information given and Information Collected presented

• Stakeholder Identification • Project description • Knowledge about the Lindane and its current • Project Objectives storage • Perceived impacts • Project Activities • Proposed Mitigation measures • Project scope • Preferences or Suggestions • Communication • Preferred Means of channels Communication

Figure 8.1: Information presented/given and collected during preliminary stakeholders’ consultation

After the group discussion meeting was concluded, the project team was accompanied by the stakeholders to visit the Lindane storage site. The project team did the following activities: − Filling in the site identification form (Annex 17). − Fill in the risk assessment evaluation form. − Identify the surrounding facilities, their owners and activities. − Take pictures of the containers, the storage site and all facilities, buildings and general surroundings. − Identify the safety and security measures available at the storage site.

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− Determine the suitable locations for sampling activities especially those related to air quality assessment apparatuses as they require power supply and secure area at a position from the Lindane storage containers.

After the site visit activities were completed, the study team was divided into three groups. These groups were as follows: − The first group met with representatives of different stakeholders to select the relevant documents that are required for the ESIA study and would help in designing effective management plan for the final disposal for that obsolete pesticide. − The second group conducted semi-structured interviews with the stakeholders who attended the preliminary public meeting. − The third group remained in the storage site to interview the site workers. They are very important stakeholders as they have daily work tasks and activity in the storage site which is usually very close the Lindane containers compared to all other stakeholders.

8.2.3 Results of the preliminary stakeholders’ engagement and consultation i. Stakeholders identification The stakeholders identified for this study are presented in Table 8.1. The first group of primary stakeholders is the site workers and supervisors. They are the most affected group by the presence of the Lindane stockpile in the premises of their daily work space. GCSS and some of its administrative staff are the second group of the primary stakeholders. As the Lindane is stored in a storage site belonging and managed to GCSS, the company itself and its administrative staff are the second group of primary stakeholders. They were identified as primary stakeholders because they have working tasks that would make them come occasionally in proximity of the storage site. The company is also responsible for the health and well-being of its employees working on near the storage sites which is considered another reason for classifying it as primary stakeholder.

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Table 8.1: Primary and Secondary Stakeholders Groups Primary Stakeholders Secondary Stakeholders

. Site workers and supervisors of . The Government of Egypt GCSS. (Ministry of Transport, Ministry of . GCSS company. the Environment, Ministry of . The Administration of the Agriculture and Land Reclamation, GARSP especially the staff in Al- Suez Governorate) Adabeya and the . Environmental and Social NGOs environmental Sector of in Suez Governorate. GARSP. . Academics, researchers and . EEAA main office and Suez consultants. branch. . International Organization: World Bank, GEF and FAO

The third group of primary stakeholders includes administrative and environmental staff of the Al-Adabeya Port and GARSP. They are the responsible authority for all activities occurring with the port boundaries. The EEAA and regional branch in Suez are now the designated authority responsible for regulating, managing and supervising the activities of the project of final disposal of obsolete Lindane stockpile in Al-Adabeya Port.

The secondary stakeholders were mostly identified through the review of secondary literature and documents. They included governmental organizations such as representatives from Suez City council (representatives of the governorate). The secondary stakeholders included also representatives of the ministries that would have jurisdictions in the area or would be involved in the activities of final disposal. The nongovernmental organizations are also presented by social societies that have activities related to the environment of Suez Governorate. This group includes also international organizations because of the nature and funding of the project activities.

The nearest residential area is located at a distance of more than 6.5 km in the North Northeast direction from the port. Major residential areas and population cluster are found at more than 8 kilometers Northeast to the storage site. There is also a small agglomeration of houses located North Northwest to the project site at a distance of 1.36 km. All these areas are located not only upwind from the project site but also far

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away from the influence regions according to the risk assessment of worst case scenario. Therefore, the general public would not be subjected to the project’s activities. ii. Key finding of the preliminary public consultation The main outcomes of the preliminary public consultation using group discussions, site visit and semi-structured interviews are as follows: . The site belongs to GCSS and it is the owner of the site but not the owner of the stockpile. There are no activities whatsoever being done to these containers or the area surrounding them as determine by the court order and general attorney’s decision. GCSS also is not allowed to open the containers or move them from their location by court order and the general attorney decision. . There is a safety distance of 50 meters for any other activity related to the site operations. The site visit ascertained the absence of any activity or other stored containers near the Lindane stockpile containers, but there was no special fencing or any other element to indicate the safety distance. . There was a unanimous agreement from all stakeholders’ representative attended the group discussion or participated in the semi-structured interview that these containers must be disposed as soon as possible to avoid its negative impacts on the human health and the environment. . They empathized on the importance of applying the most cautious practices for the disposal activities especially those related to the transportation from the site to the ship assigned for transporting the containers to its final disposal distention outside the country. . There were no accidents, spills or injuries attributed to the Lindane as indicated by all stakeholders. . There were no complaints from the neighboring facilities or any other authority except the complaints from the smells which were only reported by site workers, supervisors and GCSS administrative staffs who regularly visit the site. . The site does not contain the required security measures such as proper fencing, surveillance camera or locking. The Lindane containers are guarded as part of the storage site with no special guards assigned for their location.

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. There are no proper signs, instructions poster, placards, emergency plan or personal protective equipments (PPE) special for the Lindane storage site. These safety components are presents but only those special for loading, unloading and storage purposes. . There are also no special safety or environmental plans or management procedures by the GARSP administration and its environmental division.

8.3 Stakeholders Survey and Analysis

In order to get a true image about the expected impacts of the project on its stakeholders, a survey was conducted. Representative samples of the stakeholders were interviewed. The different characteristics of the stakeholders’ categories and groups required the construction of different questionnaires for each group.

8.3.1 Methods and tools i. Secondary data sources Before the start of Socio-economic baseline field work a review of secondary data was undertaken. This included: . Relevant literature and academic studies; . Project related technical documents and reports. ii. Primary data sources

Four questionnaires were formulated to fit the identified stakeholder groups. The questionnaires were also used to further engage the stakeholders in the process of the project by individually asking their opinion of the potential impacts of the projects and how to mitigate them. The survey was also conducted to collect information about the possible health impacts that could affect the most sensitive groups of stakeholders. The survey was done by repeated visits to the stakeholders to conduct face-to-face interviews using structured questionnaires. These questionnaires are as follows:

. Questionnaire for storage site workers (Annex 18).

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. Questionnaire for government agencies’ representatives. The questionnaire was also designed to be suitable to collect information from the local NGOs (Annex 19). . Questionnaire for supervisors and managers (Annex 20). . Questionnaire for neighboring facilities (Annex 21). The study used a highly representative sample for the primary data collection. It was of sufficient size and structure to include representatives of all stakeholder groups. The number and characteristics of the interviewed individuals for each stakeholder group will be presented in the next section. iii. Data analysis The data collected in the questionnaires were entered using a specially constructed database using both MS Excel and SPSS. iv. Data limitations . Time shortage was the most significant constraint and this hindered most of the study activities. . The sample size was adequate for the study as a whole, but not for a few specific areas; . The lack of medical records limited the accuracy and comprehensiveness of some of the responses in the health survey; . There were certain preservations by some respondents to answer certain question which will increase their liability or the liability of their organizations. Therefore, sensitive questions were indirectly raised in some discussions and structured interviews; . Data analysis is mainly descriptive; more in-depth co-variations and significance testing was not possible.

8.3.2. Results of the stakeholders survey and analysis i. Stakeholder category: The survey concentrated in the primary stakeholders as they are most affected by the project activities (Figure 8.2). There was also special emphasis on the site workers and

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supervisors in order to capture the impacts of the long storage of the Lindane on them as they have the most frequent and longest exposure. The distribution of different types of stakeholders is depicted in Figure 8.3.The samples included key persons for each group especially those at high level of administration and decision-making in the organizations.

Figure 8.2: Stakeholders categories included in the survey sample

Figure 8.3: Distribution of the stakeholder groups ii. Stakeholder characteristics:

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The age distribution of the stakeholders included in the sample is illustrated in Figure 8.4. Most of the stakeholders included in the sample are above 30 with very comparable percentages for the other three older groups. There is an important factor that would increase the convenience of the having older people in the sample. Older individuals would have spent more time in their jobs which would increase their knowledge, exposure and experience with the Lindane stockpile which is stored in the same site since the late 1990’s.

