National Implementation plans for the Management of Persistent Organic Pollutants

Republic of Lebanon Ministry of Environment National Implementation plans for the Management of Persistent Organic Pollutants Final Report 2006 ® POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Execut ive Summary A. Introduction The Government of Lebanon (GoL) signed the Stockholm Convention (SC) on May 22, 2001; it came into force on May 17, 2004. With grant funding from the Global Environment Facility (GEF)/UNEP, Lebanon is one of 12 countries participating in a pilot project for the “Development of National Implementation Plans for the Management of POPs.” Major milestones during the implementation of this NIP include: 1. Preliminary POPs inventories a. Dioxins and Furans b.Pesticides c. Polychlorinated Biphenyls (PCBs) 2. National Profile (NP) of Chemicals Management in Lebanon 3. Health and Environment Profile of Lebanon 4. National Implementation Plan: a. Priority setting: Recommendations from the preliminary inventories were aggregated into nine priority areas and scored using five evaluation criteria. b. Validation of tentative priority issues: MoE organized a full day priority-setting workshop in August 2005 with relevant stakeholders to validate the nine priority areas across all three groups of chemicals (pesticides, dioxins and furans, and PCBs). c. Draft NIP document review: MoE organized a second workshop in November 2005 to review the draft NIP document with emphasis on the proposed action plan. Participants discussed the actions and tasks specific to each chemical group and those common to all three. To the extent possible, this Final NIP document has incorporated the comments and suggestions of the participants. B. Country Profile Lebanon lies between latitudes 33°03'-34°45' and longitudes 35°05'-36°30'. The dominating topographic features of Lebanon are two parallel mountainous ranges with a NNE-SSW direction, Mount Lebanon and Anti Lebanon, separated by the Bekaa plain. Lebanon's total population was estimated at 3,753,785 persons in 2004 with a total area of 10,452 km2 of which 222 km2 are water and 10,230 km2 are land. The country is bound from the North and East by Syria, from the South by the Palestinian Authority, and from the West by the Mediterranean Sea with a coastal strip of 225 km. Local economy in Lebanon mainly depends on the trade and services sector. The Lebanese industry and agriculture are of micro and small size. Lebanese legislation sporadically addresses hazardous chemicals in different laws, decrees and ministerial decisions especially the law 64/1988 on hazardous waste, and the decree 8006/2002 and its amendments on the management of health care waste (which includes hazardous and persistent chemicals, Decree 13389/2004). National environmental standards were issued by the Minister of Environment (decision 52/1 1996 and decision 8/1 2001), however POPs were not covered. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 02-03 A number of ministries play a role in chemical management. The Ministry of Agriculture is practically handling activities concerned with agricultural pesticides, the Ministry of Environment deals with hazardous and industrial chemicals, the Ministry of Public Health is responsible of pesticides destined for domestic use and the Ministry of Energy and Water is responsible for the import of petroleum derivatives. Responsibilities for POPs management in Lebanon are not well delineated. Legal procedures are existent for the control of agricultural pesticides, industrial chemicals, domestic pesticides, and PCBs. These are regulated under MOE Decision 71/1 (PCBs) and Decree 5039 (Pesticides). While there are several legal texts that cover the management of POPs chemicals in Lebanon, enforcement of available legal instruments remains very weak due to the lack of human, technical and financial resources. Many laboratories, belonging to ministries, research institutes, universities or the private sector, can be considered for management of chemicals in Lebanon. IRI is the only institute holding an international certification (ISO 17025; General Requirements for the Competence of Testing and Calibration Laboratories) where a few laboratories are working on getting international certifications in order to improve their working practices. C. Assessment of the POPs Issue in Lebanon 1) Assessment with respect to Annex A, Part I Chemicals (POPs Pesticides) A survey on agrochemical distributing companies with a complete list of their products revealed that none of the distributed pesticides belonged to the nine POPs compounds, further confirming their probable absence in the Lebanese market. A survey conducted in a recent study at the MoE whereby the amounts of pesticides imported to Lebanon from 1996 to 2000 were recorded, none of the 9 POPs pesticides were identified. A study has reported sediment samples results within the El Kabir Watershed in North Lebanon as part of the Syria Lebanon Akkar Watershed Project. Sediment samples were analyzed for the presence of two of the POPs pesticides, namely HCB and Mirex. HCB was detected at low levels, while Mirex was not detected in any of the samples. Prior to 1999, the Lebanese customs database system was under the responsibility of the Central Administration of Statistics (CAS). Since then, the database import/export materials grouping system had changed thrice, where upon the first and second modification to the system, the amounts of POPs pesticides could not be differentiated from the overall amount of imported pesticides. As such, the amount of imported material per each pesticide was not recorded. Import/export data of 2000 through 2004, shows that 1 kg of DDT (and possibly 2 other organochlorine compounds) was imported in 2002 by order of the Ministry of Public Health for research purposes. The MoPH is the only institution that is allowed to request such import by a special order, whereby DDT was used for testing and analyses. Farmers in Lebanon are often poorly aware of the nature of the chemicals they use for their crops, and are particularly ignorant of POPs pesticides. It is highly improbable that stocks exist due to the fact that any present chemicals would have been either sold within due expiry date, or repackaged and sold after expiry in another brand name. The demand for agrochemicals on the Lebanese market is high and selling products is a very easy task considering the illiteracy of the majority of farmers. No smuggled POPs pesticides were officially detected or declared until the present day. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Land contamination from extensive usage is highly probable especially in frequently planted agricultural areas. The vastness of agricultural activities and diversity of planted crops render it difficult to pinpoint exact locations of possible POPs pesticides usage. Therefore, large areas with historically intensive agricultural practices can be identified and will be the target of the action plan for initial sampling. Any possibly contaminated agricultural soils used at construction sites for planting purposes could be considered as a potential source of these chemicals. Such non point sources could be numerous due to the construction boom after the Lebanese civil war in the past two decades. Detected levels of organochlorine pesticides heptachlor and epoxide, tested in fish species found off the coast of Lebanon did not constitute a hazard to human health. The limited evidence found could mean that the pesticides have not been in the Mediterranean for a very long time, thus the concentrations in fish are due to direct absorption into the fish body from water rather than from the consumption of other pesticide containing fish. Another likely explanation reported by the researchers is that the experiment had been too small to give accurate concentrations in the species sampled. An analysis for organochlorinated pesticides in the Kuwaiti diet including food products imported from Lebanon, concluded that the residue levels encountered were relatively low and none of these residues exceeded the FAO/WHO (1993) maximum residue limit (MRL). 2) Assessment with respect to Annex A, Part II Chemicals (PCBs) Lebanon has no PCB production facility. The country hosts two companies that manufacture and/or supply distribution transformers: Matelec (Lebanese company) and Elprom (Bulgarian company). Both companies have been using PCB free oil for many years. Two PCB assessments were conducted in 1995 and 2000, respectively. Key findings are summarized below: >> Out of 34 samples of dielectric oil collected from distribution transformers in 1995, eight contained PCB concentrations greater than 50 ppm. >> Out of 38 samples collected in 2000, also from distribution transformers, six contained PCB concentrations greater than 50 ppm and two contained concentrations between 40 and 50 ppm. >> All nine samples collected from oil barrels contained PCB concentrations less than 50 ppm (values ranged from <1 to 21 ppm); the two well samples contained 222 and 229 ppm of PCB, respectively; and the soil sample contained 8 ppm PCB. Key findings from the inventory conducted in 2004 are summarized below: • Power Plants: Lebanon's power plants are relatively new (post 1995). Samples from Lebanon's two oldest plants (Zouk and Jieh) revealed significant quantities of PCB oil in both in-use and out-of-service transformers. Total quantities of PCB oil were estimated at 42 tonnes (5 tonnes in Zouk and 37 tonnes in Jieh); commercial oil names include Askarel, Sibanol and Pyralene. PCB oil or PCB contaminated oil may be present in other power plants and would require more extensive testing. • Substations: Lebanon's substations appear to be using and to have been using PCB-free oil. The corresponding test results corroborate this finding (27 samples), where the concentration of PCB oil in new as well as old transmission transformers was not detectable. It is however difficult to categorically exclude the presence of PCB in transmission transformers due to the multitude of associated variables. • Distribution: Lebanon's power authority, Electricité de Liban (EDL), owns and operates more than 16,000 distribution transformers across the country, many of which may contain PCB oil. Old and/or damaged transformers are gradually being phased-out and replaced with new ones that contain PCB free oil. The EDL repair shop in Bauchrieh is considered the most severe hotspot in Lebanon, where an estimated 1,600 transformers are present. Previously MoE and EDL commissioned an investigation collecting a total of 84 samples between 1995 and 2000 from the site. A total of 14 samples contained high concentrations of PCB and the samples collected from a well contained PCB. • Capacitors: EDL uses only dry-type capacitors. Dry-type capacitors do not contain oil and therefore do not represent a potential repository of PCB material. 3) Assessment with Respect to Annex B Chemicals (DDT) Municipalities in Lebanon do not use DDT for mosquito abatement or insect spraying. The Ministry of Public Health (MoPH) used to distribute DDT to municipalities in the 1970s and 1980s for malaria prevention. However, no records are available detailing for distributed quantities. The most recent logbook records that are kept indicate the usage of alternative pesticides to DDT, which are often synthetic pyrethroids for spray and ambient fogging. In a recent publication by the American University of Beirut (AUB), on DDT sampling and analysis results in Lebanon, a total of 113 soil samples were collected for analysis from 3 major agricultural regions in the country: Mount Lebanon, the Bekaa Valley, and the Coastal Plain. The majorities of the analyzed samples were free of DDE (a DDT metabolite) or contained negligible amounts of it. Two urban samples with high human activity in the area revealed higher DDT amounts as compared to other POPs pesticides. These two urban sampling locations were situated in the South Caza, particularly in Saida, such that the first was near a gas station, while the second was in a dense residential zone. These relatively higher levels of DDT found in the two locations were explained by: (1) an old storage site of DDT in the vicinity, (2) small-scale haphazard dumping of DDT material in the vicinity, or (3) an accidentally discarded DDT product. There are no suggested ramifications as to these two locations, since the levels of DDT in all samples were within permissible standards for agricultural use. Sediment samples results within the El Kabir Watershed in North Lebanon were also analyzed for the presence of DDT. DDT and DDE were found in small amounts in all samples, indicating possible current usage. A research conducted at the National Council for Marine Sciences (NCMS) showed that levels of DDT, DDD, and DDE in fish were not negligible. The study also stated that the trend between 1984 and 1988 indicates that fish contamination is not likely to decrease. 4) Assessment of Releases from Unintentional Production of Annex C Chemicals (PCDD/PCDF) The preliminary inventory for Dioxins and Furans, conducted in 2005, indicated that Lebanon releases an estimated 165.8 g TEQ per year of PCDD/PCDF. Uncontrolled combustion was found to be the major contributor to such emissions with a 124.74 g TEQ/a (this is equivalent to 75.24% of total emissions). In the context of a study on dioxin assessment in soils, sampling and analysis of 6 potential sites was done in Lebanon in 2001. Test results showed levels lower than the maximum value of toxic equivalent concentration. D. Action Plans, Activities and Strategies Consistent with UNEP guidelines, this NIP presents activities, strategies and action plans for POPs management in Lebanon. It describes each activity, strategy or action plan in relation to the provisions of the Stockholm Convention and by providing relevant background information and findings, including tentative cost figures and time frame. The proposed actions and tasks reflect national priorities as expressed and discussed at the priority setting workshop in August 2005. The total number of discrete tasks proposed in the NIP is 96. 1) Institutional and Regulatory Strengthening Measures Existing laws and policies were evaluated for efficacy of POPs management, and complementary measures were proposed accordingly. The most prominent tasks were related to updating existing legislation based on its gaps and weaknesses regarding POPs. 04-05 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon These included emission and disposal standards, environmental limit values for classified industrial establishments and wastewater treatment plants for POPs as well as banning open dumping and burning of solid waste. 2) Measures to Reduce or Eliminate Releases from Intentional Production and Use Measures to reduce or eliminate releases from intentional production and use, were proposed for both POPs pesticides and PCBs. They included ensuring zero PCB release from in-use transformers, strengthening measures to prohibit the use of POPs pesticides, sample and analyze dielectric oil in in-service transformers, and investigating the fate of 13 tonnes of PCB oil imported in 2002. 3) Production, Import and Export, Use, Stockpiles and Wastes of Annex A Part I POPs Pesticides Since the preliminary POPs Pesticides Inventory in Lebanon did not register production, use, import or export of these substances and has established the absence of their stockpiles and waste, no improvement of the current management and treatment practices of Annex A pesticides is deemed necessary. However, it is recommended that additional efforts be made for improvement including systematic monitoring of environmental POPs pesticides levels in order to confirm the findings of the inventory that these chemicals do not represent a true problem in Lebanon to the environment or human health. 4) Production, Import and Export, Use, Identification, Labeling, Removal Storage and Disposal of PCBs and Equipment Containing PCBs This activity identifies all sources of PCB release and use in the country by developing a comprehensive inventory of PCBs. Additionally, it addresses monitoring, phase-out and disposal of PCB containing products and equipment. 5) Production, Import and Export, Use, Stockpiles and Wastes of DDT if used in the Country An action plan for DDT has not been developed due to absence of production, use, import or export as well as stockpiles and wastes of DDT in the country, as recorded by the preliminary POPs Pesticides Inventory. 6) Register for Specific Exemptions and the Continuing Need for Exemptions Lebanon did not register any exemptions to Annex A and Annex B chemicals, and is not likely to do so in the future. 7) Measures to Reduce Releases from Unintentional Production The aim of this activity is to take action to identify, characterize and address unintentional releases of PCDD/PCDF, HCB and PCBs formed as a by product of certain industrial processes. One of the most significant actions proposed was the promotion of BAT/BEP techniques at known source II & III establishments, requirement of BAT/BEP at new source II establishments, which include hospitals, secondary copper, aluminum, and lead producers, as well as textile and leather industries. Others actions involved environmentally sound waste management technologies to stop the uncontrolled burning of municipal solid waste. 8) Measures to Reduce Releases from Stockpiles and Wastes Two major actions are proposed under this activity to identify and manage waste sites potentially contaminated with Annex C chemicals. These sites include seven large and hundreds of small uncontrolled dumpsites in the country. This activity also aims to reduce PCB releases from PCB-containing transformers in Zouk & Bauchrieh through labeling, storage, detection and containment. 9) Identification of Stockpiles, Articles in Use and Wastes This strategy lays out procedures to facilitate the identification of POPs present in unidentified stockpiles and equipment still in use, including PCB stockpiles and potential Dioxin/Furan contaminated sites. Its detailed actions include inspection surveys of pesticides retailers, investigations of substations at other power utilities such as the Litani River Authority (LRA) and the Qadisha plant, and exercising containment procedures at identified contaminated sites or stockpiles. 10) Manage Stockpiles and Appropriate Measures for Handling and Disposal of Articles in Use This activity focuses on identifying appropriate measures to manage, handle and destroy stocks and articles in use, remedy contaminated sites and other hot spots of concern to public health and the environment. Actions include treatment or disposal of PCB oil and irreparable PCB contaminated transformers in an environmentally sound manner, and improving procedures for handling transformers at the EDL warehouse in Bauchrieh. Additionally, the activity outline a procedure for implementing a national sampling and analysis program for identification of sites potentially contaminated with POPs pesticides, and develop a remediation plan that assesses remediation options fitting to Lebanese circumstances. 11) Identification of Contaminated Sites (Annex A, B and C Chemicals) and Remediation in an Environmentally Sound Manner The strategy identifies contaminated sites and proposes alternative treatment methods for reducing and eliminating the release of POPs. Actions include delineating Dioxins/Furans contaminated sites, identifying, assessing and remediation of POPs pesticides contaminated sites, decontaminating the well at the Bauchrieh repair shop, and exploring the feasibility of decommissioning the Bauchrieh repair shop. 12) Facilitating or Undertaking Information Exchange and Stakeholder Involvement Actions under this activity aim at strengthening links among relevant private and public stakeholders, organizing and disseminating information, and establishing a mechanism involving several stakeholders to gather data on all POPs chemicals. In particular, this activity proposes to setup a central POPs database and measures to facilitate the information exchange on POPs chemicals. 13) Public Awareness, Information and Education This activity promotes and facilitates POPs awareness in policy and decision-making, and provision of information to the public at the national, sub-regional, and regional levels, via data sheets and reports, mass media, and information centers. Major actions to be taken include national awareness campaigns targeting universities, farmers, municipalities, industries, and EDL, as well as designating the MoE as the central information source for data related to POPs chemicals. 14) Effectiveness Evaluation This activity requires further deliberations during later stages of NIP implementation. Tentative actions include measures for monitoring progress, consistent with COP guidelines for comparing monitoring data, frequent update of the preliminary inventories, and developing indicators for each proposed action. 15) Reporting The objectives of this activity are to report to the COP and Secretariat by preparing and submitting national reports to the COP, and developing a data collection system for POPs emissions from individual enterprises. 16) Research, Development and Monitoring This activity proposes actions focusing on undertaking research, development, monitoring and cooperation related to POPs. The NIP proposes four actions concerning health related research, establishing inspection units and monitoring programs for POPs emissions and self-monitoring. 17) Technical and Financial Assistance Lebanon, a developing country with a $38 billion national debt, will require technical and financial resources to execute the National Implementation Plan, either wholly or partly, and to fulfill its obligations under the Stockholm Convention. Assessment of the required funds is based on cost assessment of individual action plans and strategies. Total implementation costs of NIP's key segments are estimated to amount to nearly 13.4 million USD. It is important to note that some tasks have no direct cost. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 06-07 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Table of Contents Executive Summary Table of Contents List of Acronyms List of Figures Introduction 1.1. Background 1.2. Objectives 1.3. Methodology 1.4. Report Organization Country Baseline 2.1. Country Profile 2.1.1. Country Geography and Demography 2.1.2. Political and Economic Profile 2.1.3. Profiles of Economic Sectors 2.1.4. Environmental Overview 2.2. Institutional Policy and Regulatory Framework 2.2.1. Environmental Policy, Sustainable Development Policy and General Legislative Framework 2.2.2. Roles and Responsibilities of Ministries, Agencies and Other Governmental Institutions Involved in POPs Life Cycles 2.2.3. Relevant International Commitments and Obligations 2.2.4. Key Approaches and Procedures for POPs Chemical and Pesticide Management including Enforcement and Monitoring Requirements 2.3. Assessment of the POPs Issue in the Country 2.3.1. Assessment with respect to Annex A, part I chemicals (POPs pesticides): historical, current and projected future production, use, import and export; existing policy and regulatory framework; summary of available monitoring data (environment, food, humans) and health impacts 2.3.2. Assessment with respect to Annex A, part II chemicals (PCBs)(PCB) 2.3.3. Assessment with Respect to Annex B Chemicals (DDT) 2.3.4. Assessment of Releases from Unintentional Production of Annex C Chemicals (PCDD/PCDF, HCB and PCBs) (Dioxin, BAT/BEP, PCBs) 2.3.5. Information on the State of Knowledge on Stockpiles, Contaminated Sites and Wastes, Identification, Likely Numbers, Relevant Regulations, Guidance, Remediation Measures and Data on Releases from Sites 2.3.6. Summary of future production, use and releases of POPs - requirements for Exemptions 2.3.7. Existing programmes for monitoring releases and environmental and human health impacts, including finding 2.3.8. Current Level of Information, Awareness and Education among Existing Target Groups 2.3.9. Relevant Activities of Non-Governmental Stakeholders 01 07 09 12 13 13 13 14 14 15 15 15 16 18 21 23 23 23 25 26 30 30 38 40 41 43 45 46 48 48 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 08-09 2.3.10. Overview of technical infrastructure for POPs assessment, measurement, analysis, alternatives and prevention measures, management, research and development - linkage to international programmes and projects 2.3.11. Identification of impacted populations or environments, estimated scale and magnitude of threats to public health and environmental quality and social implications for workers and local communities 2.3.12. Details of any relevant system for the assessment and listing of new chemicals 2.3.13. Details of any relevant system for the assessment and regulation of chemicals already in the market Strategy and Action Plan Elements of the National Implementation Plan 3.1 Policy Statement 3.2. Implementation Strategy 3.2.1. Introduction 3.2.2. Criteria and Priority Areas 3.2.3. Priority Setting 3.3. Activities, Strategies and Action Plans 3.3.1. Activity 1: Institutional and Regulatory Strengthening Measures 3.3.2. Activity 2: Measures to Reduce or Eliminate Releases from Intentional Production and Use 3.3.3. Activity 3: Production, Import and Export, Use, Stockpiles and Wastes of Annex A POPs Pesticides (Annex A, Part 1 Chemicals) 3.3.4. Activity 4: Production, Import and Export, Use, Identification, Labeling, Removal Storage and Disposal of PCBs and Equipment Containing PCBs (Annex A, part II chemicals) 3.3.5. Activity 5: Production, Import and Export, Use, Stockpiles and Wastes of DDT (Annex B chemicals) if used in the Country 3.3.6. Activity 6: Register for Specific Exemptions and the Continuing Need for Exemptions 3.3.7. Action Plan 7: Measures to Reduce Releases from Unintentional Production 3.3.8. Activity 8: Measures to Reduce Releases from Stockpiles and Wastes 3.3.9. Strategy: Identification of Stockpiles, Articles in Use and Wastes 3.3.10. Activity: Manage Stockpiles and Appropriate Measures for Handling and Disposal of Articles in Use 3.3.11. Strategy: Identification of Contaminated Sites (Annex A, B and C Chemicals) and Remediation in an Environmentally Sound Manner 3.3.12. Activity 12: Facilitating or Undertaking Information Exchange and Stakeholder Involvement 3.3.13. Activity 13: Public Awareness, Information and Education 3.3.14. Activity 14: Effectiveness Evaluation 3.3.15. Activity 15: Reporting 3.3.16. Activity 16: Research, Development and Monitoring 3.3.17. Activity 17: Technical and Financial Assistance 3.4. Development and Capacity-Building Proposals and Priorities 3.5. Timetable for Plan Implementation and Measures of Success 3.6. Resources Requirements References 51 55 56 56 57 57 57 57 58 61 62 63 66 68 68 70 70 70 73 75 77 79 81 83 85 87 89 91 93 94 98 100 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon List of Acronyms Al Aluminum AAA Amino Acid Analysis AAS Atomic Absorption Spectrophotometer ACTS Advanced Construction Technology Services ALI Association of Lebanese Industrialists APC Air Pollution Control AUB American University of Beirut BAT Best Available Techniques BEP Best Environmental Practices BOD Biological Oxygen Demand BS Bachelor of Sciences CAS Central Administration of Statistics COP Conference of the Parties CDR Council for Development and Reconstruction CoM Council of Ministers CRSL Central Research Science Laboratory DDD Dichlorodiphenyldichloroethane DDE Dichlorodiphenyldichloroethylene DDT Dichlorodiphenyltrichloroethane ECL Environment Core Laboratory EDL Electricité Du Liban EERC Environmental Engineering Research Center EIA Environmental Impact Assessment ELARD Earth Link and Advanced Resources Development EPA Environmental Protection Agency ERM Environmental Resources Management EU European Union FAO Food and Agricultural Organization of the United Nations GBA Greater Beirut Area GC-ECD Gas Chromatograph Electron Capture Detector GC-NPD Gas Chromatograph Nitrogen Phosphorus Detector GC-FID/PID Gas Chromatograph-Flame Ionization Detector/Photo-Ionization Detector GC-MS Gas Chromatograph/Mass Spectrometer GCLL General Confederation of Lebanese Labors GD General Directorate GEF Global Environment Facility GoL Government of Lebanon GDP Gross Domestic Product HCB Hexachlorobenzene HGU Hydrogen Generation Unit HPLC High Performance Liquid Chromatography HRGC-HRMS High Resolution Gas Chromatography/High Resolution Mass. Spectrometry HS Harmonized System ICP-MS Inductively Coupled Plasma -Mass Spectrometer IDAL Investment Development Authority of Lebanon IDRC International Development Research Center ILO International Labor Organization IRI Industrial Research Institution POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 10-11 ISO International Organization for Standardization LARI Lebanese Agricultural Research Institute LAU Lebanese American University LBP Lebanese Pounds LC-MS Liquid Chromatograph/Mass Spectrometer LCA Lebanese Customs Authority LEAC Lebanese Atomic Energy Commission LSC Liquid Scintillation Counters LT Long Term LU Lebanese University LWA Litani Water Authority METAP Mediterranean Environmental Technical Assistance Program MoA Ministry of Agriculture MoE Ministry of Environment MoEHE Ministry of Education and Higher Education MoET Ministry of Economy and Trade MoEW Ministry of Energy and Water MoPH Ministry of Public Health MoI Ministry of Industry MoIM Ministry of Interior and Municipalities MoL Ministry of Labor MoPWT Ministry of Public Works and Transport MoSA Ministry of Social Affairs MS Masters of Sciences MSW Municipal Solid Waste MT Medium Term NCSR National Council for Scientific Research NGO Non-Governmental Organization NIP National Implementation Plan NEW-SSW North East West-South South West P&TGC-MS Phosphorous and Total Gas Chromatography Mass Spectrophotometer PAH Poly-Aromatic Hydrocarbons PCB Polychlorinated Biphenyls PCDD Polychlorinated Di-benzo-para-Dioxins PCDF Polychlorinated Di-benzo-para-Furans PhD Doctor of Philosophy POPs Persistent Organic Pollutants PVC Polyvinylchloride SC Stockholm Convention SES Sanitary Engineering Service SoER State of Environment Report SoR Service of the Registry ST Short Term TEQ Toxic Equivalent UN United Nations UNDP United Nations Development Programme UNEP United Nations Environment Programme USAID United Sates Agency for International Development USD United States Dollars USJ University Saint-Joseph UV Ultra-Violet UNIDO United Nations Industrial Development Organization WWTP Wastewater Treatment Plants POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Units of Measurement °C Degrees Celsius ha Hectares km Kilometers L Liters L/cap/day Liters per capita per day m2 Square meter m3 Cubic meter m3/day Cubic meters per day mm/year Millimeters per year Mm3 Million cubic meters List of Tables 2.1. Administrative Divisions of the Republic of Lebanon 2.2 GDP Breakdown and Growth Rates by Sector 2.3. Agricultural Output Values (2001-2003) 2.4. Total Production per Crop Type (in Billions of LBP) 2.5. Animal Products Values (2001-2003) 2.6 Distribution of the 8 Largest Industrial Sectors by Governorates 2.7 Responsibilities of Government Ministries, Agencies and Other Institutions 2.8 Membership in International Organizations and Bodies 2.9 Participation in International Agreements 2.10 References to Existing Legal Instruments Regarding Agro-Chemicals 2.11 References to Existing Legal Instruments regarding Consumer Chemicals 2.12 References to Existing Legal Instruments Addressing Industrial Chemicals 2.13 DDE and DDT Sediment Levels in El Kabir Watershed (in ppb) 2.14 PCB and Pesticide Presence in Fish Species (mg/kg wet weight) 2.15 PCDD/PCDF Annual Emission Levels per Category 2.16 Results of Dioxin Soil Sampling and Analysis in Two Power Stations: Jamhour and Bsalim (Kaskas and Kodeih, MoE, 2001) 2.17 Total Quantity of PCB-Oil Present at Zouk and Jieh Power Plants 2.18 Possible Hotspots for POPs Releases and Potential Exposure 2.19 Quality and Quantity of Available Information 2.20 Location of National Data 2.21 Relevant Environmental NGOs 2.22 Summary of Expertise Available Outside the Government 2.23 Overview of Laboratory Infrastructure for Regulatory Chemical Analysis 3.1 Activity 1: Institutional and Regulatory Strengthening Measures 3.2 Activity 2: Measures to Reduce or Eliminate Releases from Intentional Production and Use 3.3 Activity 4: Production, Import and Export, Use, Identification, Labeling, Removal Storage and Disposal of PCBs and Equipment Containing PCBs (Annex A, part II chemicals) 16 19 19 20 20 21 24 25 26 33 34 35 40 41 42 43 44 45 46 47 50 51 52 60 61 61 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 12-13 3.4 Action Plan 7: Measures to Reduce Releases from Unintentional Production 3.5 Activity 8: Measures to Reduce Releases from Stockpiles and Wastes 3.6 Strategy: Identification of Stockpiles, Articles in Use and Wastes 3.7 Activity 10: Manage Stockpiles and Appropriate Measures for Handling and Disposal of Articles in Use 3.8 Strategy: Identification of Contaminated Sites (Annex A, B and C Chemicals) and Remediation in an Environmentally Sound Manner 3.9 Activity 12: Facilitating or Undertaking Information Exchange and Stakeholder Involvement 3.10 Activity 13: Public Awareness, Information and Education 3.11 Activity 14: Effectiveness Evaluation 3.12 Activity 15: Reporting 3.13 Activity 16: Research, Development and Monitoring 3.14 Activity 14: Effectiveness Evaluation 3.15 Timetable for Action Plan Implementation and Measures of Success 3.16 Implementation Costs of Activities Covered by the NIP with their Sources of Funding 3.17 Activity 17: Technical and Financial Assistance 3.18 Timetable for Action Plan Implementation and Measures of Success 3.19 Implementation Costs of Activities Covered by NIP with their Sources of Funding 64 67 69 71 74 76 78 80 82 84 86 88 90 92 95 99 15 17 18 27 28 28 29 39 List of Figures 2.1 Population Distribution in Lebanon 2.2 Administrative Boundaries of Lebanon 2.3 Institutional Framework in Lebanon 2.4 Registration Procedure of Pesticide that will be imported, produced, or formulated 2.5 Lebanese Customs Procedure for Import of Pesticides 2.6 Procedures for Import of Substances restricted by Basel Convention in Lebanon 2.7 Permitting Procedures for the Import of Pesticides for Domestic Use 2.8 Overview of the Energy Sector and PCB-oil POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon In t roduct ion 1.1. Background The Government of Lebanon (GoL) signed the Stockholm Convention (SC) on May 22, 2001; it came into force on May 17, 2004. Recognizing the impact of POPs on human health and the environment, the Stockholm Convention on Persistent Organic Pollutants (POPs) aims to: (1) Protect human health and the environment through measures which will reduce and/or eliminate emissions and discharges of POPs; (2) Eliminate and remove from use equipment containing more than 0.005% (50 parts per million) polychlorinated biphenyls and volumes greater than 0.05 liters, by 2025. It also prohibits the production of PCBs as well as their import or export for purposes other than environmentally sound waste management; (3) Eliminate the production and use of the POPs pesticides with the exception of DDT (Aldrin, Chlordane, Dieldrin, Endrin, Heptachlor, Hexachlorobenzene, Mirex and Toxaphene), as specified in Part I of Annex A; and restrict the production and use of DDT to acceptable purposes as specified by Part I of Annex B. (4) Require the use of Best Available Techniques (BAT) for new sources in categories listed under Part II of Annex C of the Convention that shall be phased in as soon as practicable but no later than four years after the entry into force of the Convention (May, 2008). Promote the use of BAT and BEP for existing sources listed under Part II and III of Annex C of the Convention and for new sources under Part III of the Annex. Pursuant to the Convention, each party shall (i) develop and endeavor to implement a plan for the implementation of its obligations under the Convention; (ii) transmit its implementation plan to the Conference of the Parties within two years of the date on which this Convention enters into force for it; and (iii) review and update, as appropriate, its implementation plan on a periodic basis and in a manner to be specified by the Conference of Parties (COP)1 . With grant funding from the Global Environment Facility (GEF)/UNEP, Lebanon is one of 12 countries participating in a pilot project for the “Development of National Implementation Plans for the Management of POPs.”2 Pursuant to the project objectives, the Ministry of Environment (MoE) prepared three preliminary inventories for pesticides3, dioxins and furans4, and PCBs5. These inventories were prepared and submitted in 2005 and received excellent ratings from the UNEP Secretariat. Building on these inventories, MoE in collaboration with relevant stakeholders prepared the National Implementation Plan (NIP) for POPs management in Lebanon. This plan was prepared during the period ranging from April through November 2005. In addition to the preliminary Inventories and National Profile, Lebanon prepared a "Health and Environment Profile" to evaluate the intensity of the effects of POPs pollutants. This report was finalized in August 20056. 1.2. Objectives The purpose of this report is to assist the Government of Lebanon define and implement its obligations under the Convention. In particular, the objectives of the NIP are to7: (1) Identify and gather information on possible options for management of POPs to implement the SC with indication of the scope of application, limitations, costs and benefits for each option. 1 Stockholm Convention on Persistent Organic Pollutants, Article 7, pg. 13 2 Project Ref nº GF/2732-02-4458 3 Inventory was prepared in 2005 by ELARD 4 Inventory was prepared in 2005 by ELARD 5 Inventory was prepared in 2005 by ECODIT Liban 6 Health and Environment Profile, ELARD 2005 7 Guidance for Developing a National Implementation Plan for the Stockholm Convention (Chapter 8). UNEP-World Bank. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 14-15 (2) Evaluate the options available and actions necessary to meet the requirements of the SC and country objectives. (3) Identify requirements for assistance in the completion of additional assessments and information gathering to complete and implement the NIP. 1.3. Methodology This National Implementation Plan builds on the findings of the preliminary inventories conducted earlier in 2005. The inventories were compiled using a combination of field investigations, sampling and testing, literature review and interviews. Major milestones during the implementation of this NIP include: (1) Three Preliminary Inventories covering: a. Dioxins and Furans b. POPs Pesticides c. PCBs (2) The National Profile of Chemicals Management in Lebanon (3) The Health and Environment Profile of Lebanon (4) Priority setting: Several NIP reports were reviewed (e.g., Croatia, Jamaica, Latvia, Poland) to explore alternative techniques for priority setting including evaluation criteria and scoring matrices. It was decided to aggregate the recommendations from the preliminary inventories into nine priority areas and to score these areas using five evaluation criteria. (5) Validation of tentative priority issues: MoE organized a priority-setting workshop in August 2005. This two-day workshop was attended by representatives from 14 private and public agencies and lead to the validation of nine priority areas across all three groups of chemicals (pesticides, dioxins and furans, and PCBs). All the participants received prior to the workshop an information package containing relevant materials including executive summaries of the inventories and scoring matrices. (6) Draft NIP document review: MoE organized a second workshop for the NIP draft document review in November 2005 hosted at the American University of Beirut (AUB) to present and discuss the draft document with emphasis on the proposed action plans. During this one-day workshop, participants made valuable suggestions for improvement to the draft NIP document as part of the working group session (the participants received prior to the workshop a copy of the draft document for their review). Participants discussed the actions and tasks specific to each chemical group and those common to all three. 1.4. Report Organization Consistent with the UNEP guidelines on the NIP structure, this report is organized into three chapters and thirteen subchapters, and its subsequent appendices as follows8: Executive Summary (1) Introduction a. Background b. Objectives c. Methodology d. Report Organization (2) Country Baseline a. Country profile b. Institutional polity and regulatory framework c. Assessment of the POPs issue in the country (3)Strategy and Action Plan Elements of the National Implementation Plan a. Policy statement b. Implementation strategy c. Activities, strategies and actions plans d. Development and capacity-building proposal and priorities e. Timetable for plan implementation and measures of success f. Resource requirements 8 Guidance for Developing a National Implementation Plan for the Stockholm Convention (Annex 5). UNEP-World Bank. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 9 FAO, 2002 10 CAS, 2005 11 MoSA/UNDP, 1996 12 CAS, 2005 Country Baseline 2.1. Country Profile This section presents background information on Lebanon, particularly the physical, demographic, geographic, and economic status in the country, with emphasis on the industrial and agricultural sectors. 2.1.1. Country Geography and Demography Lebanon lies between latitudes 33°03'-34°45' and longitudes 35°05'-36°30'9. The dominating topographic features of Lebanon are two parallel mountainous ranges, Mount Lebanon and Anti Lebanon, separated by the Bekaa plain. These topographic features extend in a NNE-SSW direction, and largely influence the climate of the country. The climate of the Lebanese coast is of Mediterranean subtropical type, with hot and dry summers, and mild and wet winters. The two mountain ranges tend to have a cool and wet climate in contrast to that of the coastal zone, whereby snow covers their mountains for several months per year. Average humidity on the coast ranges from 60's to high 70's. During the summer months of May through September, the average daily temperature in Beirut ranges from 22°C to 30°C. January and February are the coldest months of the year when the average temperature in the capital is 14°C, rarely falling below 8°C. Lebanon has a total area of 10,452 km2 of which 222 km2 are water and 10,230 km2 are land, and total land boundaries of 454 km of which 375 km are with Syria from the North and the East, and 79 km with Palestine from the South. The country is bound from the West by the Mediterranean Sea with a coastal strip of 225 km. Lebanon's total population was estimated at 3,753,785 persons in 200410. 