It should be noted that more than 90% of the stakeholders included in the sample are permanent residents of Suez Governorate. There were no illiterates in the sample. Except for the site workers, all stakeholders included in the sample have university degrees (Figure 8.5). It is mainly attributed to the fact that most of the stakeholders are employed in jobs that requires certain level of training and education.

Figure 8.4: Age distribution of the stakeholder sample

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Figure 8.5: Distribution of the education level of the sampled stakeholders

iii. Experience in the storage site: It is clear that most stakeholders have years of working experience in the site or in a position that have work tasks related to the site of at least five years (Figure 8.6). There was only about 5% of the sample with stakeholders having experience of less than one year. This, as explained before, along with the high education level and the age of the individuals included in the sample would increase the significance of the results of this survey especially those related to environmental and health impacts.

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Figure 8.6: Years of working experience in the storage site iv. Knowledge of Lindane and its impacts: It was found that the workers group has the least knowledge of the nature of Lindane (Figure 8.7). The knowledge of all members of all other groups was the complete opposite they were able to identify that Lindane is an insecticide used in agriculture. These results have significant implications as they reflect the limited knowledge of the people who are most exposed to the pesticide. This would certainly increase the risks on the site workers. It also shows that there is an urgent need for the quick removal of the Lindane from its current position.

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Figure 8.7: Knowledge of the nature of Lindane

There was about two thirds of the workers group that they know that Lindane can have health effect (Figure 8.8). The GCSS administration refused to mention the health impacts of Lindane in order to avoid any legal liability that could occur as a consequence of their answers. Hence, their group indicated that they don’t know if Lindane would have any health effects in their interview. The supervisor group has only half of its member to know that Lindane have harmful health effects. All members of all the other groups also knew about the health impacts of Lindane. They mostly stated that it can cause cancer. However, there were limited individual answers that added also mutagenic effects, toxicity and serious damages to the respiratory and digestive systems.

The knowledge of the environmental impacts of Lindane was quite limited among most of the stakeholders for especially the site workers, supervisors and the port administration (Figure 8.9). Their definition of the environmental impacts was even more limited. They only stated general impacts such as pollution and environmental deteriorations. There were only limited answers that added specific impacts such as air pollution, water pollution, crop contamination, and persistent residues in the soil.

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Figure 8.8: Knowledge of the health impacts of Lindane

Figure 8.9: Knowledge of the environmental impacts of Lindane

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Some members of the NGOs group mentioned the economic damages which would occur from the loss of the storage area being devoted for this pesticide. It was also added that the country would incur a lot of expenses to safely dispose these Lindane and all other pesticides in other places in the country. A similar answer was given by the GCSS administration representatives who emphasized the economic loss to their company from the opportunity cost of the rent of the place occupied by the Lindane containers. They also added that some customers would refuse to let their containers be stored in the whole site to avoid health hazards from being in close proximity with the Lindane containers. This made the company lose many customers to other storage companies in Al-Adabeya Port.

The stakeholders were asked about the source of their knowledge of the environmental and health impacts of Lindane. The site supervisors and workers groups indicated that it was mainly through their colleagues and the visits from the committees who studied the containers. The same source was also shared by the GARSP and GCSS administrations. Some member of the government and NGOs indicated the use of web sources and news papers. This indicates that the results of the previous studies were not shared among all stakeholders especially those most sensitive, namely the site supervisors and workers. v. Safety measures and regulations: It was found that the site does not hold any license specific for storing the Lindane. There wasn’t any security plan or special measure formulated specifically for the Lindane storage site and containers. There was, however, 24 hours guarding and surveillance which was done to the total storage area with nothing specific or specially done for the Lindane storage site. There was also restricted access to the containers and its site. The restricted access to the Lindane storage site and containers reduced the chances of the occurrence of any accidents related to them.

There was no special training programme for the workers to handle hazardous materials such as the Lindane. There were also no emergency plans or activities related

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to dealing with accidents, spills, fires or other emergency situations which were specially formulated for the Lindane storage site. The situation was the same for both the inspection and monitoring plans. The port administration and GCSS administration related that to the fact that they are not allowed to handle or deal with the Lindane containers. The site, however, contained emergency plans, emergency procedures, instruction posters, fire extinguishers and first aid kit which were provided as a measure for the general activities of the site but not specific for dealing with situations where hazardous materials were involved.

The site contained personal protective equipments (PPE) which were provided only to handle the storage and unloading activities. There were no specific equipments for handling hazardous materials such Lindane. The site workers were provided with safety masks with filters and without filters. They were also provided with overalls, safety boots, safety glasses and helmets.

There was also regular monthly and bimonthly inspection by the safety officer of the GCSS. This answer was given by all site workers and supervisors as well as the GCSS administration representatives. It should be noted that in spite of the availability of these PPE, some of the site workers indicated that they don’t wear them unless they find a need for it. They usually do their work tasks in their regular clothing. vi. Documentation: EEAA, the GARSP administration and the GCSS administration are the only three authorities that undertake documentation of any proceeding, reporting or correspondence related to Lindane stored at Al-Adabeya Port.

vii. Lindane exposure: The survey results indicated that the site workers and supervisors are the only stakeholders who have regular exposure to any risks associated to the Lindane

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containers. All other stakeholders groups do not visit the site regularly or with time duration to allow for significant exposures.

All the storage sites employees work 8 hours a day all week except weekend on Friday and the national holidays except for the guards who have a 12 hours shifts with no weekends. They are the employees most exposed to the risks of Lindane in terms of duration and frequency. They are also responsible for opening and closing the containers for inspection, sampling and other permitted study activities.

viii. Health issues: As explained in the previous section, the site workers and supervisors are the most vulnerable group to risks associated with the Lindane exposure which stored at Al- AdabeyaPort. Therefore, the health assessment will generally concentrate on this group. They were asked about their health symptoms which could be attributed to Lindane exposure. They were also asked about the frequency of occurrence of these symptoms and the treatment applied.

About 65% of the site workers are smokers. They have been smoking for periods ranging from 3 to 35 years. They smoke from 10 to 30 cigarettes per day. There are about 12.5% of the site workers who were smokers but gave up smoking more than 5 years. It was found by analyzing the data that there is no significant correlation between smoking and the complaining of the symptoms related to Lindane exposure. Some smokers reported no symptoms at all while some non-smokers reported complaints of more than two symptoms.

As shown from Figure 8.10, the rate of symptoms occurrence is very low for all symptoms except the eye itching which was more common. It should be noted that the people who complained of eye etching indicated that it was frequent and some has also mentioned the co-occurrence of lacrimation. The GCSS administration stated also that they received many complaints from the site workers about the eye itching. They also mentioned that many workers would have such symptoms during their work in close

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proximity to the Lindane containers. This was also mentioned by 50% of the workers included in survey who complained of eye itching. Some members of the study team have also complained of eye itching during the sampling and field measurements and with longer period their eyes turned red. The literature also indicated that Lindane volatilized from heat vaporization could cause irritation of the eye which is considered early symptom of Lindane exposure and toxicity.

Although, the results above could not allow for decisive conclusion that the exposure to Lindane would cause these symptoms especially eye irritation, the repeated reporting of this symptom would indicate that the relationship to Lindane exposure is still highly probable. This could have been further proved if there were any records of the medical history of the site workers. Unfortunately, all the site workers stated in their interviews that they don’t take regular medical examinations.

Figure 8.10: Reported symptoms by the site workers

All site workers, supervisors and GCSS administration representatives stated that they always encounter a pungent pesticide smell whenever they come closer to the Lindane

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containers. They also mentioned that this smell would increase with the heat. This is quite in accordance with the fact that there is increase in the volatilization of Lindane with the heat. Although, the containers are sealed, they still have ventilation opening that would allow for the release of volatilized Lindane especially during the period of high air temperature. ix. The role of NGOs: As aforementioned, the NGOs included in the survey of this study are environmental NGOs with activities in Suez Governorate. The study team interviewed several members of these NGOs. It was found that their roles are restricted to awareness programs and mobilization activities for the Suez community to support the disposal of the Lindane stored in Al-Adabeya Port. Most of their activities were done in collaboration with the EEAA-Suez Branch. They usually end the seminars with the conclusion that there should be some quick actions towards disposing these containers outside the country.