247,835 out of the total residents in Lebanon are foreigners. A total of 40% of the Lebanese population is concentrated in Mount Lebanon. Population distribution in Lebanon is shown in Figure 2.1. Females cover 50.2% of the total population with 1,885,563 and males reached a percentage of 49.8% with 1,868,222. The rate of unemployment as declared averaged to 3.8%. The rate of illiteracy in the same year was estimated to be 7.5%.The crude death rate of the overall Lebanese population is estimated at around 7.4 deaths per 1000 persons, with mortality rate being higher for men (7.9‰) than for women (6.9‰), while crude birth rate is around 24.6 live births per 1000 people11. Figure 2.1. Population Distribution in Lebanon12 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 16-17 2.1.2. Political and Economic Profile Lebanon is a republic, with the official language being Arabic while French and English are the two locally used languages. The country's institutional authorities consist of: 1) The Legislative authority: represented by the General Assembly of the Parliament whose role is to issue and update legislation; 2) The Executive authority: represented by the Council of Ministers (CoM) and its support institutions; and 3) The Judiciary authority: represented by the Higher Council of Justice (whose role is to apply the legislation). The Secretary General of the Prime Minister, the Ministries and their dependent councils constitute the administrative institutions of the central government. The Head of the State is the President of the Republic, who is elected by the Parliament and supervises the functions of each of the individual Lebanese authorities. The Prime Minister is appointed by the President after consulting the members of Parliament. The Prime Minister forms a government by appointing cabinet ministers whose appointments are ratified by Parliament. The central government is supported by a number of public institutions that include the Council for Development and Reconstruction (CDR), Civil Service Board, Central Inspection, Disciplinary Council, Investment Development Authority for Lebanon (IDAL), Electricity of Lebanon, National Council for Scientific Research (NCSR), among others. Recent developments had led to changes in the administrative regions of the Lebanese Republic. According to Law nº 522 (16-07-2003) and Decree nº 11861 (16-07-2003) 2 Governorates, Akkar and Baalbek EL-Hermel, were added to the 6 administrative regions or Governorates (Mouhafazas) and are summarized in Table 2 1. These are also illustrated in Figure 2 2. Table 2.1. Administrative Divisions of the Republic of Lebanon Mouhafaza (Governorate) Cazas Beirut North Lebanon Tripoli, Minieh, Sir Ed-Diniyeh, Zgharta, Bcharrreh, Koura & Batroun Akkar Akkar Baalbek El-Hermel Baalbek and Hermel Mount-Lebanon Baabda, Keserwan, Metn, Jbeil, Aley & Shouf Bekaa Zahle, West Bekaa & Rachaiya South Lebanon Sidon, Jezzine, Zahrani & Tyre Nabatiyeh Nabatiyeh, Hasbaya, Marjayoun & Bint Jbeil POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Each Mouhafaza is headed by a Mouhafez - a chief administrator from the Ministry of Interior and Municipalities (MoIM). The Mouhafez represents the National Government administration in the region of his Mouhafaza and is directly responsible to the MoIM. Each Mouhafaza has two advisory councils: the Council of the Mouhafaza and the Health Council whose recommendations are advisory and not binding. Law enforcement in the Mouhafaza is the responsibility of the Mouhafez who also grants permits to establish, build or operate classified establishments, with the exception of industrial establishments, whereby recent legislation attributes this role to the Ministry of Industry (MoI) and assigned permitting committees. All Mouhafazas are composed of Cazas except for the Mouhafaza of Beirut, whereby each Caza is headed by a Qaimmacam. The National Government administration in the Caza is therefore represented by the Qaimmacam who reports directly to the Mouhafez. The Municipalities and Councils of Elders make up the local government in Lebanon. The Mayor heads the municipality enjoying a vast authority over local affairs, while the Moukhtar heads the Council of Elders and undertakes the services related to statements of birth, death, personal identification, property and inheritance. Figure 2 .3 represents the existing institutional arrangements in Lebanon. 13 Courtesy of NCRS Figure 2.2. Administrative Boundaries of Lebanon13 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 18-19 2.1.3. Profiles of Economic Sectors Local economy in Lebanon mainly depends on the trade and services sector, which are common in coastal cities with abundant ports such as Tripoli, Sidon and Beirut. Agriculture is dominant in the Bekaa valley, in addition to the North and South Governorates. The main agricultural products include citrus, potatoes, grapes, olives, apples, and tobacco. The bulk of the Lebanese industry is concentrated in Mount Lebanon, the sea front suburbs of Beirut and the coastal area of northern Lebanon. Major products include construction material, food processing, textiles and readymade garments, furniture and jewelry. The distribution of GDP among the three main sectors is shown in Table 2.2. 14 adapted from METAP, 2002 Figure 2.3. Institutional Framework in Lebanon14 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 2.1.3.1. Agriculture and Livestock Sectors According to statistics done in 2003 by FAO, the value of agricultural products (Table 2.3) reached 1,900 billion Lebanese Pounds (LBP) divided as follows: o 72% (1,366 billion LBP) as crop output; and o 28% (534 billion LBP) as animal output. Agricultural production has shown a regression of 2% in 2003 compared to 2002. Lebanon produces crops in five major categories: (1) cereals, (2) fruits, (3) olives, (4) industrial crops (e.g. sugar beet, tobacco) and (5) vegetables. A recent MoA/FAO survey showed that 267,000 hectares of land were cultivated in Lebanon16, of which around 49% are irrigated. Table 2.4 indicates total production per crop type. Table 2.2 GDP Breakdown and Growth Rates by Sector15 Sector % contribution % yearly change rate 1997 2002 in value in price in volume Agriculture 6.5 5.8 0.8 -1.2 2.0 Energy & water supply 0.9 1.0 3.7 0.4 3.2 Industry 13.5 11.7 0.1 -1.6 1.7 Construction 9.4 7.7 -1.0 1.9 -2.9 Transport & communication 5.2 6.5 7.5 -0.3 7.8 Services 31.7 32.9 3.8 1.6 2.2 Trade 21.3 21.8 3.5 2.8 0.7 Public administration 11.5 12.6 4.9 - 4.9 Total GDP 100.0 100.0 3.0 1.0 2.0 15 MoET, 2005 16 MoA/FAO, 2003 Table 2.3. Agricultural Output Values (2001-2003) Product Type Production 2001 Production 2002 Production 2003 (Billion LBP) (Billion LBP) (Billion LBP) Value % Value % Value % Crop output 1247 70 1408 73 1366 72 Animal output 533 30 521 27 534 28 Total 1,780 100 1,929 100 1,900 100 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 20-21 Table 2.4. Total Production per Crop Type (in Billions of LBP)17 Product Types Production (Billions LBP) Cereals 28.9 Vegetables 372.7 Industrial Crops 100.8 Fruit Trees & other trees 646.5 Olives 110.3 Other Trees 41.9 Grameninaceae 65.1 Total 1,366.2 The majority (53%) of Lebanese farmers work in small sized (less than 0.5 ha) farms, which represent 9% of the total cultivated area in Lebanon. Medium sized farms (0.5-10 ha) provide work for 45.4 % of Lebanese farmers while only 1.6% of farmers work in large farms (>10ha), representing 61 and 30% of total cultivated area respectively. In regions where soil fertility is relatively low, such as the Baalbek-Hermel area, livestock production constitutes an important activity (Table 2.5). 2.1.3.2. Industrial Sector Excluding water, power and construction activities, Lebanon has 23 industrial branches. The majority of the manufacturing sector is made up of micro facilities (90%), while small facilities and medium facilities represent 9.7 and 0.2% of the sector respectively. Large facilities constitute 0.1% of the sector. Food products and beverages is the largest industrial sector in the country, followed by fabricated metal products and non-metallic mineral products. Table 2.6 shows the distribution of the 8 largest industrial sectors by region. 17 MoA, 2003 18 MoA/FAO, 2003 Table 2.5. Animal Products Values (2001-2003)18 Product Production 2001* Production 2002* Production 2003* Milk 23 24 26 Red Meat 11 13 15 Chicken Meat 41 39 35 Eggs 10 10 10 Honey 4 3 4 Fish 11 11 10 Total 100 100 100 Total Value (in Billion LBP) 533.1 521 534.1 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon The total number of facilities is in the range of 22 thousand, employing over 78,000 persons. Mount Lebanon holds the majority of the industries with almost half of them located within its administrative boundaries, and thus also holds the largest number of employees (almost 60%). 2.1.4. Environmental Overview20 2.1.4.1. Water Although water is one of Lebanon's most precious resources and while significant investments are made to tap water resources, very little is done to preserve them. Human activities exert strong pressures on both the quantity and quality of water resources. In addition, many activities affect the water cycle thereby altering the conditions for water replenishment. Lebanon is in a relatively fortunate hydrological situation, where it is estimated that the yearly precipitation gives rise to 40 major streams and rivers and more than 2,000 springs. Approximately 50% of the average yearly precipitation is lost through evapo-transpiration, while additional losses include surface water flows to neighboring countries21 (8%) and groundwater seepage (12%). Snow cover is a principal source contributing to groundwater recharge, where estimates for the groundwater quantity available for exploitation range from 400 to 1,000 million m3/year. Thus, 2,600 million m3 of surface and groundwater remain potentially available and 2,000 million m3 is deemed exploitable. Lebanon has 17 perennial streams and about 23 seasonal ones; whose combined length is approximately 730 km and total annual flow averages 3,900 million m322. Agriculture is by far the largest consumer of water, followed by domestic and industrial uses. Auxiliary uses and functions of water include the generation of hydroelectricity (hydroelectric power plants), recreation (water parks and sports), and aquaculture. Water quality is adversely affected by industrial, agricultural and domestic wastewaters Water bodies receive or are affected by liquid effluents and solid waste from about four million people and 22,000 industrial establishments24. The prevalence of fissured limestone formations in Lebanon facilitates the seepage of liquid wastes into groundwater25. 2.1.4.2. Wastewater Domestic wastewater management is one of the greatest concerns of Lebanese municipalities and concerned ministries (MoEW, MoIM, CDR). Lebanon generates an estimated 249 million m3 of wastewater per year, with a total BOD load of 99,960 tons. Industries generate an estimated 43 million m3 of wastewater per year. Currently, there are about 53 wastewater outfalls along the coast26, whereby some 2.3 million people live in the coastal zone. They release approximately 950,000 m3 of wastewater a day, most of it ending up in the sea27. 19 MoI, 2000 20 This section is based on the State of the Environment Report (SOER) by MoE/ECODIT, 2001 21 Litani Water Authority (LWA) 22 SOER, MoE/ECODIT, 2001 23 CAS Study No. 9, 1998 24 MoI, 2000 25 SOER, MoE/ECODIT, 2001 26 CDR/LACECO, 2000c 27 CDR/ECODIT-IAURIF, 1997 Table 2.6 Distribution of the 8 Largest Industrial Sectors by Governorates19 Number of Facilities Mouhafaza Beirut Mount Lebanon North South Bekaa Nabatiyeh Total Industry Food Products & Beverages 720 1,615 1,020 385 580 160 4,480 Leather & Leather Products 143 969 117 15 21 25 1,290 Textiles 76 500 115 38 56 19 804 Clothes & Dyeing Fur 534 1,302 286 18 95 28 2,263 Wood Products 208 1,188 151 309 310 83 2,249 Non-metallic Mineral Products 20 1,132 551 238 458 131 2,530 Fabricated Metal Products 286 1,946 477 274 371 199 3,553 Furniture & Other Manufactured 185 1,018 770 236 104 39 2,352 Goods POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 22-23 About 38% of all buildings in Lebanon were connected to a sewer network28. The remaining buildings (62%) either use cesspools and septic tanks or simply release raw sewage directly into the environment, including rivers and streams, dry river beds, and underground (through dry wells). Since 1997, extensive wastewater works have been achieved, which has presumably improved the wastewater collection capacity29. Thirty-five wastewater treatment plants (WWTP) are currently planned or under construction. The GoL initiated the construction of 7 WWTPs in 2001: Saida, Chekka, Batroun, Jbeil, Chouf coastal area, Baalbeck and Nabatiyeh. The only large-scale WWTP that is currently operational is the Ghadir plant, south of Beirut, which provides only preliminary treatment. About 50 small scale WWTPs have been established in rural areas, mainly via NGOs, the majority of which are non-operational, degraded, or incomplete30. 2.1.4.3. Solid Waste Varying degrees of Solid Waste Management is currently practiced in different parts of the country. Solid waste continues to be managed in a manner that is not protective of either human health and/or the environment. Municipal Solid Waste (MSW) makes up about 90% of the total solid waste stream generated in Lebanon. The main sources of MSW are households, commercial establishments, street markets, street cleaning operations, and public garden pruning. Lebanon generated about 1.44 million tons of MSW in 2001 (~3,940 tons/day), or about 0.92 kg/person/day. Organic waste is by far the single largest component of the MSW stream, representing over 63% of the total MSW quantity in Greater Beirut Area (GBA) and slightly over 50% at the national level. In the GBA, MSW has been managed in accordance with the 1997 Emergency Plan. To date, key solid waste management indicators (recycling and composting) remain below target, which have drastically reduced the projected lifetime of the Naameh sanitary landfill. Outside the GBA, local municipalities are responsible for waste collection and disposal. These often subcontract waste collection to local entrepreneurs and small businesses. Waste is then transported to nearby open dumps, typically located in the outskirts of the village. Due to the absence of an overall long-term strategy, mayors are being approached by small scale private businesses with their own waste treatment technologies, many of which are poorly founded and unreliable31. 2.1.4.4. Biodiversity and Natural Heritage Lebanon's biological wealth has been influenced by successive civilizations, and is closely related to its geomorphology and micro-climates. Roughly three quarters of the total surface area of the country is mountainous, which gives rise to many micro-climates, favorable to the occurrence of many plant and animal species and communities. There are 5 geomorphological regions in Lebanon: (1) the coastal zone, (2) the Mount Lebanon range, (3) Bekaa Plain, (4) The Anti-Lebanon Range, and (5) South Lebanon32. The number of known fauna and flora in Lebanon are 4,486 and 4,633 respectively33. 2.1.4.5. Energy The Ministry of Energy ad Water (MoEW) is currently responsible for the petroleum and gas sectors, while the executing agency is the General Directorate of Petroleum (GDoP), which is responsible for licensing import activities, importing crude and fuel oil, and setting prices for petroleum products. Lebanon is entirely dependent on imports of fuel for energy. Excluding limited hydropower, primary energy consumption was about 4.1 Mtoe in 1999, up from 3.5 Mtoe in 199334, which is equivalent to about 0.95 toe/person (or 39.9 GJ/person)35. Primary energy sources include gasoline, gas oil, fuel oil and diesel oil, in addition to several other minor petroleum products such as aircraft oil, liquid gas and tar. The combustion of petroleum products, charcoal, and other combustibles releases significant amounts of pollutants into the atmosphere. In addition, leaking underground storage tanks containing petroleum products and accidental oil spills could lead to significant pollution of soil, fresh water resources, and the sea36. 28 CAS census of Buildings and Establishments, 1996-1997 29 SOER, MoE/ECODIT, 2001 30 MSC/IPP, 2005 31 SOER, MoE/ECODIT, 2001 32 SOER, MoE/ECODIT, 2001 33 Biological Diversity of Lebanon, MoA/UNEP, 1996 34 METAP/ERM, 1995 35 Toe is Tonnes of oil equivalent. 1 Toe is equivalent to 41.8 Giga Joules (GJ) 36 SOER, MoE/ECODIT, 200137 Trabulsi, 1991; Abou Fakhr et al., 1995 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 2.2. Institutional Policy and Regulatory Framework 2.2.1. Environmental Policy, Sustainable Development Policy and General Legislative Framework The Lebanese Framework Law on the Protection of the Environment (Law 444/2002) mentioned the necessity to set standards and criteria to control the transport and movement of hazardous chemicals (import, production, extraction, conversion, marketing, purchase, utilization, abatement, transport and disposal). However, the ratification of the Stockholm Convention by Lebanon in 2002 (Law 432) can be considered the first legal step towards the commitment to the need to regulate the production, utilization of persistent organic pollutants in specific. Other than the legal texts mentioned above, Lebanese legislation sporadically addresses hazardous chemicals in different laws, decrees and ministerial decisions especially the law 64/1988 on hazardous waste, and the decree 8006/2002 and its amendments on the management of health care waste (which includes hazardous and persistent chemicals) (Decree 13389/2004). National environmental standards were issued by the Minister of Environment (decision 52/1 1996 and decision 8/1 2001), however POPs were not covered. At the level of POPs trade, the laws on customs still lack proper classification to effectively control the imports and exports of material containing POPs. Within the agriculture sector, despite the fact that the SC called for the banning of the utilization of POPs and despite the existence of a list published in 1992 by the Ministry of Agriculture officially banning certain pesticides, the control by the government at the marketing level and the enforcement of the law are believed to be weak. Therefore, even banned products are made available by illegal means (smuggling) and used by the public, in addition to the misuse of several agents, regardless of any health and ecological toxicity risks37. A special committee was established at the Ministry of Agriculture in 1998 to control agriculture chemicals; however, there is a conflict in mandates between MoA and MoE which is also assigned the task of specifying the chemicals and agrochemicals that harm human health and the environment. In addition, although there are legal texts setting requirements for labeling and storage of agrochemicals, adequate enforcement is needed to guarantee the effectiveness of such articles. Disposal of hazardous material is controlled by the law 64/1988 which sets the basis for licensing of facilities specialized in the disposal of hazardous waste, and giving the MoE the authority of licensing and monitoring of these facilities. However, hazardous waste management is still lagging behind due to the delayed application of an integrated solid waste management strategy. 2.2.2. Roles and Responsibilities of Ministries, Agencies and Other Governmental Institutions Involved in POPs Life Cycles A number of ministries play a role in chemical management. The Ministry of Agriculture is practically handling activities concerned with agricultural pesticides, the Ministry of Environment deals with hazardous and industrial chemicals, the Ministry of Public Health is responsible of pesticides destined for domestic use and the Ministry of Energy and Water is responsible for the import of petroleum derivatives. Table 2.7 provides a general overview of ministerial responsibilities and activities related to chemicals management through its life-cycle from production/import to final disposal. 