The activities of these NGOs did not include any collaboration with any stakeholder other than the EEAA-Suez Branch. They also did not communicate any of the stakeholders. Therefore, it could be concluded that their activities and role was restricted to the awareness campaign to the general population of Suez Governorate. In spite of these limitations, their activities were very helpful in collecting public support for urging the responsible authorities to take the necessary actions to safely dispose the Lindane stockpile outside the country.

x. Knowledge of the project: It was found that the most of the stakeholders know about the Lindane disposal project except for the most vulnerable groups which are the site supervisors and the site workers with the latter having the least knowledge of the project (Figure 8.11).

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Figure 8.11: Stakeholders’ knowledge of the project

All representatives of the GCSS administration and the GARSP administration had previous knowledge about the project which was mainly obtained from the report and correspondence with the concerned authorities particularly EEAA. The representatives of the governmental agencies and EEAA representatives all knew about the project from their organizations. The NGOs’ representatives were found that they know about the project through their communication with the EEAA – Suez Branch while some have also read about the project in the news. xi. Stakeholders’ perception of the project impacts: The stakeholders’ perception of the project impacts were measured by asking if they see the project would have positive as well as negative impacts. They were also asked to give details about their perceived positive and/or negative impacts. It was found that all individuals from all stakeholders’ group perceive that the project will certainly have positive impacts (Figure 8.12).

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Figure 8.12: The perception of positive impacts of the project

The general consensus of the existence of positive impacts of the project by all stakeholders’ indicates the importance of the project to them. They have also expressed the urgent need for the quick implementation of the project. They also explained many positive impacts. Most of these impacts were shared by many stakeholders included in the survey.

The perception of the presence of negative impacts of the project is described by Figure 8.13. Most of the stakeholders participated in the survey did not perceive any negative impacts of the project. The participants, who thought that the project would have negative impacts, did not actually explain negative impacts of the project. What they stated as negative impacts are actually safety concerns rather than actual health or environmental impacts. The positive and negative impacts expressed by the stakeholders are explained in the Chapter V.

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Figure 8.13: The perception of negative impacts of the project

8.4 The public hearing

8.4.1 Overview Public hearing is a form of participation in which stakeholders and all those affected by the projected activities are brought together in a forum. Public hearings are also one of the best tools that can be used for public participation and consultation. It has become recently one of the mandatory requirements to projects classified as Category C according to the amended Egyptian Environmental Law (Law 4/1994). The main objectives for organizing these public hearings as part of the ESIA review process are: . to provide a forum for the proponent to inform the entire community of the outcome of the ESIA of proposed undertakings; . to verify the accuracy of the ESIA findings in relation to the situation on the ground; . to confirm that all the affected parties and stakeholders have been adequately consulted and have been part of the various decision-making processes; . Continue good relations with the stakeholders established during the ESIA surveys and the project’s ongoing consultation process;

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. to offer the affected and interested parties, as well as other stakeholders, the opportunity to express their opinions on any issues considered outstanding; and, . to promote effective public participation and ensure confidence in the Egyptian ESIA process as well as support for the proposed project.

8.4.2 Preparation of the public hearing After the completion of the project’s ESIA draft report, a summary of the draft report was prepared and translated into Arabic to be able to distribute it all concerned stakeholders. After the summary of the draft has been communicated and approved by the EEAA as the contracting authority, the project team started planning the public hearing.

The location of the public hearing venue was decided to be close to the targeted stakeholders’ places of work and/or residences as possible and made easily accessible to those expected to attend. It was also decided that the public hearing must take place outside Al Adabeya Port to avoid the inconveniences of the required entrance permit. The GARSP offered their conference hall in their main administrative building at Port Fouad district to be used as the venue for the public hearing. It was decided that it would take place on the 22nd of July 2014 at 11 am.

Invitations to the public hearing were sent to the stakeholders and all concerned parties which would be related or affected by the project proposed activities. Beside the sent invitations, many stakeholders were also invited by phone call to ensure their attendance. The announcement of date and place of the public hearing was also communicated to several newspapers and news agencies such as El-Youm El-Sabe’a, El- Masry El-Youm, El-Ahram News Portal, Sada El-Balad and the EEAA news page (Annex 22). It should be emphasized that the public hearing was highly anticipated by the news agencies as a results of several news reports that handled the topic for several years.

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8.4.3. The activities of the public hearing The stakeholders and other members of the public were welcomed at the door of the hall, asked, but not obliged to sign in, given handouts, and advised of the agenda of the hearing. They were provided with handouts which contained a copy of the presentation. The handouts included also a questionnaire that the attendees were requested to fill after the public hearing activities.

All of the public hearing’ proceedings were documented (video and transcript) and this resultant ESIA report is retained in the study database. The public hearing was conducted in Arabic including presentations and discussion to be convenient for all stakeholders and the general public. The meeting consisted of: . A "Welcome" and general instructions regarding the process . A presentation of the public hearing and overview of project . An overview of the EISA methodology and findings . The mitigation measures, environmental and social management plan and detailed description of the project activities . After the welcome words and the study presentations, the discussion was open to all attendees.

A lot of people have attended the public hearing. Beside the Governor of Suez and the Head of GARSP, there were 73 registered attendees of the public hearing. Most of them are primary stakeholders which comprise about 82% of the attendees. The secondary stakeholders represent the remaining 12%. There was high attendance from the media representing 31% of the secondary stakeholders. The representatives of NGOs were about 15% of the secondary stakeholders. The academia was represented by 23% of the secondary stakeholders group in addition to the study team. 8.4.4. Key topics discussed during the public hearing During the discussions, most of the participants expressed their general satisfaction of the quality of the study and the transparency in presenting the results. Most of the participants emphasized the importance of this public hearing and results of the study to relieve the general public regarding the impacts of the Lindane especially related to

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what was incorrectly reported by several media agencies about the presence of radioactivity from the Lindane containers. They also indicated the importance of the study as a long awaited concrete step towards the activation of the process of the disposal of the Lindane containers after long administrative and legal proceedings.

The discussion session was commenced directly after the presentation. They also urged the responsible authorities particularly EEAA to expedite the activities of the proposed project to avoid any further negative impacts that might occur from the Lindane containers in Al-Adabeya port. The following are the key topics of inquiry and concerns that were raised by the attendees of the public hearing and replies of the project team.

. The precautions regarding handling the Lindane and its containers and the safety measure to avoid accidents or spills. − The reply by the scientific team of the study was that the study has proposed a strict management plan which followed the national and international guidelines and regulations in its formulation. Therefore, if the proposed plan is followed by the implementing agency the risks will be highly minimized and contingencies are accounted for.

. There was a question about the population and demographic data as they are not very recent and about the use more of recent statistics such as those provided by the Human Development Index reports of UNDP. − Regarding the statistics used for the population characteristics, the reply was that these are the most recent available and reliable statistics. However, it was indicated that the study team will be pleased to update the statistics if any of attendees have more recent data. It was also indicated that most recent data from the UNDP-HDI are included in the study report.

. Several attendees asked about the time frame of the implementation of the project.

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− The reply was that it is expected to take about nine month after the final approval of the study.

. There was a question about the safety and control measure for the process of repacking the Lindane packs . The study team explained that the study has a very comprehensive management plan including all the safety measures that should be applied not only during repacking or transportation but also during every single activity for the disposal of these containers. The management plan also includes contingency and emergency plans. The plan clearly and thoroughly describes each step and the procedures required for applying the disposal activities. The plan also describes the responsibilities, tools, equipments and apparatuses required for implementing each step.

. Several attendees raised the question of the presence of a monitoring plan to assess the impacts of the projects activities during their implementation. − The study team explained that there is a proposed environmental monitoring plan. The plan includes all the monitoring requirements for each activity and phase of the disposal project. It contains the parameter to be measures, how they should be measured and at which frequency. These monitoring activities will have a hierarchy of supervision that would allow for rigorous measurements and accuracy. The monitoring plan for the site will continue even after the disposal of the containers to make sure that there are no residues left in the site.

. The precautions and safety measures regarding the transportation of the Lindane to the shipping vessel was of a major concern as expressed by many attendees. − The transportation activities are proposed to take into consideration the route and timing of the transportation. It must be done by licensed train drivers who would follow the safety procedures according to the plan proposed by the study. The precautions with the transporation process

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are described in details in the plan included in the report. It would consider also the occupational health and safety standards for such processes. Each transportation vehicle has its full safety kits as described by the plan. The plan also described the roles and responsibilities of the defense and fire departments in the port. The study has followed the related national and international standards of such process and activities when developed the management plan and its activities and procedures.