37 Trabulsi, 1991; Abou Fakhr et al., 1995 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 24-25 T ab le 2 .7 R es po ns ib il it ie s of G ov er nm en t M in is tr ie s, A ge nc ie s an d O th er I ns ti tu ti on s St ag es o f L ife c yc le Im po rt Pr od uc tio n St or ag e T ra ns po rt D is tr ib ut io n/ U se D is po sa l C he m ic al T yp e Le ga l I ns tr um en t En tit y C on ce rn ed m ar ke tin g H an dl in g M oE 1 a a a a a a In du st ri al c he m ic al s, La w n º6 90 , 2 7/ 08 /2 00 5 Pe st ic id es M oP H 2 a a a a a In se ct ic id es D ec re e 83 77 , 3 0/ 12 /1 96 1 M oA 3 a a a a a Pe st ic id es D ec re e 50 39 , 2 0/ 06 /1 99 4 M oL 4 a O cc up at io na l; in du st ri al D ec re e 83 52 , 3 0/ 12 /1 96 1 M oI 5 a a a a In du st ri al D ec re e 13 17 3, 0 8/ 10 /1 99 8 M oE W 6 a a a a a a Pe tr ol eu m La w n º 2 47 (r ep la ce d La w nº 9 /3 7 da te d 32 1 2 19 73 & is su ed o n 07 0 8 20 00 ) LC A 7 a Im po rt ed c he m ic al s D ec re e 44 61 (i ss ue d on 15 1 1 20 00 ) 1: Ministry of Environment 2: Ministry of Public Health 3: Ministry of Agriculture 4: Ministry of Labor 5: Ministry of Industry 6: Ministry of Energy and Water 7: Lebanese Customs Authority POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Responsibilities for POPs management in Lebanon are not well delineated. Governmental institutions potentially involved in the life cycles of POPs include the Ministry of Environment (MoE), the Ministry of Energy and Water (MoEW) and Ministry of Finance (MoF) as described next. • MoE has lead responsibility on all matters related to the Convention (e.g., reporting, awareness). The focal point for the Convention is the Service of Environmental Technology. The ministry hosted and executed the Lebanese component of the regional UNEP project for the management of POPs. • MoEW has lead responsibility in the management of PCBs in the energy sector. Lebanon's national electricity company, Electricité du Liban (EDL), handles hundreds of potential PCB-containing equipment including and transformers. EDL falls under the tutelage of MoEW. • MoF also has a significant role in controlling the flow of PCB-containing equipment to Lebanon; this is the direct responsibility of the customs authority which falls under the tutelage of the MoF. • MoA has a lead responsibility in the control of pesticides. It is important to note that POPs pesticides have been banned from being imported, used, or circulated in the Lebanese territories since the year 1998 through Decision 94/1 that was issued by the Minister of Agriculture. • Dioxins and Furans are under the shared responsibility of four main ministries: MoE, MoI, MoIM, and MoPH. A number of controlled and uncontrolled sources are behind the release of these POPs. MoE is mainly concerned with the monitoring of emissions released at the different sources. The promotion of BAT/BEP practices is mainly the duty of the MoI in addition to MoE. 2.2.3. Relevant International Commitments and Obligations Lebanon is involved in a number of international organizations through regional and international agreements and conventions. Table 2.8 provides an overview of Lebanon's membership at international organizations and the responsible local contact. Table 2.8 Membership in International Organizations and Bodies International Organization Body/Activity National Focal Point (Ministry Related National Activities /Agency & Primary Contact Point) Intergovernmental Forum on Chemical MoE None Safety (IFCS) FAO MoA Integrated Pest Management UNIDO MoE Alternatives to Methyl Bromide (Strawberry) ILO ILO Regional Office, Beirut Employment policies that promote workplace safety World Bank Agriculture infrastructure development, solid waste management, health sector rehabilitation OECD IDAL Promote Lebanon as a viable investment destination and foster, facilitate and retain investments in the country. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 26-27 Lebanon has signed a number of conventions and agreements where some have been ratified. Among these conventions, the Government of Lebanon (GoL) signed and ratified the Basel Convention on the Control of Transboundary Movements of Hazardous Waste and their Disposal in 1994 (Law 387/94). As such, any future export of PCB-containing waste to designated destruction facilities abroad must comply with the provisions of the Basel Convention. Table 2.9 presents agreements that are effective. 2.2.4. Key Approaches and Procedures for POPs Chemical and Pesticide Management including Enforcement and Monitoring Requirements 2.2.4.1. Pesticides Chemicals In order to receive a permit of import, production, formulation, use, packaging or marketing of pesticides, the facility should submit documents required by Decree 5039 (26/3/1982) to the Department of Pharmacy at the Ministry of Agriculture which refers the file to the Committee of Pesticides which in its turn reviews the case and gives the final decision. Each facility holding a permit should register any pesticide imported, produced or formulated, and submits a request to the Department of Pharmacy at MoA. The file is assigned a number and checked for the completion of all required documents. When all documents are supplied, the pesticides committee studies the file and decides to whether or not grant its approval. This procedure is shown in detail in Figure 2.4. Table 2.9 Participation in International Agreements International Agreements Primary Responsible Agency Relevant National Implementation Activities Agenda 21 - Commission for Sustainable MoE Previous activities promoting Development application of agenda 21 principles FAO Code of Conduct (voluntary procedure) MoA Yearly statistics on agricultural sector growth Basel Convention MoE Application based on ratification Law 387 Stockholm Convention MoE Inventories on PCDD/PCDF, pesticides, PCBs, National Profile on Chemicals Management, health profile Vienna Convention and Montreal Protocol MoE Adequate implementation and and its amendments compliance to the protocol requirements Barcelona Convention MoE Wastewater treatment plants at the coast; 2 completed, 4 under construction, and 6 on-going POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon In order to import pesticides for any purpose, the importer should hold a permit allowing the company to import pesticides and fertilizers. The companies can only import pesticides that are registered at the Ministry of Agriculture. Once the pesticides reach the Lebanese customs, the importer submits an import request at the MoA. The department of Pharmacy then checks for the pesticide registry, whereby if the pesticide is not registered, the request is denied. If the pesticide is registered, the department checks if the importer has a permit for import thus keeping request in process or otherwise it stops. At Customs, inspectors check if the importer has a permit of import to allow the processing of the importation. Sampling is done by inspectors at the Quarantine and sent to one of Ministry of Agriculture's laboratories to identify the active ingredient and its percentage composition. Laboratory results are then compared with the information submitted by the importer; if the test results show a difference of 10% for pesticides whose active ingredients constitute 10%, or 5% for pesticides with 10-20% active ingredients, or 3% for pesticides with over 20% active ingredients, compared to the submitted information by the importer, the request is stopped (Figure 2.5). Figure 2.4. Registration Procedure of Pesticide that will be Imported, Produced or Formulated POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 28-29 2.2.4.2. Industrial Chemicals Industrial chemicals do not undergo an official procedure at MoE. Industries that deal with chemicals request a permit from the MoI where environmental conditions are part of the conditions set by the MoI. Only chemicals restricted by MoE based on the Basel Convention are given codes at customs for identification and checking. The importer requesting such restricted chemicals asks for clearance from the MoE, which controls the import of these products. Upon product entry, the code is identified and reported to MoE, whereby environmental conditions and specifications are verified by the Service of Prevention of Impacts from Technological and Natural Hazards and approval is subsequently granted for the product entry. The procedures for these chemicals to enter the country are depicted in Figure 2.6. Figure 2.5. Lebanese Customs Procedure for Import of Pesticides Figure 2.6. Procedures for Import of Substances restricted by Basel Convention in Lebanon POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 2.2.4.3. Chemicals for Domestic Use Facilities that deal with the import of pesticides for domestic use submit necessary documents to the Sanitary Engineering Service (SES) at the MoPH in order to receive an import permit. After receiving the permit, the importer can request a clearance for the import of the target chemicals. When the requested products reach customs, the file is transferred to SES. The file is methodically reviewed for compliance with MoPH conditions and specifications. Random sampling occurs under the request of SES. Final approval is granted based on the file review and test results. Figure 2.7 shows the complete procedure in detail. There is no available information on non regulatory mechanisms for managing chemicals. The Ministry of Finance issued in a declaration to inform customs officials of Decision 71/1 (Ministry of Environment, 1997) on banning the entry of PCBs products into the country. The extent to which these procedures have been implemented or enforced remains uncertain. MoE has prepared an Environmental Framework Law as well as a draft Environmental Impact Assessment (EIA) decree, both of which await approval by parliament and the Council of Ministers, respectively. Despite extensive delays in endorsing the EIA decree, MoE has been requiring project investors to conduct and submit EIA studies as part of the permitting application. While EAs cannot help with the already imported materials, it can help prevent the entry of new PCB products in the country. There are no explicit government procedures in place regarding the handling of PCB contaminated equipment. MoE has however employed Basel Convention procedures to assist the American University of Beirut in exporting hazardous waste for destruction abroad (PCB containing materials) - see Box 1. Figure 2.7. Permitting Procedures for the Import of Pesticides for Domestic Use POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 30-31 Lebanon has at least one formal experience in exporting hazardous waste to a destruction facility abroad; a two-tonne shipment of hazardous waste (including chemicals and containers) from the American University of Beirut. The university contracted a UK-based waste management firm in 2002 to pack, export and destroy the waste in the UK. The firm handled the shipment in accordance with the Basel Convention by drafting a waste protocol according to two mandatory phases: 1. Preparatory Phase (about 3 to 4 months) from the time the contract is concluded with the exporting company till that company completes all so called “movement documents.” 2. Duly Motivated Request (a maximum of one year) from the time the movement documents are approved till the time the waste has been shipped and destroyed, and the export country/entity has been informed in writing that the waste has been destroyed. The Duly Motivated Request is prepared by the ministry of environment (or equivalent agency) in the exporting country and addressed to the ministry of environment (or equivalent agency) in the importing country. Box 1. Export and Destruction of Chemical Wastes from Lebanon 2.3. Assessment of the POPs Issue in the Country 2.3.1. Assessment with respect to Annex A, part I chemicals (POPs pesticides): historical, current and projected future production, use, import and export; existing policy and regulatory framework; summary of available monitoring data (environment, food, humans) and health impacts 2.3.1.1. Historical, Current and Projected Future Production, Use, Import and Export Surveyed agrochemical dealers, distributors, or manufacturers denied having, selling, packaging, distributing, or having done those activities in the past for any of the nine POPs pesticides. None of these industries claimed to have any stocks of pesticides. This is most likely true since all stocks would have been already re-packaged and sold on the market years ago. Although contacts were often made through individuals known or friendly to these industries, no useful information was received. Municipalities claimed to be using alternative pesticides to DDT for mosquito abatement or insect spraying. The Ministry of Public Health (MoPH) used to distribute DDT to municipalities, around 15 to 20 years ago (as stated during interviews), for the purpose of mosquito spraying and malaria prevention. However, the quantities were usually sufficient for one to three spraying events, and no records are available detailing for such quantities distributed. The periodic change in municipality authorities and representatives usually hinders the keeping of steady records in these public institutions. Related records are not kept in a consistent manner, properly filed or maintained, such that data on pesticide usage is often incomplete, irregular or simply absent. The most recent logbook records that are kept indicate the usage of alternative pesticides to DDT, which are often synthetic pyrethroids for spray and ambient fogging38 . A survey on agrochemical distributing companies with a complete list of their products revealed that none of the distributed pesticides belonged to the nine POPs compounds, further confirming their probable absence in the Lebanese market. A survey conducted in a recent study at the MoE whereby the amounts of pesticides imported to Lebanon from 1996 to 2000 were recorded, none of the 9 POPs pesticides were identified39 . 38 Kawar, 2005 39 MSC-IPP, 2003 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon The most relevant piece of information obtained was a recent publication by AUB professors40. This article contains information on DDT sampling and analysis results in Lebanon. During this study, a total of 113 soil samples were collected for analysis from three major agricultural regions in the country: Mount Lebanon, the Bekaa Valley, and the Coastal Plain. The majorities of the analyzed samples were free of DDE (a DDT metabolite) or contained negligible amounts of it. Two urban samples with high human activity in the area revealed higher DDT amounts as compared to other POPs pesticides. These two urban sampling locations were situated in the South Caza, particularly in Saida, such that the first was near a gas station, while the second was in a dense residential zone. These relatively higher levels of DDT found in the two locations were explained by: (1) an old storage site of DDT in the vicinity, (2) small-scale haphazard dumping of DDT material in the vicinity, or (3) an accidentally discarded DDT product. There are no suggested ramifications as to these two locations, since the levels of DDT in all samples were within permissible standards for agricultural use. A convincing statement would be that there was no major DDT dumpsite in any of the sampled locations as reflected by the sampling results and data analysis. Another study has reported sediment samples results within the El Kabir Watershed in North Lebanon as part of the Syria Lebanon Akkar Watershed Project41. Sediment samples were analyzed for the presence of, among other substances, three of the POPs pesticides, namely DDT, HCB and Mirex. HCB was detected at low levels, while DDT and DDE were found in measurable amounts in all samples, indicating current use of DDT parent compounds in the watershed despite it being a banned substance. Mirex was not detected in any of the samples. Regarding the Lebanese customs database system, prior to 1999 it was under the responsibility of the Central Administration of Statistics (CAS). The database import/export materials grouping system had changed thrice. The first categorization grouped all geochemical compounds into one category, which made it impossible to differentiate even between fertilizers and pesticides. Upon the second modification to the system, the amount of POPs pesticides still could not be differentiated from the overall amount of imported pesticides. The amounts of POPs pesticides could not be known from the total due to the grouping of several pesticides and pesticide classes under one category of imports. As such, the amount of imported material per each pesticide was not recorded. For instance, even to date, with the most advanced and detailed customs import database, DDT is grouped with two other compounds under one category. As a result, assumptions are inevitable as to the percentage of importations that are actually DDT. From the import/export data of 2000 through 2004, which are categorized into 6,000 different groups, it was obtained that 1 kg of DDT (and possibly 2 other organochlorine compounds) was imported in 2002 by order of the Ministry of Public Health. Since the import of such material is illegal, special permissions are granted for import for research purposes. The MoPH is the only institution that is allowed to request such import by a special order. This one kilogram of DDT was used by the MoPH laboratories for testing and analyses. Upon request, the MoPH refused to submit written evidence of such usage in their laboratories. It must be noted that the imported quantity is insufficient for agricultural use. Information from farmers was hard to obtain since they are often poorly aware of the nature of the chemicals they use for their crops. Many of the farmers are illiterate and unaware of the existence of active ingredients, and tended to remember commercial names of pesticides instead. Commercial names are prone to change especially if packed by local distributors, which makes the task of getting any useful information neither promising nor accurate. 40 Bashour et al., 2004 41 IDRC, 2003 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 32-33 Given the rather homogeneity of the farmers community in Lebanon with respect to their agriculture practices and knowledge42, the number of farmers interviewed provides a fairly representative overview of their possible use (or previous use) of the POPs pesticides. Regarding the coverage of agricultural areas, it should be noted that although the Bekaa plain has the most intensive agricultural activities, those farmers in Bekaa plain own the largest amount of land per farmer, while those in the South have the least farming area per individual. Thus, considering population density in each Mouhafaza43, and the relative population density in percent, the area covered per each category is very well distributed with respect to land coverage per farmer (reflected by population density in each Mouhafaza). No smuggled POPs pesticides were officially detected or declared until the present day. Concerning the possibilities for the presence of stocks, it is highly improbable that they exist. This is due to the fact that any present chemicals would have been either sold within due expiry date, or repackaged and sold after expiry in another brand name. The demand for agrochemicals on the Lebanese market is high and selling products is a very easy task considering the illiteracy of the majority of farmers. The remaining issue of concern is the contamination of land and agricultural soils in the country. Land contamination from extensive usage is highly probable especially in frequently planted agricultural areas. Lebanon's mild climate, versatile landscape, and fertile soils render it suitable for agricultural activities. The vastness of agricultural activities and diversity of planted crops render it difficult to pinpoint exact locations of possible POPs pesticides usage. However, large areas with historically intensive agricultural practices can be identified and will be the target of the action plan for initial sampling. It is highly suspected that the majority of previously imported or currently smuggled POPs pesticides would eventually wind up in the agricultural soils. Any possibly contaminated agricultural soils used at construction sites for planting purposes could be considered as a potential source of these chemicals. Such non point sources could be numerous due to the construction boom after the Lebanese civil war in the past two decades. 2.3.1.2. Existing Policy and Regulatory Framework Table 2.10, Table 2.11, and Table 2.12 present a description of existing legislation and regulations addressing POPs in Lebanon. The mentioned section describes relevant environmental laws, decrees amendments, regarding protection of the environment, transport and movement of hazardous chemicals, ratification of the Stockholm Convention, hazardous chemicals, management of health care waste, and POPs chemicals trade. 