. There was question was about the presence of any health risks to the workers at the sites where the disposal activities take place. − The team has also asserted that the management plan considered the safety of the site workers and it contains measures and procedures that will minimize the workers risk exposures especially if the proper handling is followed and the required safety equipment are provided and used. . He also asked about the impacts of the storage of Lindane on the surrounding areas especially considering the long period of storage in the port. − The team explained that of course the presence of Lindane has health and environmental effects. They explained that the study has meticulously studied the environment surrounding the containers. The presence of Lindane in closed containers which were not allowed to be dealt without proper clearances by the concerned authority made the impacts of the Lindane very minimal to the workers.

. The attendees emphasized the importance of careful selection of the contractor or the company implementing the project’s activities. − The reply by the scientific team of the study was that it will be done by international tender, which would allow for selecting companies with sufficient experience and known reputation. This was asserted by the EEAA representatives that the agency will select carefully the contractor and would closely monitor the implementation of the activities.

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. There were some questions about the impacts on the general public especially the agglomeration of small houses present near the port. − The study contains a thorough risks assessment which studied all possible scenarios. In the worst case scenario, if all the Lindane is spilled on the ground, there was a zone of effect. It was found that the random agglomeration of houses would be outside the effect zone. The study team included grievance mechanism (Annex 15) for any complain by the general public about the project activity.

. There was a concern that was shared by a number of participants which is about the mechanism by which the contractor or company implementing the project would be closely monitored. − There was a suggestion that selected representatives of EEAA along with other competent authorities would be assigned to be present at the project site during its implementation phase. The team agreed on that the contractor should be closely monitored by the competent authorities. They also explained that the study specifically describe in details the activities of the project which would make it easy to monitor the implementation activities.

. Several questions were asked about the repacking process in terms of its details and the measures to ensure no spills. − The team answered that the storage of Lindane bags within the containers is in such a way that the materials should not spills. Also there will be checks on the integrity of the packs. The repacking activity would be done mechanically to decrease the risk of exposure for the workers. The daily repacking rate will be decided by the contractor according to the work plan and the time frame of the entire safeguarding activities.

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. An important issue was raised regarding how the area will be used after finishing all the disposal activities and decontaminating the site. − The reply by the scientific team of the study was that the details of the reuse after the decontamination are found in the report. As it is decontaminated and ascertained through thorough measurements that would not pose any risks to the workers it will be used for its original purpose by the GCSS.

. There was an important suggesting about making the results of the study available to the general public to ensure transparency. − Regarding the disclosure of the study results and its availability to the public, the EEAA promised that it will be uploaded on the agency website and made available to the public. The team also indicated that the full report of the study will be available to the public at EEAA an Alexandria University.

8.4.5. The results of the questionnaire of the public hearing There was a very positive feedback from all attendees in relation to the study and the project. This is expected considering the nature of the project as it is planned to get rid of a very risky material that has been present for a very long time. The attendees were asked to fill in a questionnaire provided along with the public hearing materials. The results of the analysis of the replies in the questionnaire elucidated and emphasized the highly positive response and acceptance of the attendees for the study and the project. It also highlighted the common areas of concerns shared by the attendees of the public hearing.

About 92% agreed that the project have positive impacts (Figure 8.14). The remaining were 4% don’t agree and 4% non-respondent. Most of the attendees also agree on all the impacts suggested by the stakeholders included in the SIA. They, however, shared common concerns that are very similar to those handled in the discussion. The most common concerns are related to:

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. The transportation activities: Most of the concerns explained in the questionnaire were related to this issue which indicates its importance to the stakeholders and the general public. Therefore, it should be the most sensitive phase of the project activities which should be implemented with the utmost precaution measures and requires careful preparation before undertaking this step.

Figure 8.14: Opinions on the presence of positive impacts to the proposed project

. The second is impacts on the workers in the site and the surrounding area. They respondents emphasized the importance of applying the best health and safety measures to avoid the impacts on this highly sensitive group who are also the most directly affected group. . The respondents also emphasized the importance of the concerned government agency to learn the lesson and make sure that similar situations are avoided in the future through the application of high penalties to those who would bring similar materials into the country. . They requested that the competent authorities should increase their awareness programs to the general public to educate them about how to avoid handling these materials and how to report or complain if they come across hazardous materials.

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The result was 64% agreed on the implementation of the project (Figure 8.15). This is lower than the responses of the presence of positive impacts of the project which could be related to the concerns discussed above and those discussed during the public hearing. However, only 4% of the respondents did not agree on the implementation of the project. Their reasons were that they skeptical about the possibility of the project to be implemented. Finally, 20% of the attendees completed the questionnaire did not answer that question at all.

Figure 8.15: Opinions of the respondents on implementing the project

The results displayed during the public hearing obtained high media attention. Several newspapers reported the outcome of the public hearing with comments from His Excellency Dr. Khalid Fahmy – Minister of the Environment and Eng. Ahmed Abu El- Soaud – Executive Director of EEAA. These newspapers are such as El-Masry El-Youm, El-Youm El-Sabe’a, Sada El-Balad and Akhbarak.net (Annex 22). The reports emphasized the importance of the results of this study as a crucial step towards the implementation of the actual disposal activities. The reports also showed positive feedback towards the results of the study that would make no for future rumors and misunderstandings. It

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would also comfort the public as it was an issue of high public concerned. The newspapers have also described the next steps that the competent authorities are planning to make sure that the project would start by the end of this year.

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EEAA Disposalof Obsolete Pesticide Stockpilein Al- Adabeya Port, Suez - Egypt EEAA

تقييم األثر البيئي واإلجتماعي للتخلص من مخزون المبيدات الحشرية المتقادمة بميناء األدبية – السويس – مصر

الملخص التنفيذي 1. خلفية الموضوع: إن مصر لديها مخزون هائل من المبيدات الحشرية المهملة التي تدهورت على مدار السنين، تعتبر هذه المواد من المواد خطرة كما بيّن مشروع إدارة الملوثات العضوية الدائمة المستدامة )P 116230(، يوجد 18 موقع مخصص لتخزين المبيدات في مصر ويمكن أن يصبح مرشحاً للمعالجة والتخلص اآلمن. وبنا ًء على البيانات المتوافرة فإن الكمية الكلية للمبيدات المهملة والعضوية الداشمة يترواح مابين 2250 و 4600 طن من هذه الكمية فإن كمية المبيدات العضوية الدائمة يتراوح مابين 250 إلى 1500 طن. والموقع الخاص بالملوثات العضوية الدائمة قد يحتوي على مصدر واحد أو أكثر من مصادر التلوث. إن الهدف اإلستراتيجي للسياسة البيئية في مصر هو تقديم وتكامل اإلهتمامات البيئية المتعلقة بحماية صحة اإلنسان وإدارة الموارد الطبيعية داخل كل السياسات الدولية، والخطط والبرامج والمشاريع الخاصة بخطة التنمية المحلية، إن الهدف متوسط المدى هو الحفاظ على الموارد الطبيعية والتنوع البيولوجي والميراث الطبيعي داخل محتوى التنمية المستدامة... أما الهدف قصير المدى هو تقليل مستويات التلوث الحالية وتقليل المخاطر الصحية لتحسين جودة الحياة للمواطنين والسكان في مصر. إن حماية البيئة قد اكتسبت أهمية متزايدة في مصر خالل العشرون عاماً األخيرة كنتيجة لتحسن التعليم الحكومي والوعي والذي أدى إلى ضغوط على الحكومة إلتخاذ اإلجراءات وزيادة خصخصة القطاع الصناعي، وكذلك المسئولية األكبر والضغوط من المتبرعين لضمان أن مشاريعهم مستدامة بيئياً وتساعد مصر في تحديث أنظمة إدارتها البيئية، إن الحكومة المصرية تلتزم بقوة بالتحكم في مخرجاتها الصناعية، وكذلك مراقبة كل العوامل التي تؤثر على مياه الشرب وتلوث الهواء، وقد صدقت الحكومة المصرية على معاهدة استكهولم إلدارة الملوثات العضوية المستديمة في مايو 2002.