42 MSC-IPP, 2003 43 MoE/ECODIT, 2001 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Table 2.10 References to Existing Legal Instruments Regarding Agro-Chemicals Legal Instrument Responsible ministries Chemical use Objective of legislation Relevant or bodies categories covered articles/Provisions Law n°6/68 MoA All fertilizers, Organization of the 2 (Issued in 08-01-1968) pesticides and trade of fertilizers, provender (production, pesticides and provender manufacturing, importing, distribution and use) Decision of the Minister of MoA All provender Interdiction of producing, 1&2 Agriculture n°336 containing arsenic importing, and using (Issued in 16-11-1973) and antimonies (both provender that contain importing and arsenic and antimonies producing) Decree nº5039 MoA Pesticides Organizing the import, 1&2 (Issued in 26-03-1982) trade, packaging, formulation, production and use of pesticides Decision of the Minister of MoA List shown in article 1 Prohibition of importing 1 Agriculture n°65 some pesticides (Issued in 22-06-1983) Decision of the Minister MoA All commercial Organizing the importation 1 of Agriculture n°19/1 agricultural fertilizers operations of agricultural (Issued in 1991) as listed in the decree fertilizers and the n°15659 21-09-1970 verification of the rightness of their composition for their use in the Lebanese agriculture Decision of the Minister of MoA Pesticides registered Necessity of an advance 2 Agriculture n°254/1 in M.O.A (only) authorization for the (Issued in 30-05-1997) importation of agricultural pesticides Decision of the Minister of MoA Pesticides Prevents the import, trade, 3 Agriculture nº92/1 and use of pesticides (Issued in 20-05-1998) without specifications for labeling of agrochemicals bottles and information required to be provided Decision of the Minister of MoA Some pesticides Bans the use, import and 1 Agriculture nº94/1 trade of 109 pesticides (Issued in 20-05-1998) Decision of the Minister of Agriculture nº262/1 (Issued in 2001) Decision of the Minister of MoA All types of pesticide Conditions for importation 1 Agriculture n°90/1 chemicals pesticides of pesticides (Issued on 05-04-2000) Organic, solid and 4 liquid pesticides Decision of the Minister of MoA Some pesticides Ban certification for 1 Agriculture nº262/1 Monocrotophos, methyl (Issued in 26-09-2001) parathion, lindane, fenamiphos Decision of the Minister of MoA Some pesticides Allow certification of 1 Agriculture nº316/1 import of some (Issue on 31-10-2001) pesticides: Fenamiophos POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 34-35 Legal Instrument Responsible ministries Chemical use Objective of legislation Relevant or bodies categories covered articles/Provisions Decree n°456/1 MoA Pesticides Formation of the Current 1, 2 (Issued on 26-01-2004 Committee of Pesticides according to Decree 5039 Decision of the Minister of MoA Pesticides Organizing the import, 1 Agriculture nº59/1 registration, and use of (Issued on 26-02-2005) pesticides in Lebanon. Description of documents and information required from the importer. Table 2.11 References to Existing Legal Instruments regarding Consumer Chemicals Legal Instrument Responsible ministries Chemical use Objective of legislation Relevant or bodies categories covered articles/Provisions Decision of the Minister of MoPH Cyclamic acid Prohibition of importing, 1 Public Health n°148 manufacturing and (Issued in 08-04-1972) exporting of cyclamic acid Saccharin Special visa given for 2 importing, manufacturing, packing and exporting saccharin Law n°11/78 MoPH Insecticides Organization of importing, 1 (Issued in 24-04-1978) selling, filling, packing, preparing, manufacturing and spraying insecticides Decree n°5100 MoPH Insecticides Specification of the technical 1,2,3,4 (Issued in 12-04-1982) and special conditions for the importing, selling, filling, storing, preparation, manufacturing and spraying of domestic insecticides POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Le ga l I ns tr um en t R es po ns ib le m in is tr ie s C he m ic al u se c at eg or ie s co ve re d O bj ec tiv e of le gi sl at io n R el ev an t a rt ic le s/ Pr ov is io ns or b od ie s La w n °6 4/ 88 M oE Li st in a nn ex 1 T he p re se rv at io n of e nv iro nm en t a ga in s t po llu tio n 2 (I ss ue d in 1 2 08 1 98 8) fr om h az ar do us w as te s an d ha za rd ou s m at er ia ls 2 La w n ° 3 87 M oE A nn ex es n °1 ,2 ,3 ,4 a nd 5 A ut ho ri za tio n to th e go ve rn m en t f or th e 3/ 1 (I ss ue d in 0 4 11 1 99 4) ra tif ic at io n of " B as el T re at y" c on ce rn in g th e co nt ro l o f t he m ov em en t o f h az ar do us w as te s ac ro ss th e bo rd er s an d th e di sp os in g of th em D ec is io n of th e M in is te r of M oE Pe tr oc ok e C er tif ic at io ns r eq ui re d by th e im po rt er to b e 1 En vi ro nm en t n °9 /1 su bm itt ed to M O E ah ea d of th e or de r ar ri va l t o (I ss ue d in 1 8 09 1 99 5 an d Le ba no n am en de d th e D ec is io n n° 5/ 1 D ec is io n 17 4/ 1, d at ed 2 /1 1/ 19 98 M oE C ro ci do lit e Pr oh ib iti on a nd a llo w an ce o f i m po rt , t ra ns po rt , tr ad e, a nd u se o f v ar ie tie s of c ro ci do lit e D ec is io n of th e M in is te r of M oE Li st s n° 1, 2, 3, 4, 5, 6, 7, 8, 9, 11 , 1 2, 13 ,1 4 D et er m in at io n of th e sp ec ifi ca tio ns a nd s pe ci fic 1 En vi ro nm en t n °5 2/ 1 co nc en tr at io ns to li m it th e ai r, w at er a nd s oi l (I ss ue d in 2 9 07 1 99 6) po llu tio n D ec is io n 17 4/ 1, d at ed 2 /1 1/ 19 98 M oE A sb es to s R eq ui re m en t o f t he A sb es to s pr od uc t t o a pr ev io us im po rt a llo w an ce fr om M oE D ec is io n of th e M in is te r of M oE Li st n um be r 1 R eg ul at io n of im po rt in g w as te s re pl ac ed 1 En vi ro nm en t n ° 7 1/ 1 (w ith p er m is si on fr om M oE ) de ci si on 9 1/ 1, 2 4 10 1 99 6 an d de ci si on (I ss ue d in 1 9 05 1 99 7) Li st n um be r 2 ( t ot al p ro hi bi tio n of 22 /1 , 1 7 12 1 99 6 4 im po rt at io n) D ec is io n of th e M in is te r of M oE In du st ri al li qu id w as te s (w at er th at En vi ro nm en ta l c on di tio ns fo r th e au th or iz at io ns 2/ 1 En vi ro nm en t n °1 /2 2 m ig ht c on ta in c hr om e, c hl or id e, of c re at in g/ ex pl oi ta tio n ta nn in g fa ct or ie s (I ss ue d in 0 5 09 2 00 0) ni tr og en , s ul fid e, p es tic id es , e tc .) So lid w as te s (le at he r re si du es , 2/ 2 gr ea se s, e tc .) A ir p ol lu te rs 2/ 3 D ec is io n of th e M in is te r of M oE In du st ri al li qu id w as te s En vi ro nm en ta l c on di tio ns fo r th e au th or iz at io ns 2/ 2 En vi ro nm en t n °5 /1 So lid w as te s of c re at in g/ ex pl oi ta tio n of c on se rv at io n fir m s of 2/ 3 (I ss ue d in 3 0 11 2 00 0) A ir p ol lu te rs fr ui ts a nd v eg et ab le s 2/ 4 D ec is io n of th e M in is te r of M oE Li qu id a nd s ol id in du st ri al w as te s En vi ro nm en ta l c on di tio ns fo r th e au th or iz at io ns 2 En vi ro nm en t n °4 /1 of c re at in g/ ex pl oi ta tio n sl au gh te rh ou se s (I ss ue d in 1 2 01 2 00 1) T ab le 2 .1 2 R ef er en ce s to E xi st in g L eg al I ns tr um en ts A dd re ss in g In du st ri al C he m ic al s POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 36-37 Le ga l I ns tr um en t R es po ns ib le m in is tr ie s C he m ic al u se c at eg or ie s co ve re d O bj ec tiv e of le gi sl at io n R el ev an t a rt ic le s/ Pr ov is io ns or b od ie s D ec is io n of th e M in is te r of M oE A ir p ol lu te rs , l iq ui d w as te s ge ne ra te d St an da rd s & sp ec ifi ca tio n co nc er ni ng a ir po llu te rs , 2, a nn ex 1 En vi ro nm en t n ° 8 /1 by c la ss ifi ed fi rm s, w at er tr ea tm en t w as te s g en er at ed fr om c la ss ed fi rm s a nd e ve ry da y & (I ss ue d in 3 0 01 2 00 1) st at io n an d ho sp ita ls in a dd iti on to w at er tr ea tm en t s ta tio n 2, a nn ex 2 th os e ge ne ra te d by s ec to rs , i nd us tr ie s an d ot he r so ur ce s of p ol lu tio n D ec is io n of th e M in is te r of M oE In du st ria l l iq ui d w as te (b is (II e th yl he xy l) En vi ro nm en ta l c on di tio ns fo r t he a ut ho riz at io ns o f 2/ 1 En vi ro nm en t n °6 1/ 1 ph th al at e) , D i n bu ty l,b is cr ea tin g/ ex pl oi ta tio n th e fa ct or ie s f or p la st ic (I ss ue d in 1 0 09 2 00 1) (I I di et hy lh ex yl ), di m e th yl p ht ha la te So lid w as te 2/ 2 A ir p ol lu te rs 2/ 3 D ec is io n of th e M in is te r of M oE In du st ri al li qu id w as te (p H ) En vi ro nm en ta l c on di tio ns fo r th e au th or iz at io ns 2/ 1 En vi ro nm en t n °1 5/ 1 So lid w as te s ( re sid ue s o f m el te d gl as s) . of c re at in g/ ex pl oi ta tio n fo r gl as s fa ct or ie s 2/ 2 (I ss ue d in 0 4 03 2 00 2) A ir p ol lu te rs 2/ 3 D ec re e n° 80 18 M oI D et er m in at io n of th e pr oc ed ur es 3 (I ss ue d in 1 2 06 2 00 2) an d th e co nd iti on s fo r th e au th or iz at io ns o f c re at io n in du st ri al fir m s La w n °4 44 M oE Li st o f h az ar do us c he m ic al s in B ul le t Pr ot ec tio n of th e en vi ro nm en t. C ha pt er 6 , a rt ic le 4 4 (I ss ue d in 2 9 12 2 00 2) 1 of a rt ic le 4 4, C ha pt er 6 D ec re e n° 80 06 M oE W as te s si m ila r to m un ic ip al w as te s Sp ec ifi ca tio n of th e ty pe s of th e he al th in st itu tio n 4/ 1 (I ss ue d in 1 1 06 2 00 2 an d (a nn ex 1 ) w as te s an d th e w ay s of th ei r dr ai ni ng 4/ 2 am en de d by D ec re e n0 1 33 89 H az ar do us & in fe ct io us w as te (a nn ex 1 ) O rg an iz at io n of th e m an ag em en t o f t he h ea lth is su ed in 3 0 09 2 00 4) H az ar do us a nd n on i nf ec tio us in st itu tio n ai m in g th e pr ot ec tio n of th e 4/ 2 w as te s (a nn ex 2 ) en vi ro nm en t a nd th e ge ne ra l i nt er es t Sp ec ia l w as te s (a nn ex 3 ) 4/ 3 R ad io ac tiv e w as te s( a nn ex 3 ) 4/ 4 D ec re e 11 80 2 M oL H ea lth a nd S af et y H ea lth a nd s af et y m ea su re s at th e in du st ri al C ha pt er 1: P re ve nt io n an d (is su e d o n 31 0 1 20 04 ) oc cu pa tio n sa fe ty C ha pt er 2 : H ea lth C ha pt er 3 : O cc up at io na l sa f e ty a t c he m ic al u se C ha pt er 4 : P re ve nt io n fr om oc cu pa tio na l h az ar ds fr om be nz en e POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon While there are several legal texts that cover the management of POPs chemicals in Lebanon, enforcement of available legal instruments remains very weak. In the case of pesticides, monitoring is performed at the customs according to specifications imposed by MoA on imported pesticides. The pesticides committee at MoA informs the customs about banned pesticides, which are subsequently rejected to enter the country. The Ministry of Agriculture has a specialized inspection team and laboratory for monitoring, analysis and control of products entering the country. Testing is limited to active ingredient. Concerning the monitoring of implementation, inspection on-site is done by the staff of the responsible ministry. Theoretically, inspection units work should monitor the implementation of regulations at all facilities, but it is limited due to lack of personnel. MoE Decision 71/1 (issued on 19/5/1997) bans the import of PCB products44. The Decision however is not PCB specific (about 100 other chemical groups and waste products are also listed) and lack enforcement measures. Lebanon has no laws banning the production, use and/or disposal of PCB containing equipment and byproducts. Emissions of Dioxins and Furans are not regulated for their concentration. The promotion of BAT/BEP is included under some legislation. Enforcement is a main component that is lacking due to the lack of personnel, equipments and funding. 2.3.1.3. Environmental Contamination and Monitoring Data Levels in air, water, sediment, soil, and biotic sinks (part of the food chain) vary over several orders of magnitude, often depending on the proximity to the source of release into the environment45. Because much of the drinking water supplies in Lebanon originates from groundwater reserves, it is not considered at high risk of POPs pollution, because the hydrophobic properties of POPs (e.g. Aldrin and Dieldrin) make them resistant to leaching into ground water46. Low levels of HCB were detected in a study conducted by IDRC in 2003; whereas, measurable amounts of DDT and its metabolite (DDE) were detected in all samples. On the other hand, Mirex was not detected in any of the samples. Organochlorine pesticides, including heptachlor and epoxide, were tested in fish species found off the coast of Lebanon47. This study tested for biomagnification of organochlorines in fish species belonging to several trophic levels; however the hypothesis was not proved, and the detected levels did not constitute a hazard to human health from fish consumption. The researchers further discussed that the limited evidence they found could mean that the pesticides have not been in the Mediterranean for a very long time, thus the concentrations in fish are due to direct absorption into the fish body from water rather than from the consumption of other pesticide -containing fish. Another likely explanation reported by the researchers is that the experiment had been too small to give accurate concentrations in the species sampled. A Kuwaiti study published in 2001 analyzed for organochlorinated pesticides in the Kuwaiti diet which includes food products imported from Lebanon48. This study concluded that the residue levels encountered were relatively low and none of these residues exceeded the FAO/WHO (1993) maximum residue limit (MRL). 44 Annex 2, under the generic heading “halogenated wastes,” (ID# 2903.69.10) 45 EPA, 1996 46 UNEP, 1998 47 Riss and Gulbrandson, 1970 48 Saeed et al., 2001 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 38-39 At the national level, breast cancer was reported as the most common cancer among women in Lebanon accounting for almost one third of all cancers in women, whereas, in the mid-sixties, it represented 18%, of all cancers in women49. In addition, the cancer registry results for the year 2002 reported breast cancer as the top ranking among cancer cases in females; however, these numbers should be handled with extreme care and caution as there are no prevalence or incidence rates based on which scientific analysis can be made. These findings might indicate an increase in incidence, similar to the experience of countries with reliable data, or an increase in diagnosis and reporting. In-depth investigation and epidemiological studies are needed to examine the association between these high rates and exposure to POPs. As for pesticides, low level exposure was reported to be correlated with increased risk of cancer. One study reported that the growing incidence of cancer cases among children in Lebanon (average cancer cases 786 cases/year) can be attributed to contaminated breast milk50. 2.3.2. Assessment with respect to Annex A, part II chemicals (PCBs) (PCB) 2.3.2.1. Production of PCB Lebanon has no PCB production facility. The country hosts two companies that manufacture and/or supply distribution transformers: Matelec (Lebanese company) and Elprom (Bulgarian company). Both companies have been using PCB-free oil for many years. For example, Matelec uses known PCB-free oil called Nynas. 2.3.2.2. National PCB Preliminary Inventory Estimating PCBs quantities in Lebanon is difficult; PCB containing equipment is seldom labeled, and archives and statistics are not readily available (or too recent). Under contract with MoE, a local consulting firm produced in 1995 the first partial assessment of PCBs in Lebanon51. This assessment investigated PCB quantities in out-of-service distribution transformers stockpiled in a warehouse and repair shop located near Beirut, owned and managed by EDL52. The same firm then conducted a follow up sampling and analysis campaign in 2000 from the same warehouse during which they collected 50 samples as follows: 38 samples from out-of service transformers, nine samples from storage barrels, two samples from a contaminated well and one soil sample. Key findings from both assessments are summarized below53: • Out of the 34 samples collected in 1995, eight contained PCB concentrations greater than 50 ppm. • Out of the 38 samples collected in 2000, six contained PCB concentrations greater than 50 ppm and two contained concentrations between 40 and 50 ppm. • The firm could not establish a statistical correlation between manufacturers and PCB concentrations. • All nine samples collected from the oil barrels contained PCB concentrations less than 50 ppm (values ranged from <1 to 21 ppm); the two well samples contained 222 and 229 ppm of PCB, respectively; and the soil sample contained 8 ppm PCB. In 2004, MoE contracted a Lebanese firm to prepare a preliminary national inventory of PCBs in the country54. The inventory recognized the overwhelming importance of the energy sector as a potential source of PCBs found in dielectric fluids/oil and PCB-contaminated transformers (i.e., closed applications). Such transformers are located in (i) power plants (thermal and hydroelectric), (ii) substations and, (iii) distribution stations, as illustrated in Figure 2.8. The inventory categorized dielectric fluid/oil into three groups; PCB containing oil, non-PCB oil that has been contaminated and PCB-free oil. 49 Nuwayhid and Sibai, 2002 50 El-Saghir et al., 1998 51 COGIC Consultants, with technical assistance from TREDI, a PCB destruction facility in Switzerland 52 The repair shop is located in Bauchrieh, in the northern suburbs of Beirut. 53 Rapport d'Evaluation des PCB Site EDL de Baouchrieh, COGIC Consultants, 2000 54 ECODIT Liban, www.ecodit.com POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon • The inventory could not investigate PCBs in other types of closed applications such as those found in the tourism sector (in hotels and large resorts), in domestic facilities and large public complexes. Key findings from the inventory are summarized below: With the exception of two plants in Zouk and Jieh, Lebanon's power plants are relatively new (post 1995). Samples from each of Lebanon's seven power plants indicate that only the Zouk and Jieh power plants have significant quantities of PCB oil equivalent to about 42 tonnes. PCB oil or PCB-contaminated oil (a direct result of oil filtration and/or oil refilling) may nevertheless be present in other power plants and would require more extensive testing. • Lebanon's substations appear to use (and have been using for many years) by and large PCB free oil. The corresponding test results55 corroborate this finding (27 samples); the concentration of PCB oil in new as well as old transmission transformers was not detectable. It is however difficult to categorically exclude the presence of PCB in transmission transformers because there are many variables (e.g., different manufacturing companies, different ratings and years of manufacturing). • EDL owns and operates more than 16,000 distribution transformers distributed across the territory. Many of these transformers may contain PCB oil. Naturally, old and/or damaged transformers are gradually being phased-out and replaced with new transformers that contain PCB-free oil. However, hundreds of PCB transformers are still in use and will remain so for many years to come. • EDL uses only dry-type capacitors, i.e., they do not contain oil and therefore do not represent a potential repository of PCB material. • Some level of cross contamination between transformers may be occurring during routine filtration of dielectric fluids. 2.3.2.3. Import/Export Lebanon has a poor track record in data management and national statistics. In recent years, MoF developed and launched a public database on all imports to the country (www.customs.gov.lb). While useful, the database brings little value to the assessment of PCBs because (1) the oldest records are from the year 2000 and, (2) the data are aggregated under general subheadings. The website uses the Harmonized Commodity Description and Coding Systems (or Harmonized System, HS) which came into effect in 50 countries on January 1, 198956. The Harmonization Code System (HS-Code) is a system of progressively more specific identifiers for a commodity. PCB oil falls under "oil from petrol and bitumen mineral” - the general code is 2710. HS271091 contains PCB oil as well as other oil products. According to the database, total import of HS271091 between 2000 and 2004 was 13 tonnes (net weight). 55 17 samples were analyzed at the environmental core lab at the American University of Beirut 56 http: //www.tradeinfo.net/itc.html Figure 2.8. Overview of the Energy Sector and PCB-oil POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 40-41 2.3.2.4. Treatment of PCB- containing waste There are no incineration plants for municipal waste or landfills for chemical waste in Lebanon. PCB-contaminated equipment are usually handled and disposed off haphazardly, or sold to third parties as scrap, without prior knowledge or verification of the potential presence of PCBs. EDL sends damaged distribution transformers to its designated warehouse and repair shop in Bauchrieh. In the past, EDL used to store waste oil (low-quality dielectric fluids) in barrels to be sold as fuel, or discharged the oil in an open well. Open dumping has reportedly ceased and the oil is entirely stored in barrels for resale. The inventory identified six alternative disposal methods: 1. Incineration 2. Chemical Dechlorination 3. Transformer retrofilling 4. Landfilling 5. Plasma Arc Technology 6. Storage Based on a preliminary comparative analysis of these disposal methods, the most feasible alternatives for the treatment and/or disposal of PCB waste are (a) incineration in cement kilns in Lebanon and (b) export to destruction facilities. The results of a comparative analysis of the two options indicated that export was more feasible than in-country incineration. Evaluation criteria included proximity of the facility to the source, the type of waste, destruction efficiency, ease of management and administrative requirements, health and safety, public acceptability and costs. Among several destruction facilities in the Gulf region and Europe, a follow-up analysis indicated that export to Europe (e.g., France, UK) was the best and most reliable option overall. 2.3.2.5. Available monitoring and health impact data So far, there is no official program to monitor PCB effects on public health and the environment. Leading research institutions may be sponsoring small-scale and point studies on PCBs but such research has so far not contributed to formal PCB discussions at the national level. Only one study has so far examined the incidence of several disease symptoms (e.g., ocular, dermal, cardio and cancer) among PCB-exposed personnel, and reported those findings (see section 2.3.11). 