232 Environmentaland Social Impact Assessment (ESIA) for the

EEAA Disposalof Obsolete Pesticide Stockpilein Al- Adabeya Port, Suez - Egypt EEAA

إن مشروع الملوثات العضوية الشبثه )المستديمة( المقترح يستهدف خطتين لضمان أمن البيئة... األولى هي التقييم البيئي والثانية هي إدارة المبيدات إن نتائج التقييم المتناظر قد أوردت أن سياسة تقييم البنك الدولي والمصري على التقييم البيئية كما ُعدلت في عام 2009 تقريباً متساويتين تماماً، وأن المستديمة تخضع لتقييم جدوى بيئية وتقييم أثر بيئي وتحضير خطوط عامة استرشادية لهذا التقييم )مرفق 1(. وكذلك وضع خطة عمل تشريعية وإدارية باإلتفاق الكامل مع معاهدة استكهولم والمعاهدات األخرى المتعلقة بالمواد العضوية المستديمة والتي تعد مصر من الدول المشتركة وعليه فإن الحكومة المصرية قدمت خطة تطبيق محلية تشتمل على: )1( إدارة وتخلص بيئي رشيد للفينوالت عديدة الكلورة والمبيدات. )2( إجراءات مؤسسية وتنظيمية قوية. )3( بناء الوعي وأنشطة ألصحاب المصلحة. وللمساعدة في الوصول لتلك األهداف فإن جهاز شئون البيئة المصري )EEAA( طلب من البنك الدولي تحضير مشروع GEF يركز على أنواع الملوثات العضوية، المستديمة، الثالثية واستكمال القدرات.. وبنا ًء على هذا الطلب تم تقديم مقترح بالمشروع وتم الموافقة على تمويله في يونيو 2009... يهدف المشروع إلى دعم الحكومة المصرية في إدارة المبيدات والملوثات العضوية المستديمة والفينوالت المكلورة ويعرض اإلستثمار في بعض المواقع الصغيرة كإثبات لحسن اآلداء. إن ميناء األدبية هو أحد تلك المواقع المصرية والمشروع هو أساساً مشروع تنظيف يجلب منافع بيئية وصحية قوية ولكن لضمان إن كل األنشطة للمشروع يتم تنفيذها بشكل اجتماعي وبيئي سليم فإن هناك حاجة إلى عمل تقييم أثر بيئي وإجتماعي وكذا خطة إدارة بيئية وإجتماعية لكل نشاط. إن ميناء األدبية هو موقع تخزين تم بناؤه في مصر عام 1975 وخصص لتخزين البضائع الجافة ويقع على بعد 125 كم شرق القاهرة ويتم الوصول إليه عن طريق سلوك الطريق السريع وأقرب مدينة كبيرة له هي مدينة السويس بمحافظة السويس )17 كم إلى الشمال( والمخزن في باحة مفتوحة مصممة للتخزين المؤقت للبضائع المشحونة. والباحة لها بوابتين، واحدة منهما )في الركن الشمالي الشرقي( هي بوابة الطوارئ.

233 Environmentaland Social Impact Assessment (ESIA) for the

EEAA Disposalof Obsolete Pesticide Stockpilein Al- Adabeya Port, Suez - Egypt EEAA

يقدر حجم المخزون بميناء األدبية من اللندين بحوالي 220 طن تم تخزينها منذ عام 1998 وهذه المخزونات المهملة معبأة في حقائب ورقية ثقيلة مدعمة بإطار بالستيكي سعة 25 كجم ومخزنة في عشرة حاويات إرتفاع 20 قدم تشغل مساحة 5850 م2 )225م × 26م(. إن التربة بتلك الباحة لم يتم جمع عينات منها لمعرفة األثر على جودة التربة وخصوصاً محتوى المبيدات المكلورة وكذلك فإن مستويات التعرض للمبيدات المخزنة غير معروفة. توجد سجالت عن مستويات اإلشعاع المباشر حيث يتم تخزين المبيدات ولكن حصر شامل ومفصل لم يتم عمله بعد وعليه فيجب التحقق من كل الحاويات وفي غضون ذلك فإن قطاع األسلحة الكيميائية، قد حلل محتوى الحاويات في معامله المعتمدة. إنه من المفهوم أن المبيدات المهملة والمواد العضوية المستديمة قد يتم تخزينها بطرق وحدود دون المستوى المطلوب ولذلك فإنه هناك احتمال حدوث انبعاثات كنتيجة لدرجات الحرارة العالية السائدة ولكن ال توجد سجالت بيئية لذلك. إن المشاريع المقترحة تشتمل على التعامل مع تعبئة ونقل والتخلص من هذه المبيدات الخطرة المخزنة وكذلك معالجة أي تلوث في موقع التخزين وعليه فإنه قد تم عمل تقييم بيئي واجتماعي لتطبيق الخطة المحلية بالدولة وهدف التقييم األكبر هو وضع آلية اتخاذ قرار إلدارة بيئية رشيدة لمخزون اللندين الخالص بميناء األدبية بالسويس.

2. التشريع البيئي والهيكل المؤسسي:

إن مصر لديها عدد من األجهزة لإلسترشاد البيئي المستدام من حيث السياسة والتشريع والتنظيم المؤسسي إن السياسات المحلية واإلستراتيجية واإلجراءات والهيكل المؤسسي وكذلك المعاهدات الدولية واإلتفاقيات التي تقوم عليها إدارة المبيدات المهملة قد تم أخذها في اإلعتبار عند تقديم التقييم، وفيما يلي هو بعض السياسات الرئيسية المتعلقة بالتقييم: قانون البيئة المصري )4/1994( والمعدل بقانون )9/2009( التشريعات التنفيذية لتقييم األثر البيئي، تنظيمات المخلفات الخطرة، تشريعات قانون )48/1982( والتشريعات المعدلة بقانون )1982/48( بالقرار )92/2013(. القوانين الزراعية والقرارات الوزارية المتعلقة بالمبيدات، وقانون العمالة )1981/137(.

234 Environmentaland Social Impact Assessment (ESIA) for the

EEAA Disposalof Obsolete Pesticide Stockpilein Al- Adabeya Port, Suez - Egypt EEAA

وباإلضافة إلى األجهزة السياسية والقانونية، فإن هناك بعض اإلتفاقيات المحلية تم وضعها في اإلعتبار اتفاقية باماكو لمنع استيراد المخلفات الخطرة إلى أفريقيا والتحكم في حركتها عبر الحدود وإدارة المخلفات الخطرة إلى أفريقيا والتحكم في حركتها عبر الحدود وإدارة المخلفات الخطرة داخل أفريقيا والتي وقعت بمصر في 30/1/1991 ودخلت حيز التنفيذ في 12 /5/1994 و ُصدق عليها في 15/5/2004. إن المعاهدات الدولية التي وضعت باإلعتبار هي تشمل معاهدة بازل للتحكم في نقل المخلفات الخطرة عبر الحدود والتخلص منها )1989( ومعاهدة روتردام للحصول على الموافقة المسبقة عن علم لبعض المواد الكيميائية والخطرة والمبيدات في التجارة الدولية )لم تصدق مصر على تلك المعاهدة حتى اآلن(،

ومعاهدة استكهولم 2001 على الملوثات العضوية المستديمة )PoPs(.

3. فحص حاويات اللندين : لتجنب أي ضرر أثناء نقل حاويات اللندين المهمل يجب فحص الحاويات بدقة، وعليه فقد تم تكليف كوميبصل الدولية بعمل فحص دقيق للحاويات لضمان أنها مناسبة لنقل الشحنة وتم التحقق من حالة الحاويات بواسطة معاينتين من كوميبصل ووجد أنها سليمة هيكلياً ومناسبة لحمل الشحنة.

4. وصف الموقع المقترح للمشروع: إن الموقع المقترح للمشروع هو عبارة عن منطقة مسطحة مرصوفة وتشغل مساحة 5850 م2 )225×26م( وتتبع تلك األرض الشركة العامة للصوامع والتخزين والموقع المقترح لتخزين اللندين المهمل تمت زيارته ووجد أنه في حالة جيدة جداً من حيث بعده عن األرض وموقعه بالنسبة إلى األنشطة األخرى بالميناء، ومن حيث األمان في الموقع حيث توجد المخزونات محاطة بسور من جميع الجهات والحاويات العشرة الخاصة باللندين مرصوصة بأمان على األرض المعدة. وداخل كل حاوية توجد حقائب )أكياس( اللندين المهمل مرصوصة بحيث يكون ثلث الحاوية األعلى خالياً ومعظم الحاويات مغلقة جيداً بإحكام وكل حاوية من الحاويات العشرة يحتوي على واحد أو اثنين من الحقائب المعطوبة التي لم تغلق بإحكام أو

235 Environmentaland Social Impact Assessment (ESIA) for the

EEAA Disposalof Obsolete Pesticide Stockpilein Al- Adabeya Port, Suez - Egypt EEAA

تمت إعادة تعبئتها وتركت عشوائياً أثناء أنشطة جمع عينات قطاع األسلحة الكيمائية، وهيئة الطاقة الذرية المصرية ولذلك تعطي رائحة سيئة بالمكان.

5. وصف البيئة الحالية – البيانات األساسية: - تم جمع المعلومات عن البيئة الغير حية الموجودة وخصوصاً المتعلقة بالمناخ والجيولوجي والجيومورفولوجي والتربة والهيدرولوجي والصرف. - التربة من باحة المبيدات الحشرية المهملة ومن المواقع القريبة منها تم جمع عينات منها لتحليل حجم الحبيبات المكونة لها لتعيين نسيج التربة وتقدير معدالت التصفية خاللها... أيضاً تم تحليل عينات التربة لمعرفة تركيزات وجود اللندين بها على وجه الخصوص لمعرفة إن كانت قد تلوثت بالمبيدات الحشرية المهملة أم ال ولمعرفة أي نوع من اللندين قد لوثت التربة.

6. سطح األرض والمياه الجوفية: تم تقدير خواص سطح األرض والمياه الجوفية بإستخدام طرق فحص حقلية وأيضاً الخرائط والصور الجوية والبيانات من التقارير األخرى وقد اعتبرت البيانات األساسية وسيلة كمية لمعرفة حالة المياه الجوفية ولمعرفة إن كانت المياه الجوفية قد تلوثت باللندين )كنتيجة 16 سنة من التخزين للمبيدات الحشرية المهملة ( أم ال. يقع ميناء األدبية عند الطرف األقصى للجزء الشمالي الشرقي من الصحراء الشرقية لمصر. ان الجزء الشمالي من مصر بما يشمله من الصحراء الشمالية الشرقية و الصحراء الشمالية الغربية وكذا النيل وشمال سيناء يقع في منطقة قارية غير مستقرة )سعيد 1962(، إن المبيدات الحشرية المهملة تقع في الشرق من جبل عتاقة و شمال جاللة ويقع إلى الشمال من مصبات وادي مجول ووادي بركة ووادي غوينة. 7. الجيولوجي والتركيب والتربة: لقد كان خليج السويس مشكالً لوحدة تركيبية مميزة تطورت في حركات أرضية على مدار الزمان جعلتها تحت سطح البحر لمعظم تاريخ حياتها الجيولوجي.

236 Environmentaland Social Impact Assessment (ESIA) for the

EEAA Disposalof Obsolete Pesticide Stockpilein Al- Adabeya Port, Suez - Egypt EEAA

إن معظم أنواع التربة السطحية التي تعاملنا معها أثناء فحص الموقع الخاص بمحطة معالجة مياه الصرف الصحي )9كم( إلى الشمال من موقع المبيدات المهملة قد كانت عبارة عن رواسب طميية وتشكل من رمال وحصى وبعض الجمرات والطمي. إن توزيع النشاط السيزمي لمصر قد يتأثر بشكل أكبر بتوزيع المحطات السيزمية ، وحديثاً تم إنشاء محطات سيزمية في أسوان و الميناء والقطامية ودهشور والغردقة ولذلك تم رصد العديد من األنشطة الزلزالية الصغيرة والمتوسطة.

8. األمطار والمياه الجوفية: يمثل سقوط األمطار هو المصدر الرئيسي لتغذية المياه الجوفية في المنطقة حيث تصل كثافة سقوط األمطار إلى حوالي 20مم /سنة وتتسرب إلى أسفل سريعاً عبر الشقوق في طبقة الحجر الجيري. إن خزانات المنياه الجوفية الهامة هي خزانات منطقة العين السخنة: إن الخزان الرباعي يمثل أهم الطبقات الحاملة للمياه في منطقة العين السخنة. ويتم ضخ المياه الجوفية بواسطة الشركات والمصانع والقرى السياحية الموزعة في المنطقة، وهي تتركب من الحصى والرمال والطين متعاقبة مع الحجر الجيري، إن السمك المخترق من الخزان الرباعي في فم وادي غويبة يبصل إلى 400 م ويقل نحو الشمال والشمال الشرقي وتتواجد المياه الجوفية في الخزان الرباعي تحت ظروف حرة من ظروف مستوى سطح الماء الجوفى. إن تحليل النظائر قد أوضح أن تغذية هذا الخزان يعتمد أساساً على تصفية السريان السطحي والتسريبات الرأسية من الخزانات األعمق، وإن سحب المياه الجوفية يكون أساساً عبر الضخ لإلستخدامات المختلفة، إن عمق المياه يتراوح مابين 6.2 م إلى 60.2 م ويكون إتجاه ميل وتدفق المياه إلى خليج السويس.

9. الحياة النباتية: قد شمل مسح الحياة النباتية الجزء الشمالي من جبل الجاللة البحرية والذي وجد خالياً من الحياة النباتية ويقتصر نمو النبات على أنظمة الصرف )الجريان السطحي للصحراء( والجزء المركزي لبطن الوادي غالباً مايكون خالياً من الغطاء النباتي الحولي ليكون النبات مقتصراً على جانب الوادي ألنها تدعم عشيرة نباتية أغني من باقي السهل ألن الوصول لها

237 Environmentaland Social Impact Assessment (ESIA) for the

EEAA Disposalof Obsolete Pesticide Stockpilein Al- Adabeya Port, Suez - Egypt EEAA

سهالً فإن الوديان قد كانت وال تزال عرضه للرعي وقطع األخشاب، ويرتبط الرباط النباتي ارتباطاً واضحاً بمساحة منطقة تجمع المياه والنسيج وعمق غطاء بطن الوادي، وقد تم التعرف على عده مجتمعات نباتية وكانت األنواع السائدة هي األكاشيا الشعاعية واألثل عديم األوراق والشائكة والحماية واألنابيس المفصلي وإلتمام المنتفخ والزال الشائكة والزيجو فيلم القرمزي. والنباتات التي تميز المرتفعات ومساقط المياه الجوفية التي تقطع مسارات الوادي عبر التالل تشمل: نبات الكبر الشائكة والكبر السيناوية ونبات التين اللنجي.

10. الحياة الحيوانية: إن الزواحف المميزة لهذا النوع من الموائل في منطقة خليج السويس تشتمل على أنواع ساكنة للصخور مثل البرص المصري والعجمة الشاحبة وعجمة سيناء. وفي بطون األودية توجد سحلية دهب المصرية والحية المقرنة وتتميز األودية التي لها طبقات من الرمال الدقيقة بوجود سحلية النوة أما األودية ذات الطبقات الرملية الخشنة فيتواجد بها سحلية بوسك .)EEAA,UNEP 93( إن األنواع الحيوانية من الطيور المتزاوجة تشتمل على النيوفرن وحجلة الرمال واألبلق الحزين واألبلق الراهب والعزل المفرد وبومة صقر الفرعون وعازف البوق الصغير والحنجرة الشاحبة. ويوجد وفرة غير عادية من الطيور المهاجرة التي تعبر خالل األودية والجبال خصوصاً أثناء هجرة الخريف.

11. الظروف السكانية اإلقتصادية: إن إستجابة المجتمع اإلقتصادية للمشروع وتقييم األثر البيئي واإلجتماعي تتأثر بمزيج معقد من الوضع اإلجتماعي - اإلقتصادي حيث سيتم إنشاء المشروع ولذلك قبل تقديم موجدات تقييم األثر البيئي واإلقتصادي واإلجتماعي يجب عمل البيانات الثانوية مختصرة للمحتوى اإلجتماعي واإلقتصادي لمنطقة المشروع مثل الظواهر الجيوجغرافية والظواهر السكانية وقوة العمالة ومظاهر التعليم واألمية والظواهر الصحية والمؤشرات العامة وصحة المرأة والطفل والخدمات والصرف الصحي وإمدادات الطاقة وموارد مياه الشرب واإلتصاالت.