2.3.3. Assessment with Respect to Annex B Chemicals (DDT) As previously mentioned (Section 2.3.1.1), research studies conducted by the AUB and IDRC revealed that DDT was used in the past in two areas in the South. This was explained by: (1) the possible presence of an old storage site of DDT in the area, (2) the presence of a small-scale haphazard dumping of DDT material in the vicinity, or (3) the accidental discard of the DDT product. Yet, ramification strategies were not set since the levels of DDT in all samples were within permissible standards for agricultural use57 . A study conducted by IDRC in year 2003 analyzed for DDT and its metabolite DDE in the sediments of El-Kabir watershed. Measurable amounts of DDT and its metabolite (DDE) were detected in all samples. The detected DDE and DDT levels are presented in Table 2.13. 57 Bashour et al, 2004 58 IDRC (2003) Table 2.13. DDE and DDT Sediment Levels in El Kabir Watershed (in ppb)58 SAMPLING LOCATION PP'-DDE PP'-DDT L1 0.08 2.70 L6B ND 0.17 L8 9.96 12.17 L13 2.36 4.33 S3 0.34 0.74 S12 0.51 2.95 Mean 2.21 3.84 Standard Deviation 3.90 4.35 ND not determined POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon In Lebanon, research conducted at the National Council for Marine Sciences59 showed that levels of PCB and organochlorine pesticides (DDT, DDD, DDE) in fish were not negligible (Table 2.14). The study also stated that the trend between 1984 and 1988 indicates that fish contamination is not likely to decrease. Organochlorine pesticides, including DDE, DDD, and DDT, were tested in fish species found off the coast of Lebanon (Section 2.3.1.3)60. A Kuwaiti study published in 2001 analyzed for organochlorinated pesticides in the Kuwaiti diet which includes food products imported from Lebanon61. Concerning pesticides in general, low level exposure was reported to be correlated with increased risk of cancer62(Section 2.3.1.3). 2.3.4. Assessment of Releases from Unintentional Production of Annex C Chemicals (PCDD/PCDF, HCB and PCBs) The United Nations Environment Program (UNEP) Toolkit 2003 defined ten common sources of emissions of Dioxins and Furans. These sources are: a) waste incineration, b) ferrous and non-ferrous production, c) power generation, d) production of mineral products, e) transport, f ) uncontrolled combustion, g) production and use of chemicals and consumer goods, h) disposal and landfilling of wastes, and i) miscellaneous sources. The preliminary inventory for Dioxins and Furans, developed in the year 2005, indicated that an estimated total of PCDD/PCDF of 165.8 g TEQ/a were released annually from these sources. Detailed information about the emissions by category is presented in Table 2.15. Uncontrolled combustion was found to be the major contributor to such emissions with a 124.74 g TEQ/a (this is equivalent to 75.24% of all emissions). The inventory showed an increased level of emissions after the utilization of the edited UNEP 2003 Toolkit, when compared to the previous national inventory for the year 1999, where the estimated total annual amount of Dioxins and Furans releases was 77.465 g TEQ/a. The 1999 inventory also indicated the highest emissions by uncontrolled combustion, which was estimated at 54.035 g TEQ/a (equivalent to 69.754% of the total emissions). However, caution should be exerted in explaining this rise as it might indicate higher emission levels (thus more uncontrolled combustion), or it could just be a translation of improved accuracy in data collection. Note that since numerous assumptions are used in the calculations, it is difficult to provide the exact reason for the increase in emission levels. 59 Kouyoumjian and Safa, 1993 60 Riss and Gulbrandson, 1970 61 Saeed et al., 2001 62 El-Saghir et al., 1998 Table 2.14. PCB and Pesticide Presence in Fish Species (mg/kg wet weight) NA not available Local Fish Species Pesticide Year 1984-85 1986 1987 1988 DDT 0.014 0.010 0.010 0.014 DDD 0.005 0.007 0.012 0.0125 DDE 0.046 0.040 0.057 0.1000 DDT 0.007 0.005 0.065 0.0090 DDE 0.012 0.027 0.015 NA POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 42-43 It is important to note that high concentration levels are due to assumptions done at some categories. In the case of medical waste incineration, only 85 hospitals were surveyed by the Syndicate of Hospitals from 160 hospitals. An extrapolation was done for the left number of hospitals resulting in an estimated total emission of 32.09 gTEQ/a of PCDD/PCDF in the air. Another major rise in the estimated releases of PCDD/PCDF is due to the open burning of solid waste. It was estimated that 10% of generated waste is open burned. The estimation resulted in a release of 39.24 gTEQ/a in the air and 78.48 gTEQ/a. Several industries have the potential for relatively high formation and unintentional release of PCBs as a result of thermal processes involving organic matter and chlorine64. Some of these sources may be present in Lebanon: 1. There are currently two or three licensed medical waste incinerators in Lebanon, but there are many more unlicensed and poorly monitored. Soil samples taken from one incinerator site revealed high concentrations of Dioxins and Furans 65. 2. Cement kilns: There are five cement factories in Lebanon. MoE began to monitor stack emissions from these factories intermittently. There is no public information on the source and origin of the type of fuel burnt at the cement kilns before that. 3. Production of pulp using elemental chlorine for bleaching: There are three paper factories in Lebanon (Sipco, Sicomo and Solicar) that recycle paper. It appears that they do not use bleaching but coloring to enhance paper whiteness. They use very small quantities of pulp to strengthen the paper, which is producing using recycled paper. There is no pulp production in Lebanon. 4. Thermal process in the metallurgical industry PCBs may also be unintentionally formed and released from the following source categories: 1. Open burning of waste from landfill sites, 2. Fossil fuel-fired utility and industrial boilers, Table 2.15. PCDD/PCDF Annual Emission Levels per Category 63 Category PCDD/PCDF Annual Release (g TEQ/a) Air Water Land Product Residue Total 1. Waste Incineration 32.09 - - - 0.161 32.251 2. Ferrous and Non-ferrous 0.488 - - - 0.4056 0.8936 Production 3. Power Generation 0.8921 - - - 0.037 0.9291 4. Production of Mineral Products 0.41 - - - 1.107 1.517 5. Transport 0.1493 - - - - 0.1493 6. Uncontrolled Combustion 44.98 - 0.0173 - 79.748 124.74 7. Production and use of - - - 3.052 - 3.052 chemicals and consumer goods 8. Miscellaneous 0.000517 - - - - 0.000517 9.Disposal/Landfill - 1.203 - - 1.079 2.282 10. Hot Spots - - - - - Total 79 1.203 0.0173 3.052 82.53 165.8 63 Dioxins-Furans Inventory, MoE/ELARD, 2005 64 Stockholm Convention, Annex C 65 Greenpeace Soil Sampling, Hotel Dieu Hospital, 2001 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3. Motor vehicles (burning leaded gasoline): Lebanon introduced unleaded gasoline in 1993. The Government of Lebanon phased out leaded gasoline completely in 2001. This has significantly reduced (though not eliminated) vehicle lead emissions as well as the unintentional release of PCBs. 4. Textile and leather dyeing: The tanning sector in Lebanon has been facing mounting problems including fierce competition from neighboring countries, and effluent discharge standards. In recent years, several tanning industries have shut down or relocated (less than 20 tanning units remain). The tanneries may be using chlorine-containing chemicals (chloranil) throughout the dyeing process. 2.3.5. Information on the State of Knowledge on Stockpiles, Contaminated Sites and Wastes, Identification, Likely Numbers, Relevant Regulations, Guidance, Remediation Measures and Data on Releases from Sites 2.3.5.1. Dioxins and Furans The disposal of products or residues containing PCDD/PCDF poses a threat of repeated release into the environment. A landfill or open dump can become a reservoir for the release of these compounds. Such is the concern of these potential contaminated sites. It is important to note that the dump or landfill in this case must be contaminated with PCDD/PCDF containing wastes described in categories 1 through 9 of the UNEP Toolkit. The three main sanitary landfills in Lebanon: Tripoli, Naameh, and Zahleh are potential contaminated waste sites. These landfills receive all kinds of waste from batteries, health care waste, bleached products and other. No specific data on PCDD/PCDF releases were found thus as an estimation of PCDD/PCDF releases resulted in 0.00005 gTEQ/a in the leachate and 0.4046 gTEQ/a in the flared gas. Open dumping and burning of solid waste spread out in a fast and random way within the Lebanese territory in the absence of legal enforcement. In addition, accidents which often result from accidental fires of PCB transformers, storage rooms, and houses rich in plastics, carpets, treated wood or brominated flame retardants should be considered for PCDD/PCDF release. The Israeli bombarded electric distribution stations at Jamhour and Bsalim which contained PCB containing equipment (transformers and capacitors, also refer to the previous 1999 Inventory) and that has not been de contaminated, are still a probable site for PCDD/PCDF. In the context of a study on dioxin assessment in soils, sampling and analysis of 6 potential sites was done in Lebanon in 2001. Sampling was done at Jamhour and Bsalim distribution stations, Amrousieh old site of a municipal waste incinerator, Quarantina a domestic waste dump and two cement kilns' surroundings in Chekka and Feih-Koura. The results of the analysis are presented in Table 2.16. Table 2.16. Results of Dioxin Soil Sampling and Analysis in Two Power Stations: Jamhour and Bsalim (Kaskas and Kodeih, MoE, 2001) Sampling sites Detected value of Toxic Equivalent Maximum value of Toxic Equivalent Concentration (I-TEQ) pg NATO-TEQ/g Concentration (I-TEQ) pg NATO-TEQ/g Amrousieh 0.6 < 0.9 Jamhour 0.6 < 0.9 Quarantina 0.9 < 1.1 Bsalim 0.1 < 0.4 Chekka 1.7 < 2.2 Feih-Koura 0.1 < 0.5 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 44-45 According to the sampling done, one can notice that tested concentration levels are lower than the maximum value of toxic equivalent concentration. Regarding relevant fire accidents, according to the Lebanese Civil Defense firefighting forces, no large scale incidents where PCB containing equipment were burned were known to occur. On average, 20 to 70 large house/apartment fires are encountered per year, where wood and more particularly plastics and carpets are common household elements. However, it should be noted that the occurrence of these events is sporadic and does not result in the accumulation of PCDD/PCDF in a certain area. Thus, it can be concluded that household fires during 2004 did not constitute a contributing factor to the inventory emissions and do not qualify as PCDD/PCDF hotspots. 2.3.5.2. PCBs Out of 10 oil samples collected from Lebanon's seven thermal power plants, only one sample contained PCB - a staggering 500,000 ppm66. This finding subsequently revealed the presence of up to 5 tonnes of PCB oil stored in 10 out-of service transformers located in the Zouk power plant and about 37 tonnes stored in in-service transformers in the Jieh power plant (see Table 2.17). The commercial oil names were Askarel, Sibanol and Pyralene. Potentially Contaminated Hotspots The inventory identified seven potential PCB hotspots in Lebanon. These sites were considered potential hotspots either because they sustained aerial bombing (e.g., Israeli air raids) or because significant leakages are known to have occurred and/or still occur. These hotspots are (dates of shelling are indicated in parenthesis): Power plants: o Deir Aamar and (2000) o Baalbeck (2000) Substations: o Bsalim (1993, 1996,1999 and 2000), o Jamhour (1993, 1996, 1999 and 2000), o Deir Nbouh (2000), o Hazmieh (1975 - 1990) and o Bauchrieh The Jamhour and Bsalim substations sustained the highest number of raids. In Jamhour, several transformers were hit during the civil war (1975 1990); information on the extent of damage sustained during that period is lacking. The substation was then damaged again during three successive air raids, in 1996, 1999 and 2000. Following the 1999 raid, several transformers were either repaired or replaced (nine new ABB, 57-40MVA, transformers). The 2000 raid resulted in the complete destruction of all 17 transformers, containing on average 20 tonnes of oil each (340 tonnes in total). The extent of oil percolation into soil and groundwater is uncertain and would require targeted sampling and analysis. Naturally, if these transformers contained PCB-free oil before the raids, then the resulting contamination would not include PCBs. The EDL repair shop located in Bauchrieh (one of Beirut's northern and highly urbanized suburbs) is considered the most severe hotspot in Lebanon. Table 2.17. Total Quantity of PCB-Oil Present at Zouk and Jieh Power Plants Source: PCB Inventory, 2005 PCB-Oil Type Zouk (kg)* Jieh (kg)** Askarel 4,740 Sibanol - 5,840 Pyralene - 31,275 Subtotal 4,740 37,115 66 Name of manufacturing company, ACEC POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon An estimated 1,600 transformers, of different marks, epochs and capacities are scattered around the site. Previously MoE and EDL commissioned the investigation of PCB by collecting a total of 84 samples between 1995 and 2000, 38 from out-of-service transformers, nine from storage barrels and two from the contaminated well and one soil sample67. A total of 14 samples contained high concentrations of PCB and the samples collected from the well contained PCB. 2.3.5.3. Pesticides Intensive agricultural practices reflect on the frequency of chemicals usage, and therefore the most agriculturally active areas will be identified for future reference purposes. POPs pesticides were mostly used in Lebanon on fruit trees, especially commercial fruit orchards, citrus trees, and on greenhouses vegetables. They were not used on olive trees which are the most commonly cultivated tree species. A hypothetical zone, which is strongly suggested for sampling, is represented by Lake Qaraoun, which lies in the Bekaa plain. The sediments of this lake can contain accumulated evidence of prolonged usage of the target chemicals. Sampling from the bottom of the lake is suggested. Despite the concentrations of plantations and agricultural practices in certain areas of Lebanon, the domestic usage of the POPs pesticides on insects has implications on their more random distribution. This is also supported by the common presence of fertile soils in many regions and scattered agricultural practices in Lebanon. 2.3.6. Summary of future production, use and releases of POPs - requirements for Exemptions There is no production of DDT in Lebanon, and no likely future production, no known use or future use, and no clearly detected releases of this pesticide. Lebanon did not file for any exemptions under the Stockholm Convention for DDT, and is not likely to do so in the future. The national inventories highlighted some hotspots for POPs releases and potential exposure and these are summarized in Table 2.18 below. Table 2.18. Possible Hotspots for POPs Releases and Potential Exposure PCB Category Hotspots Dioxins and Furans • Areas around incinerators (hospitals equipped with incineration facilities) • Areas around uncontrolled combustion (open dumps) PCBs There are at least seven sites in Lebanon potentially contaminated with PCB oil: • Three power plants (Deir Aamar, Deir Nbouh and Baalbeck) • Three substations (Bsalim, Jamhour and Hazmeih) • EDL repair shop in Bauchrieh: The most critical PCB hotspot; about 1600 transformers are stored on site destined for repair or disposal. • The disposal of burnt oil continues to pose grave environmental concerns. Pesticides Areas of commercial fruit orchards, citrus trees, and on greenhouses vegetables: • Coastal plain • Bekaa plain 67 COGIC Consultants, with technical assistance from TREDI, a PCB destruction facility in Switzerland POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 46-47 2.3.7. Existing programmes for monitoring releases and environmental and human health impacts, including findings In order to be able to manage chemicals and take the proper decision in various situations, it is necessary to have accurate and complete data basis on chemical substances, their properties, impact on humans and environment, the exact quantities of chemicals produced, used, imported or exported and the types and quantities of the accumulated waste in the country. It is expected that each ministry has a database that covers such information on chemicals where some of them are required under existing legal instruments. Table 2.19 shows the availability of data for different types of chemicals. Information on chemicals is available in the form of reports, literature (national and international databases). The information however is still considered very limited and disorganized; information sources being scattered in different institutions. A networking among the information sources would be very beneficial to chemical management and would go a long way in facilitating information dissemination. There is no single data reporting system in Lebanon. The main institution which accumulates and provides information on all type of activities, including production and trade data is the Central Administration of Statistics. However, data is not provided to all public and is not detailed, i.e. do not specify which chemicals and hence in real terms the data is far from usable in assessing chemical management. However, for detailed import and export of chemicals, the Ministry of Economy and Trade Customs division provides accurate data, which is available to all public via their internet site. Table 2.19. Quality and Quantity of Available Information Data Needed for/to Pesticides (agricultural Industrial Chemicals Consumer Chemical Chemical Waste public health and products consumer use) Priority Setting Yes Yes No No Assess Chemicals impact Yes Yes No Limited under local conditions Risk Assessment No No No No (Environment/Health) Classification/Labeling Yes No No No Registration Yes Yes Yes No Licensing/Permitting Yes Yes Yes No Risk Reduction Decision No No No No Accidental preparedness/Response No Limited No No Poisoning No No No No Emission Inventories Limited Limited Limited Limited Inspection and Audit Limited Limited Limited Limited (Environment/Health) Information to workers Yes Limited Limited No Information to the Public Limited Limited Limited Limited POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Information on the use of pesticides and fertilizers is the responsibility of the Ministry of Agriculture. Data on hazardous waste, on environment monitoring, on pollutant emission should be collected by the Ministry of Environment. Note that different types of data are located in different organization and agencies at the national level that can be used for chemical management as shown in Table 2.20. This data is stored in different formats. It is unfortunate that the scope of data collected on a nationwide basis is not adequate (it is accurate and detailed only in respect to chemical import/export broken down according to product - raw material, complete with value and mass figures). Different organizations employ their own different formats and criteria for undertaking data collection. For example, the Ministry of Agriculture, as the responsible body for the registration of pesticides in the country, has developed its own registration criteria for pesticides that are being used at the national level. The Customs registers import/export of all chemicals. In general, the procedures for the collection and dissemination of chemical data in the country depend mainly on the internal policies or purposes of the different organizations and agencies. The Ministry of Environment has data on chemical waste that are imported. Unfortunately these information need to be entered within a database. Reports on emissions productions are part of obligations of facilities that receive their permits from the Ministry. These information need to be collected and disseminated. The Ministry of Public Health has the capacity for health surveillance for chemical diseases. However, health assessment analysis related to chemicals does not exist at the national level. Data on issues such as chemical accidents, levels of production, imports etc. are not available. However, The Ministry of Interior and Municipalities has the responsibility of dealing with any incident that may put the general public in danger, and therefore might have information dealing with chemical incidents. However, the ministry does not have a special data repository for chemical accidents. Table 2.20. Location of National Data Type of Data Location(s) Data Source Who has Access Format Production Statistics Ministry of Industry UNIDO Open Computerized Ministry of Agriculture www.industry.gov.lb database, files of FAO documents, (www.agriculture.gov.lb) Internet Import Statistics Customs Customs Open Computerized www.customs.gov.lb database, Internet Export Statistics Customs Customs Open Computerized database, Internet Chemical Use Statistics ASPLANTE MoA Open Upon request Industrial Accident Report None None None None Occupational Health Data None None None None (Agricultural) Occupational Health Data None None None None (Industrial) Poisoning Statistics None None None None Pollutant Release and Ministry of Environment ECODIT/MoE 2001 Open CD-ROM, hazardous waste data www.moe.gov.lb Internet METAP 2002, Publications ERM 2002 Register of Pesticides MoA Customs Upon request Upon request Register of Toxic Chemicals None None None None Inventory of Existing Chemicals MoA Customs Upon request Upon request Register of Producers Ministry of Agriculture MoA Open Upon request POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 48-49 There is no national exchange system between ministries and institutions. An official request of information is sent from the Director General at the requesting ministry to the Director General at the ministry expected to have the information. Information request is mainly addressed to the Director General of the concerned ministry. Specific information from international organizations to concerned parties is supplied through international projects, and agreements. Relevant information is mainly sent by mail to concerned parties. International information can be directly accessed through internet communication. 