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12. المسح اإلشعاعي لحاويات اللندين المهمل: قد وجد أن معدل جرعات اإلشعاع تترواح مابين 0.08 إلى 0.029 ميكروسيمنز فولت / ساعة وال تزال في نطاق المعدالت المسموحة لجرعات اإلشعاع بناءاً على عده مؤسسات مثل الهيئة الدولية للحماية من اإلشعاع )KRP( والمجلس الوطني األمريكي للحماية من اإلشعاع )NCRP( ولجنة األثار البيولوجية لإلشعاعات المؤينة للمجلس الوطني البحثي )BEIR( ولجنة األمم المتحدة ألثار اإلشعاع الذري ) VNSCEAR( ومؤسسة أثار اإلشعاع البحثية )RERF( ولم توجد أي أثار ضارة إشعاعياً للحاويات بنا ًء على المسح اإلشعاعي القياسي.

13. فحص حالة الحاويات بواسطة كوميبصل: وحتى يتم تجنب أي أخطار أثناء نقل حاويات اللندين المهملة فإن الحاوية يجب فحصها جيداً. تم استخدام كوميبصل الدولية لعمل فحص شامل لضمان أن الحاويات مستقرة وصالحة لحمل تلك الشحنات. تم فحص حالة الحاويات بواسطة مساحين من كوميبصل ووجد انها صالحة هيكلياً وصالحة لحمل الشحنات المذكورة سلفاً. مرفق تقرير كوميبصل الدولية مع هذا التقرير )مرفق 3 ، 5(.

14. التأثيرات البيئية واالجتماعية: من الممكن أن تحدث العديد من التاثيرات البيئية واالجتماعية خالل عملية النقل والتخلص النهائي من مخزون الليندين في منطقة ميناء األدبية.

يقوم امين المخزن المكلف من قبل هيئة ميناء األدبية بفحص حاويات الليندين مرة واحدة على األقل في األسبوع كما يتم توفير حارس أمن لمدة طويله تصل لحوالى 24 ساعة يوميا. اما عن دواعى السالمة، فلم توجد أي معدات واضحه خاصة بالحرائق وال لإلسعافات األولية أو حتى معدات الحماية الشخصية التى يستطيع امين المخزن استخدامه اال على بعد )230 متر( من المخزن االخاص بالشركة العامة للصوامع والتخزين.

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من اهم التاثيرات تكون واقعة على العمال وهى نتيجة استنشاق الغازات الصادرة من حاويات الليندين ويرجع ذلك الى وجود بعض الحاويات مسبقة الفتح واخرى غير محكمه الغلق تقوم بنشر تلك الروائح فى المنطقة المجاورة للحاويات كما قد يتسبب فى زياده انتشارها فتح االبواب بمنطقة التخزين . فلقد اجمع جميع أصحاب المصلحة والمستفيدين اثناء المسح االجتماعي واالقتصادي على التخلص من تلك الحاويات في أقرب وقت ممكن لتجنب آثارها السلبية على صحة اإلنسان والبيئة. جميع اصحاب المصلحه فى العينة التى تم اخدها حاصلين على شهادات جامعية باستثناء عمال الموقع مما يعكس مستوى التعليم العالي ,وبالتالي الوعي. كما ان معظمهم لديهم سنوات من الخبرة في العمل تصل الى خمس سنوات على األقل وبذلك يكون لديهم الخبرة الكافية التى تسمح لهم بمعرفة وإدراك تأثيرات المشروع. وبهذا فقد أشارت النتائج إلى أن عمال الموقع هم أصحاب المصلحة الوحيدين لتعرضهم المنتظم لكافة المخاطر المرتبطة بالليندين. اذن فإن نتائج المسح االجتماعي تشير الى ان عمال الموقع والمشرفين هم أصحاب المصلحة الوحيدة لتعرضهم المنتظم للمخاطر المرتبطة بحاويات الليندان.

ان معدل ظهور أالعراض المرضية منخفض جدا لجميع األعراض المعروفة ماعدا حكة العين والتي كانت أكثر شيوعا. كما ذكر جميع العاملين والمشرفين وممثلي اإلدارة بالموقع بتعرضهم الدائم لرائحة المبيدات الالذعه عند اقترابهم من حاويات الليندين. وفقا لذلك نستنتج أنه على الرغم من تخزين الليندين في حاويات محكمة الغلق ال يزال هناك تعرض لبعض االبخرة الخاصة بها. كما يرى جميع االفراد )اصحاب المصلحة( من كافة التوجهات أن المشروع سيكون له تاثيرات إيجابية .هذه التاثيرات هى :  القضاء على مخاطر التلوث البيئي التي من شأنها أن تحدث بوجود حاويات المبيدات.  القضاء على اآلثار الصحية الناجمة عن التعرض لهذا المبيد خصوصا عمال الموقع وهذا يعطى العاملين المزيد من الشعور باألمن في بيئة عملهم.

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 تحسين ظروف العمل في الموقع والحد من المخاطر الصحية المهنية على العمال في الموقع.  القضاء على الخسائر المالية الناتجة عن ايجارات المخازن الذي تشغلها الحاويات.  اقترح أصحاب المصلحة على ضرورة وجود خطة محكمة وخاصة اثناء التخلص من الحاويات وخاصة اثناء عملية النقل لتجنب أي مخاطر اثناء المشروع.

15. خطة اإلدارة البيئية واالجتماعية: الهدف من خطة اإلدارة البيئية هو توفير استراتيجية إلدارة حاويات الليندين المهملة ، مع التركيز بشكل خاص على طرق التخلص النهائي من الليندان المهمل وكذلك االكياس الفارغة له للحد من التاثيرات والمخاطر الذي يشكلها مخزون الليندين المهمل.

غطت هذه الدراسة جميع الجوانب المتعلقة بعملية التخلص من الحاويات مثل التحقق من بعض العمليات كالتسجيل؛ النقل؛ التخزين وكذلك خيارات التخلص النهائية من الليندين المهمل )محلية /دولية( مع االمتثال لالتفاقيات الكيميائية الدولية ذات الصلة .كما تم أدراج مصفوفة خاصة بالدراسة في الفصل السابع من هذا التقرير.

16. أنشطة الحماية : للتأكد من تغطية جميع التاثيرات الحالية والمحتملة لمخزون الليندين المهمل والمواقع الملوثة فسيتم تنفيذ الخطه على خطوتين. الخطوة االولى سوف تركز على التخفيف من التاثيرات الحالية بينما الخطوة الثانية فسوف تركز على التخفيف من تاثيرات عمليات الحماية والتخلص منها. اما فى حالة التعرض لظروف حرجة اثناء التخلص من مخزون الليندين المهمل وكذلك المواقع الملوثة به يجب تنفيذ خطة للحماية فى حالة الطوارئ لمنع الصحة العامة والمخاطر البيئية من الخروج عن نطاق السيطرة. قبل البدء فى خطة الحماية الرئيسية يجب اتخاذ تدابير للحد من االخطار الصحية والبيئية لمخزونات الليندين المهمل. كذلك بعد عملية الحماية وإزالة

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الليندين المهمل يجب تطهير الموقع نهائيا في أقرب وقت ممكن. كذلك يجب تطهير المركبات والمعدات المستخدمة في أنشطة الحماية والنقل. كما يعتبر هيبوكلوريت الصوديوم )NaOCl) عامل مؤكسد يمكن استخدامة اثناء عملية التطهير.

17. خطة الرصد البيئية واالجتماعية: هناك حاجة ماسة إلى عملية الرصد البيئى لمعرفة إلى أي مدى قد تم التخفيف من التاثيرات ومواجهة اى مشاكل جديدة قد تظهر. هذا وقد شملت خطة الرصد البيئية واالجتماعية على خطط للرصد كما انهاخصصت مسؤوليات ألنشطة الرصد. تجرى عملية الرصد ألنشطة الحماية على أيدي أفراد من وحدة إدارة المشروع و سوف تتشارك مع المسؤولين الحكوميين المحليين في عملية الرصد. وسوف تشكل المنظمات غير الحكومية و منظمات خدمة المجتمع المنظمات فريق لمراقبة أنشطة الحماية. وبذلك يكون مراقبي المنظمات غير الحكومية طرف محايد فى تقييم التدابير الفعالية المقترحة. وستقوم وحدة إدارة المشروع باختيار المنظمات غير الحكومية الوطنية األنسب لشغل هذا الدور. أحد األهداف الرئيسية للمشروع هى استخدام الطاقات الحالية وتاسيس طاقات جديدة لكل عنصر من العناصر الرئيسية للمشروع. كما يجب تقديم التدريب المناسب للذين سيشاركون في نشاطات الحماية والتخلص من التاثيرات لتمكينها من أداء واجباتهم على نحو فعال آمن وبطريقة صديقة للبيئة. في ضوء ذلك تحتاج تلك الطاقات الى تطويرها في المجاالت التالية :الصحة والسالمة وحماية البيئة، وتوريد المعدات و استشارات الجمهور، واإلدارة، والسياسات البيئية وبرامج واإلدارة والتخطيط ووضع الميزانية .كما تم أدراج مصفوفة خطة المراقبة البيئية واالجتماعية في الفصل السابع من هذا التقرير.

18. تحليل البدائل: تم اقتراح بديلين رئيسيين خالل هذه الدراسة وقد نوقشت هذه البدائل مع أصحاب المصلحة فى جلسة استماع تمت فى مايو ويونيو 2014، وتلك البدائل هي: فى حالة وجود المشروع وفى حالة عدم وجود المشروع. كما يجب اإلشارة إلى أن بدائل خيارات التخلص من الملوثات العضوية الثابتة )POPs( هي إلى حد كبير متشابهة على اى حال فسوف نسلط الضوء على االختالفات الملحوظه ادناه

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. فعملية الحماية مطلوبة لمخزون الليندين ، االكياس الفارغة الملوثة بالمبيدات ، المعدات الملوثة، ونفايات المبيدات الملوثة، والتربة الملوثة. مع وجود الحاجه للحماية من المبيدات المهملة فقد تم اخذ وتحليل ثالثة بدائل في االعتبار. هذه البدائل هى:  عدم وجود اجراءات حماية.  حماية على الموقع الحالي.  حماية لمخزون المبيدات الرئيسي لوزارة الزراعة )يجب نقل مخزون الليندين من ميناء األدبية (. الجدير بالذكر ان خيار العمل على حماية الوضع الراهن لمواقع تخزين الليندين الملوثة هو السبب الرئيسى في تنفيذ هذا المشروع. كما يجب االخد فى االعتبار مناقشة الحماية عند منشأة تخزين المبيدات الرئيسية لوزارة الزراعة واستصالح األراضى )يجب نقل مخزون الليندين المهمل من ميناء األدبية (. استنادا إلى تحليل البيئي SWOT، فمن الواضح أن الحماية على الموقع الحالي هو األكثر مالءمة وهذا موصى باعتماده في قرارات الحقة في هذا المشروع. كما يتضح من تحليل SWOT ايضا ان نقل الليندين من الميناء إلى موضع التخلص النهائي له سيكون عن طريق الشحن البحري فمزايا الشحن البحري عن الشحن الجوي واضحة بال شك . باإلضافة إلى ما سبق، يجب االخذ فى االعتبار عدم توافر كل من المحارق الكبيرة المتوافقة مع المعايير المعترف بها لتدمير االكياس الفارغة لليندين وأنواع أخرى من النفايات عن طريق الحرق في مصر.

19. تقييم المخاطر البيئية: استنادا إلى المشاهدات والفحص والمسوحات الخاصة بالموقع فان نتائج التحليل الخاصة بعينات الهواء والتربة وحساب معامل الخطر (FP وFE( مع محاكاة اسوأ سيناريو متوقع فقد تم استنتاج وجود رائحة لليندين في محيط منطقة التخزين والحاويات مما يؤدى إلى تعريض صحة كل من اإلنسان و البيئية الى مخاطر طفيفة. فقد يشكل الليندان خطرا يهدد العاملين في الموقع واالفراد في المبانى القريبة . و باالشارة الى (FP (2,860,000 و *FP

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100 = و ,(FE (18 فقد يتسبب موقع التخزين لشركة ميناء األدبية للمبيدات المهملة فى اشكالية كبيرة . بعد تطبيق دراسة تقييم المخاطر إلدارة مساحة التخزين )الموقع الملوث( في منطقة ميناء األدبية قررت اللجنة الفنية أن أفضل التقنيات المتاحة (BAT) وأفضل الممارسات البيئية (BEP) إلدارة المشكلة هو القضاء على )المصدر / الملوث( نفسه (مبيد الليندين(من االتصال مع المستقبالت. ينبغي اتخاذ إجراءات فورية للمضي قدما نحو تنفيذ أنشطة الحماية المقترحة والتخلص النهائي من الليندين من خالل التصدير والتخلص منها في المنشأة المرخص لها في الخارج وفقا التفاقيتي بازل واستكهولم.

20. المشاورة المجتمعية: أجريت لقاءات فردية واجتماعات لمجموعات صغيرة وكبيرة عدة مرات مع توفير اربع استبيانات تم تحليلها. وقد اشتملت المشاركة العامة واالستشارات على اناس ذات مستويات مختلفة من التعليم وفئات عمرية مختلفة. فقد اجري يوم الثالثاء 22 يوليو 2014 اجتماع تشاوري شعبي كبير فى سلطات موانئ البحر األحمر وحضر االجتماع كل من محافظ محافظة السويس، مدير هيئة موانئ البحر األحمر مع حضور حوالى 70 فرد يمثلون أعضاء هيئة التدريس, ممثلي جهاز شئون البيئة، وأصحاب المصلحة للعديد من شركات النقل البحري و عمال شركة ميناء األدبية، ممثل قطاع السالح الكيميائي )الجيش المصري( وأخيرا المحليات وممثلي وسائل اإلعالم. أشار محافظ السويس على أهمية الدراسة كما وضع حدا لجميع االقاويل التى تتحدث عن وجود مواد مشعة داخل هذه الحاويات و قد حث الناس عن طريق وسائل اإلعالم على توضيح هذه النقطة في تقاريرها.

ومن ابرز القضايا والتعليقات الرئيسية التي أثيرت من قبل الحضور هي  ينبغي تجنب تأخير التعامل مع مشكلة التخلص اآلمن والمشاكل المشابهة لها في جميع أنحاء مصر.  معالجة هذه الحاويات يجب أن يتم وفقا ألعلى احتياطات و تدابير السالمة الممكنة.

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EEAA Disposalof Obsolete Pesticide Stockpilein Al- Adabeya Port, Suez - Egypt EEAA

 عملية إعادة تعبئة حاويات الليندان يجب ان تخضع الى التدابير المناسبة التي اقترحتها دراسة المراقبة والرصد  حالة الطوارئ و خطط الطوارئ للتعامل مع أي انسكابات قد تحدث خالل الخطوات المختلفة للتخلص من المخلفات خصوصا عند إعادة التعبئة والنقل.  وجود أي مخاطر صحية للعاملين في المواقع التي تجري فيها أنشطة التخلص من المخلفات  تاثيرات تخزين الليندان على المناطق المحيطة وذلك بالنظر إلى فترة التخزين الطويلة له في الميناء.  مساهمة المنظمات غير الحكومية ولو باستشارة في الدراسة  والتدابير التي ينبغي القيام به إذا حدث أي سكب في مياه الخليج.

لقد تم الرد على جميع هذه التعليقات واألسئلة من قبل فريق االستشارات. وفي الختام، اتفق جميع الحضور من الجمهور وأصحاب المصلحة حول هذا المشروع، وأكدوا أن التخلص من المبيدات المخزونة في ميناء االدبية يجب أن يتم بطريقة سريعة وآمنة من أجل صحة وسالمة العامة.

21. التكاليف التقديرية للتنفيذ :

تبلغ التكاليف التقديرية لتنفيذ )الحماية والتخلص من الليندين ، والتربة الملوثة والمواد الملوثة األخرى( جنبا إلى جنب مع تكلفة الرصد البيئي ومتطلبات التدريب حوالي 1824000 دوالر امريكى. وتقوم هذه التكاليف على متوسط أسعار الوحدات وتشمل جميع التكاليف المترتبة على ذلك حتى التخلص النهائي لها خارج مصر. متوسط سعر الوحدة ماخوذ

من حاالت مماثلة مع اخذ فى االعتبارتعديالت الظروف السائدة.

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