2.3.8. Current Level of Information, Awareness and Education among Existing Target Groups In terms of education, Lebanon has a large number of universities relative to its size. Only one university (AUB) has a department on risk management and chemical safety. Nevertheless, a number of universities provide programs in the environmental sector (water, air, science, health, biodiversity, technology, chemistry) and the agricultural sector. In addition, some environmental courses are offered for non environmental majors. At the level of schools, topics on POPs chemicals are not integrated within the offered disciplines of the Lebanese curriculum. POPs chemicals are known at the level of experts in scientific institutions, laboratories, organizations and companies. Public awareness on POPs does not still have its own national campaign in Lebanon. A campaign targeting different groups is needed to raise the level of knowledge especially at groups that are directly related to POPs; farmers, customs, industries, electric stations, and municipalities. Media is an important component that can be exploited for the education and awareness on POPs related issues. A number of environmental NGOs undergo awareness campaigns. The focus on POPs is limited within activities undertaken by these NGOs. Some NGOs aim at organic farming and at farmers' awareness on the best management techniques for agriculture and pest management. Awareness regarding Dioxins and Furans is very limited. There is no national exchange system between ministries and institutions. In order to receive information, one should submit a request that is mainly addressed to the General Manager of the concerned institution. 2.3.9. Relevant Activities of Non Governmental Stakeholders In Lebanon, several associations representing the interests of various industrial sectors in general and within the field of chemicals do exist. These organizations' major objective is to bring together the industries belonging to their sector or region and promote material output and export, with limited or no concerns in relation to health, safety and the environment. Some institutions and groups that involve chemical management in their activities or support such initiatives are further described in the subsequent paragraphs. 2.3.9.1. Industrial, Commercial and Agricultural Associations ASPLANTE ASPLANTE is a non profit association of importers and distributors of agricultural products, established in 1965. Its major activities deal with forwarding services and looking after the interests of its members, besides, enhancing agricultural production practices and methods for the welfare of the Lebanese Farmer and Lebanese agricultural economy. ASPLANTE indulges in ministerial actions through the Committee of Pesticides. It is an active member of Croplife International, the global Agro-Industry Federation and does work under its emblem in issues related to industry. It is an active participant in regional and international conferences related to pesticides formulation and manipulation. The association takes stake endeavor for the implementation of environmentally safe use of pesticides including import, registration, safe use, and disposal of obsolete stock and empty containers. The Association does practice technical activities related to agrochemicals licensing and development of regulatory issues concerning the importation, registration, use, labeling and awareness of pesticides manipulation and disposal. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Federation of Chamber of Commerce, Industry and Agriculture of Lebanon The federation has its juridical personality as well as financial and administrative autonomy. The Federation coordinates between the different chambers of commerce and industry in Lebanon and has the following main activities: • Holds economic conferences, local and international exhibition. • Represents the chambers in common interests with official authorities, economic talks with Arab, foreign and international delegations. • Cooperates with official authorities in order to organize, develop and promote the national economy, collect and coordinate economic and commercial information and statistics, issue newsletters and prepare studies and researches in this purpose. • Exchanges opinions, information and reports with international and foreign organizations and institutions interested by economic and commercial matters, while giving opinion to competent authorities before approving the establishment of new chambers and giving new permits to establish mixed chambers between Lebanese and foreigners. The regional chambers have the following activities: • Approval of bills and the issuance of the necessary certificates of the authenticity of exports' prices as well as certificates that prove the commercial or industrial or agricultural nature of a product. • Approves the authenticity of signatures of traders, industrialists and agriculture producers registered in the Chamber and issues certificates of origin for exports since the chamber has been entrusted by the government with the task of attesting invoices and issuing certificates of origin and submitting of commercial documents relating to the export of goods from Lebanon. • Provides solution to problems and hindrances impeding commerce, industry and agriculture, and work on solving them as well as helping within its capacity. Association of Lebanese Industrialists The association of Lebanese Industrialists is a Lebanese economic organization grouping industrialists from all Lebanese regions in a concerted and balanced effort at promoting and developing industry in Lebanon. The association seeks to create and maintain an atmosphere which is favorable to industrial growth and development. The Association boasts a membership of 1,100 which represents about 75% of the total capital invested in manufacturing. It lobbies for certain policies, negotiates with labor unions, fosters cooperation between industrialists and organizes seminars and activities to help modernize industrial firms. The association has a wide range of activities on the national and international level: • Vocational training development • Technical education program • Sales promotion of Lebanese manufactured products in the local markets • Rehabilitation of infrastructures, transport, etc... • Participation in meetings and discussions related to industrial activities There are 12 Specialized Committees that play a significant role in policy formulation. Each committee is headed by a member of the Board of Directors and membership is open to members of the Association. In addition, there are 4 Special Committees. The environmental committee is part of the ALI's committees and follows-up issues concerned with the environment. This committee meets once per month and has the following activities: • Follow-up of issues concerned with the environment • Participation in environmental workshops • Organize awareness programs concerned with cleaner production Another committee is formed jointly with the MoE where a partnership was established between both parties. The main objective of this committee is to form a strategy for compliance of industrial to environmental requirements. It is headed by the General Director at MoE and members are represented by MoE staff and the ALI representative. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 50-51 Industrial Syndicates Lebanon has a wide range of business associations that are mainly concerned with promoting their business interests and maintaining good working relations with policy makers. With regard to the organization of labor, there are approximately 400 labor syndicates in Lebanon. The pyramid of labor organization is topped by the General Confederation of Lebanese Laborers (GCLL). 2.3.9.2. Environmental Non-Governmental Organizations National and international NGOs such as Rene Moawad Foundation, Makhzoumi Foundation, and Greenpeace are active and participate in bringing up the issue of chemicals management and hazardous waste through daily follow-up and public awareness campaigns. MoE has provided small grants to environmental NGOs since 1994 as part of its own budget. In 1992, eight NGOs combined to establish the Lebanese Environment Forum (1999 membership reached 33 NGOs) while other five organizations formed the Green Forum. However, more than fifty organizations do not belong to these forums. So far, Lebanese environmental NGOs have been weak at the national and international levels in terms of effectively lobbying for policy changes. Activities are focused primarily on urgent local issues and can be summarized as follows: • Raising environmental awareness • Organizing conferences, seminars, workshops, etc. • Organizing topical activities • Exposing environmental threats • Protecting nature (mainly forests and wildlife reserves) • Undertaking research and training Table 2.21 gives an idea of active NGOs in the field of environment and agriculture. The Greenpeace office in Lebanon has been running an aggressive campaign against POPs. In 1997, they launched a campaign to protest against waste incineration in Lebanon, stressing on the fact that incineration is the primary source of POPs in Lebanon. Greenpeace demanded and maintains that Lebanon should ban incineration. The campaign contributed to the closure of two municipal waste incinerators in the Beirut suburbs (Karantina, Aamrousieh). In 2002, Greenpeace began pressuring hospitals to stop medical waste incineration. They collected and analyzed soil samples from the vicinity of the incinerator at Hotel Dieu, one of the largest hospitals in Beirut. The results showed high levels of Dioxins, Furans and heavy metals. Following sustained public pressure, the American University Hospital and Hotel Dieu are considering alternative waste treatment technologies including autoclaving. Their incinerators have reportedly been decommissioned. Table 2.21..Relevant Environmental NGOs Organization Activities Contact Makhzoumi Foundation Agriculture, community development www.makhzoumifoundation.org Rene Moawad Foundation Agriculture, health, environment, www.rmf.org.lb rural development Association for Forest Development Community development, rural www.afdc.org.lb and Conservation development, environment Green Line Association Agriculture, environment www.greenline.org.lb Society for the Protection of Nature in Environment, education www.spnl.org.lb Lebanon Arc En Ciel Community development, www.arcenciel.org handicaps, health Greenpeace environment www.greenpeace.org.lb Association Libanaise pour le Maîtrise environment www.almee.org.lb de L'Energie Mercy Corps International Income generation, rural development www.mercycorps.org Pontifical Mission Rural development, refugees/displaced www.pontifical.org Young Men's Christian Association Agriculture, health, community www.ymca-leb.org.lb development POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 2.3.9.2.1 Universities Environmental clubs at universities work on awareness programs where faculties (Science, Agriculture) work more on funded projects by the Ministries of Agriculture and Environment or International funding agents (USAID, EU). 2.3.9.2.2 Private Consulting Companies There are over 20 Lebanese engineering and consulting firms with experience and qualifications in different environmental planning and management aspects68. However, most of these consulting firms are small in size, although with most of them venturing with European or American counterparts. 2.3.9.2.3 Summary Table 2.22 shows the strengths of different institutions and the capability of integrating them in governmental programs to raise their responsibilities in the management of chemicals. 2.3.10. Overview of technical infrastructure for POPs assessment, measurement, analysis, alternatives and prevention measures, management, research and development - linkage to international programmes and projects 2.3.10.1. Overview of Laboratory Infrastructure This section provides an overview of laboratories with analytical chemistry capabilities which can help to ensure the quality of chemicals, conduct residue analysis, identify unknown substances, and monitor for possible adverse effects. A questionnaire was prepared based on the "UNEP Global Monitoring Program on POPs" questionnaire with some modifications. This questionnaire has been sent to laboratories at universities and government institutions. Fourteen (14) laboratories from responding ones were relevant to the study. Many laboratories, belonging to ministries, research institutes, universities or the private sector, can be considered for management of chemicals in Lebanon. The most important ones, from the perspective of enforcing chemicals' management policies, are mentioned in the Table 2.23. 68 MoE/ECODIT, 2001 Table 2. 22. Summary of Expertise Available Outside the Government Field of Expertise Research Universities Industry Environmental/ Labour Unions Professional Other Institutes Consumer Groups Orgs. (specify) Data Collection √ √ x √ x √ Yes consulting firms Testing of Chemicals √ √ √ x x x Yes Laboratories Risk Assessment √ x x x √ Yes consulting firms Risk Reduction √ √ √ x x x Policy Analysis √ √ x x x √ Yes consulting firms Training and √ √ x √ x √ Yes Education Consulting firms Research on Alternatives √ √ x √ x √ Monitoring √ √ x √ x x Enforcement x x x √ √ x Information to x √ √ √ √ √ Yes (Farmers Workers org) Information to √ √ x √ √ √ Public POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 52-53 Table 2.23. Overview of Laboratory Infrastructure for Regulatory Chemical Analysis Name/Description Location Equipment/ Accreditation Certified GLP69 Purpose of Laboratory Analytical (if yes, by whom?) (yes/no) capabilities available Advanced Construction George Assy St., -UV Spectro- None ISO9001 Physical, and chemical Technology Services Sanayeh photometer ISO/IEC 17025 testing of material (ACTS) P.O. Box (in process) construction and soil 14-5918 Beirut, Lebanon Environmental Core Basic Medical -GC-ECD/ NPD/FID EPA Certification ISO/IEC PCB, organochlorine Laboratory (ECL) bldg, 3rd floor, -GC-MS Manual for 17025,.(in process) pesticides, drugs/ room:3-27,3-28, -ICP-MS Environmental pharmaceuticals, 3-42,3-44, AUB -HPLC Laboratory petrochemicals, heavy PandTGC-MS Approval Program metals, PAHs, Alcohols, HRGC-HRMS and American toxins, food additives, Colorimetric method Association for poisons. Water, waste Laboratory water, solid waste, food Accreditation compost stones, alloys, (A2 LA) rocks, biological tissues Central Research AUB, Faculty - HPLC None - Science Laboratory of Arts and - Flame AAS (CRSL) Sciences - Colorimetric method Immunoassay screening Environmental AUB, Faculty - Flame AAS None - Heavy metals Engineering Research of Engineering - Electrothermal AAs (wastewater, leachate, Center (EERC) -Hydride/vapor municipal solid waste, generation AAS sediments, sludge, soil, water) Soil Chemistry AUB, Faculty - Colorimetric None - Heavy metals Laboratory of Agriculture - Flame AAs and Food Sciences Pesticide Research AUB, Faculty - GC-MS - Organochlorine pesticides, Laboratory of Agriculture organophosphorous and Food pesticides, pharmaceutical Sciences drugs, alcohols/glycols Centre régional de CST - Mar - Spectrophotometer None - L'eau et de Roukos BP - AAA l'environnement GREEN 11-0514 Université Saint Joseph, Riad El Solh Faculté D'ingénierie, Beyrouth ESIB Liban 1107 2050 IRI: Paris Avenue -Spectro-photometer: German ISO/IEC 17025 Pesticide residue, Industrial research Père Lebret UV/VIS Accreditation heavy metals, water, institution Street, -HPLC: UVdetector/ Body, Germany soil, air, food, wetchemistry Ras Beirut, fluorescence 2005 Industrialand Beirut, -ICP-MS commercial product, Lebanon -AAA: MVU/HGU petroleum products GC-ECD/NPD/ FID GC-MS 69 Good Laboratory Practices POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Name/Description Location Equipment/ Accreditation Certified GLP69 Purpose of Laboratory Analytical (if yes, by whom?) (yes/no) capabilities available LU (Faculty of Sciences) Hadath -AA None - Chemical pollutants spectrophotometer (MoE/ECODIT, 2001) Gas chromatography Flame photometer Total carbon analyzer HPLC, UV spectrophotometer LAU: Byblos -UV spectro- None - Water, sediments and Lebanese American photometer ambient air University -Fluorescence Specto. Environmental -HPLC laboratory and the -LC-MS pharmacy -AAS GC-MS/FID/UV/ fluor. Detectors. ICP LARI: Tel Amara -Inductively Coupled None - Soil, plant tissues Lebanese Agricultural Station in the Plasma-AE analysis, drinking and Research Institute Bekaa Valley - HPLC irrigation water, animal AAS waste analysis UV-VIS Feedingand forage Spectrophotometer analysis. Kjeldhal distillation and digestion Flame Photometer Ion Chrom. Amino Acid Analyzer Elemental Analyzer Saccharimeter Infratec Analyzer pH and electrodes Sample preparation LARI: Fanar -GC-ECD None None Organochlorine Lebanese Agricultural -GC-FID/PID pesticides, heavy Research Institute -HPLC metals, alcohols, natural Flame AAS toxins, other poisons Hydride/vapor generation AAS Colorimetric Public Health Laboratory: Nsouli Street, -GC with several None None Clinical chemistry, central laboratory Beirut detection systems. water, food. HPLC ICP UV spectro NCSR- Lebanese Highway -Alpha Spectrometry None None Water, food, clinical, Atomic Energy Beirut, Lebanon -GC-MS waste. Commission. (LEAC) P.O. Box 11-8281 -LSC Riad el Soleh POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 54-55 Name/Description Location Equipment/ Accreditation Certified GLP69 Purpose of Laboratory Analytical (if yes, by whom?) (yes/no) capabilities available NCSR- National Centre Batroun - -Electrothermal AAS None None Heavy metals for Marine Sciences North Lebanon -Hydride/vapor (NCMS). P.O.Box 534, generation AAS Batroun, -Colorimetric Beirut Arab University Beirut -HPLC None None Drugs/pharmaceuticals Flame AAS heavy metals, poisons, Hydride/vapor industrial/municipal generation AAS wastewater, sediments, Colorimetric soil, water Electrothermal AAS Anodic stripping voltametry AAA = Amino Acid Analysis AAS = Atomic Absorption Spectrophotometer; GC-MS = Gas Chromatography-Mass Spectrophotometer; NPD = Nitrogen-Phosphorous Detector; FID = Flame Ionization Detector; ICP-MS = Inductively Coupled Plasma Mass Spectrophotometer; HPLC = High Performance Liquid Chromatograph; P&TGC-MS = Phosphorous and Total Gas Chromatography Mass Spectrophotometer; HRGC-HRMS = High Resolution Gas Chromatography-High Resolution Mass Spectrophotometer IRI is the only institute holding an international certification (ISO 17025; General Requirements for the Competence of Testing and Calibration Laboratories) where few laboratories are working on getting international certifications (AUB) in order to improve their working practices. The poison centre at USJ works on analyzing poisoning related to food, alcohol, and medicine use. The centre is getting equipped and trained to work on pesticide poisoning as a future step. Personnel working at surveyed laboratories are highly skilled (holding Ph.D., M.S. and B.S. degrees). Generally, the laboratories affiliated to academic institutions are followed-up and improved in accordance to the institution's regulations, objectives, and budget allowances and if accredited, supposedly jointly by the accreditation body. As for governmental laboratories, improvement is dictated by the authorities to whom the laboratory is affiliated. The Ministry of Finance is working on a project funded by the EU on quality units where 5.8 Million Dollars will be dedicated among others, to improve lab infrastructure. Cooperation among countries to share laboratory facilities is very limited and informal. Share of test results with an another country occurs upon a common agreement especially at connected water bodies or other resources Measurement capacities Workers potentially exposed to PCBs have received no training on how to conduct rapid qualitative tests to detect PCBs. At least two laboratories in Lebanon (Industrial Research Institute and AUB Core Lab) have in-house PCB testing capabilities. Research and Development The inventory was not able to obtain information regarding the possibility of research studies currently in preparation or on-going at universities and research institutes. 2.3.10.2. Overview of Government Information Systems/Computer Capabilities Lately, computers facilities have increased in governmental institutions, ministries and industries; some ministries developed their own Internet sites, which further facilitate internal and external information flow. On the other hand, almost all the research laboratories or staffs use the Internet and the Email system to provide information about their activities and qualification, to communicate, to collect data and to get access to international magazines. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 2.3.10.3. Overview of Technical Training and Education Programs Lately, some universities and institutes in Lebanon developed higher educational programs (MS., PhD) related to chemicals' management in chemistry, biochemistry, agronomy, food science and technology, public health, environmental sciences and engineering. In addition to universities, there are some important research centers in Lebanon, namely the National Council for Scientific Research, the Industrial Research Institute, and the Lebanese Agricultural Research Institute for the sake of illustration Although their facilities and financial resources are limited, the universities and research institutes try to provide the best trainings to their employees to keep them up-dated with the latest available information and technologies, by collaborating with external research institutes and universities, by investing in libraries and equipments, by financing theses and by participating in national and international seminars, hold in and outside Lebanon such as AUB laboratories and IRI. The research areas are many and involve basic and applied research in their multiple aspects such organic, inorganic and analytical chemistry, etc. On the technical level, there are no educational institutes providing technical studies in chemicals' management in Lebanon and important investments are still needed in this field POPs awareness in Lebanon is fairly limited to educated people or individuals who are professionally or academically interested in POPs issues. Perhaps the most limited awareness is that of farmers' to POPs pesticides. PCB awareness in the country is limited to very few people mostly the members of the PCB committee, the project team and a few chemical specialists. There is a need to publicize the affects of PCB use on human health and the environment. Training workshops are necessary for the EDL staff. The training workshop must focus on developing the skills and know-how on handling, storing and monitoring of PCB products and equipment. The customs website is the only existing system that provides computerized records that date back to 2000. The database is online and information on the amount of PCB import has been aggregated under mineral oil (i.e., 13 tonnes imported since 2000). Previous records of transformers that have undergone oil filtration and record keeping of distribution transformers is poor. EDL archives all documents (including purchasing requests) for about 10-15 years then destroys those records. The records have never been computerized and put for public access. Consequently, historic records of oil imports (pre 1990) some of which may have contained PCB are no longer available. The public does not have access to any records or information related to PCBs in Lebanon. 2.3.11. Identification of impacted populations or environments, estimated scale and magnitude of threats to public health and environmental quality and social implications for workers and local communities At the national level, breast cancer was reported as the most common cancer among women in Lebanon accounting for almost one third of all cancers in women, whereas, in the mid-sixties, it represented 18%, of all cancers in women70. In depth investigation and epidemiological studies are needed to examine the association between these high rates and exposure to POPs. As a case study, analysis of health history of workers within Jieh Power plant and Bauchrieh station showed cancer incidence among workers exposed to PCB71. However, this case study was mainly based on questionnaires, filled by 145 workers, 62 of whom reported health problems, and 11 of whom reported cancer. However, these findings need to be addressed cautiously due to methodology limitations (particularly the questionnaire and the small sample size). 70 Nuwayhid and Sibai, 2002 71 COGIC, 2004 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 56-57 Concerning pesticides, low level exposure was reported to be correlated with increased risk of cancer. Within the Lebanese context, cardiovascular diseases were the main underlying cause of death in Beirut in 1992-93 (49% of deaths among males and 36% among females)72. The World Bank Human Development Group of Middle East and North Africa (January 2000) reported that the major causes of morbidity among elderly in Lebanon are cardiovascular diseases and diabetes and which requires further research and investigation to analyze for its relationship with exposure to POPs. Neurotoxicity research has been facing many challenges in Lebanon, but it is worth noting that some attempts were made to examine the prevalence of neurobehavioral effects among working children, and detected a correlation between lower neurobehavioral performance and exposure to solvents in some occupations74. Similar research might be needed to test for similar correlations with POPs. There are no clear indicators or estimates for endocrine symptoms at the national level. However, hormonal disturbances are reflected in reproductive (fertility), metabolic (diabetes) and other health outcomes. Local studies report that reproductive impairments and diabetes are common in Lebanon, and increase with age75. Yet in-depth analysis and research is needed to analyze for cause effect relationships with environmental exposures. Technicians that work at the hotspots and who transfer old and damaged transformers as well as emptying the oil from irreparable transformers are at high risk from PCB exposure, especially since most do not wear protective clothing. An earlier study in 200476 assessed the impact of PCBs on the health workers at the Bauchrieh repair shop using a questionnaire. A total of 145 workers participated, 62 (43%) of which were seen to be directly exposed to PCB. The questionnaire investigated the affect of PCB exposure on the occurrence of health symptoms encountered by the workers (i.e. Ocular, Dermal, Cardio and Cancer symptoms). Out of the workers exposed to PCB 34.7% showed ocular symptoms versus 15.1 of the workers that were not exposed. As such 20.8% versus 4.1 % showed dermal symptoms, 26.4% versus 38.4% showed Cardio symptoms and 22.2% versus 4.1% showed Cancer symptoms. In general the workers exposed to PCBs were more susceptible to the health symptoms in comparison to workers who were not. 2.3.12. Details of any relevant system for the assessment and listing of new chemicals No well-defined procedure is available for the assessment and listing of new chemicals. Despite this, new banned chemicals were being introduced quickly and efficiently through coordination between relevant ministries and the Lebanese Customs Authority. As such, a system remains to be defined and well-described, in order to decrease dependence on simple one-to one communication among institutions. 2.3.13. Details of any relevant system for the assessment and regulation of chemicals already in the market There were limited relevant systems or mechanisms identified in Lebanon that regulate the marketing of chemicals (agricultural, industrial). Pesticide retailers and outlets typically submit logbook records of their sales, by product active ingredient, brand name, and quantity. Statistics have been gathered by the MoI on industrial sales and production, and are to be frequently updated and published. 72 Nuwayhid et al., 1997 73 Nuwayhid and Sibai, 2002 74 Saddik et al., 2003 75 Nuwayhid & Sibai, 2002 76 Preliminary Inventory for PCBs and Chlorinated Pesticides prepared by COGIC consultants, 2004 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Strategy and Action Plan Elements of the National Implementation Plan 3.1. Policy Statement Being aware of the toxic properties of the Persistent Organic Pollutants, their resistant properties to environmental degradation, their capacity to bioaccumulate, and their mobility in the environment, as well as the risk they present to human health, In line with Lebanon's long standing efforts to combat POPs pollution, reflected through the decision by the Minister of Environment nº 71/1 on 19/5/1997 (Banning the import of PCBs or any material containing or contaminated with PCBs), and the decision by the Minister of Agriculture nº 94/1 on 20/5/1998 (banning, among others, the POPs pesticides subsequently mentioned in the Stockholm Convention), Convinced of the importance of undertaking gradual reduction, and where feasible elimination, of emissions and discharges of POPs on the Lebanese territories, Determined to safeguard its environment and population by controlling all sources of adverse impacts induced by POPs at all stages of their life cycle, The Ministry of Environment's decision closes the consultation process and is regarded as a political declaration for undertaking actions directed at reducing the impacts of Persistent Organic Pollutants on the environment and human health, and endorses the National Implementation Plan (NIP) for the Stockholm Convention, prepared under the UNEP/DGEF 12 Countries Pilot Project for the Development of National Implementation Plans for the Management of Persistent Organic Pollutants Lebanon Sub-project (GF/2723-02-4458). The Ministry of Environment commits itself to undertake adequate activities in order to implement the tasks included in the NIP action plans and meet its obligations under the Stockholm Convention within its existing national circumstances and capabilities. 3.2. Implementation Strategy 3.2.1. Introduction The diagnosis of the existing situation in Lebanon on the basis of available data is an essential element for taking proper measures aiming at successful implementation of the provisions of the Stockholm Convention. In that respect, the results of the three preliminary inventory reports and the National Profile on Chemical Management were first evaluated. This proved to be a valuable exercise, as major gaps were identified. The major obstacles ahead are: • Lack of databases and monitoring infrastructure; • Lack of precise emissions data; • Insufficient or lack thereof on the level of environmental and food contamination by persistent organic compounds; • Low public awareness related to threats caused by POPs • Lack of sufficient financial resources to eliminate, control or reduce the emissions of POPs. Quantitative data on chemical pollution is very limited. Published figures regarding chemical pollution within different media are limited to studies and projects within a restricted period and selected area. Continuous monitoring is almost absent often due to insufficient financial resources, technical infrastructure and skilled human resources. There is a lack of information on the chemical composition for most of imported chemicals, raw materials and products. The lack of database on imported and used chemicals in the country makes it unfeasible to determine the location of handling and storage of certain hazardous chemicals. In general, there is no systematic tracking system of hazardous products transport in Lebanon. No emergency response system is set in place to address emergency situations related to transport or industrial accidents. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 58-59 In addition to the lack of database information, no national health assessment studies are available rendering it more difficult to set national health priorities. The capacity to comprehensively monitor industrial sources is limited in Lebanon. There is a clear need to promote source monitoring programs in coordination with the private sector. From existing publications, a general or qualitative idea of chemicals-related problems can be inferred, but not quantitative or region specific information showing which regions are more affected than others since studies do not cover long monitoring periods, affecting factors and impacts. The absence of data pertaining to: a) environmental levels (air, water, land, and sediments), b) human concentrations, and c) sources of POPs pesticides presents a major limitation for conducting risk assessment representative of the real situation in the country. Risk Assessment of such pollutants is recommended after the identification of hotspots, the detection of the levels of suspected chemicals, and the identification of the exposed population. Lack of adequate sources of data was the major limitation for the assessment of the status of POPs in Lebanon. This limitation was a common reported factor across the three inventories. Monitoring data was a major shortcoming facing health and environment assessment of POPs as Lebanon lacks a specialized monitoring program for the detection of environmental Dioxin and Furans concentrations. This can be attributed to the lack of financial and human resources. The developed National Profile for the year 2005 identifies and assesses the capacity of the national laboratories in chemical analysis, and the hindering factors behind the continuous monitoring of such chemicals. 3.2.2. Criteria and Priority areas With respect to the current situation with POPs based on the inventories (Dioxins/Furans, PCBs, and Pesticides) and the National Profile for Chemical Management in Lebanon and developed criteria, priority areas were recognized during the National Priority Validation Workshop. For each priority area a set of objectives was formulated to better define the proposed activities under each priority area, each objective generating a number of actions. The priority actions were set as follows: 1. Strengthening the Legal Framework • Take effective legislative measures to regulate POPs management in the country, including obligation for introduction of new technologies, techniques and practices, inventory, monitoring and control programmes of POPs in environment and humans • Update existing legislation based on gaps and weaknesses of existing legal framework; this includes reviewing the mandates of key institutions. • Propose new legislation to complement the existing ones and lead to full compliance with Stockholm convention's requirements. • Develop mechanisms for enforcement of legal framework such as the creation of inspection units for the control of chemicals at their different stages (import, export, formulation/production, emission, storage, packaging, use, marketing and disposal). 2. Institutional Strengthening and Capacity Building • Identify and assess the needs of key ministries and institutions involved in chemical management to fulfill its mandates (human resources, equipment, financial resources, IT, etc.). • Identify and propose mechanisms to improve the communication among key ministries and stakeholders such as through the creation of a National Committee for Chemicals Management. • Provide training for relevant parties; decision-makers, industrialists, farmers, laboratories, customs, traders and community as needed. • Control of smuggling activities POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3. Improving Data Management • Update and strengthen existing databases. • Strengthen information exchange linkages. • Create a database for record keeping on POPs emissions. • Update inventories on regular basis. • Conduct a comprehensive POPs inventory and update it regularly. 4. Raising Awareness • Develop awareness programs to decision makers, industrialists, farmers, laboratories, customs, traders and community. 5. Mobilizing Financial Resources for NIP Implementation • Develop a resource mobilization plan for chemicals management in Lebanon (Insufficient national financial resources at the moment). • Allocate new funds based on NIP findings and recommendations. 6. Promoting Improved Technologies and Practices • Promote Best Available Technology (BAT)/ Best Environmental Practices (BEP) techniques. • Establish emergency plans, health and safety measures to reduce risks occurring during the import, production, transport, use, and emission of chemicals. 7. Promoting Research in Chemicals Management • Identify key areas that need further research and development. • Identify key research institutes to form an R&D holster. • Support the holster in developing R&D in the key areas identified. • Systematic research programmes for more efficient control and monitoring of each group of POPs chemicals in the environment and humans (during the inventory assessment phase, it has been confirmed that the current levels of research programmes in POPs areas were not sufficient). 8. Improving National Infrastructure • Increase laboratories' capabilities of testing POPs and chemicals' composition and residue. • Increase the number of qualified laboratory personnel, trained for the different analysis methods. • Increase the number of accredited and certified laboratories. • Assess the need for new laboratories in different geographical areas of Lebanon. 9. Managing Hot-Spots and Stockpiles • Promote the safe disposal of existing stocks • Identify and de-contaminate polluted sites with POPs chemicals. • Sample and monitor environmental matrices (air, water, soil, sediments) and biota (food, occupation). As part of the priority-setting process, proposed five evaluation criteria to screen and prioritize the issues and actions related to the management of Dioxins and Furans, PCBs, and pesticides were proposed. The five criteria are: 1. Technical feasibility 2. Financial requirements 3. Relevance to the provisions of the Stockholm Convention 4. Ability to generate socio-economic benefits 5. Urgency The fifth criterion was later slightly modified from “Urgency” to “Urgency/Occurrence” (the change was solely made to the term used and not to its definition or degree of urgency). Each evaluation criterion can obtain 1pt, 2pts or 3pts. Assuming no weights are assigned to the criteria, the highest obtainable score would then be 15 points (5 criteria, 3 pts each), whereas the lowest would be 5. To differentiate high priorities from medium and low priorities, the following grading levels are proposed: 1. High Priority are issues that have received a score between 12-15 points 2. Medium Priority are issues that have received a score between 10-12 points 3. Low Priority are issues that have received a score below 10 points The evaluation criteria are listed Table 3.1 below and described in more details to facilitate the priority-setting exercise. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 60-61 Table 3.1. Evaluation Criteria and Scoring System for Priority Setting Criteria Weight* Score 3 2 1 1. Technical feasibility (incl. skills and know-how) Highly Moderately Poorly Feasible Feasible Feasible 2. Financial requirements (incl. capital and O&M costs) Low Moderate High 3. Relevance to provisions of the Stockholm Convention Highly Moderately Poorly Relevant Relevant Relevant 4.Ability to generate socio-economic benefits High Moderate Low (incl., BEP and BAT) 5. Urgency/Occurrence Very Urgent Moderately Urgent Poorly Urgent Maximum Scores 15 10 5 * The priority-setting workshop discussed the merits of assigning weights to the evaluation criteria. 1. Technical feasibility - This criterion is about how feasible it is to implement the priority area. A priority area would score 3 (highly feasible) if the human (skills and know-how) and technical (technology) resources are widely available for implementation of the priority area. Additionally, the selected technology should be adapted to local conditions (physical, chemical, geographic). The priority area would score 1 point if neither human or technical resources are readily available. 2. Financial requirements - This criterion examines the financial requirements of the priority area including capital as well as Operational and Management (O&M) costs. The priority area would score 3 points if it requires low financial resources (capital and O&M) and 1 point if it requires unreasonably high resources. 3. Relevance to the provisions of the Stockholm Convention - This criterion is designed to differentiate priority actions that are directly related to the Convention (i.e., the priority area is clearly embedded in one of its Articles) from those that are not (i.e., the priority area is not a stand-alone Article in the Convention). 4. Ability to generate socio-economic benefits - This criterion reflects the ability of each priority area to generate socio-economic benefits. For example, if the priority area will generate significant socio-economic benefits, such as improving the occupational environment of workers exposed to POPs, then it would score 3 points. If however the priority area will potentially generate significant opposition (e.g., imposing heavy emission charges on industries, introducing waste incineration to treat POPs), then the priority area will score 1 point. The socio-economic impacts of introducing Best Environmental Practices (BEPs) and Best Available Techniques (BATs) should also be considered here. 5. Urgency/Occurrence - This criterion reflects the urgency of the priority area within the Stockholm Convention timeframe (i.e., up to 2025). If the priority area must be immediately implemented, then it would score 3 points. If the priority area “can wait,” then it would score 1 or 2 points depending on how relaxed the urgency. During the priority setting workshop, an open debate was initiated in order to discuss the effectiveness of adding a weighing factor to the matrix. It was proposed to vote on picking a weighting system of: no weights, weights 1 to 3, or weights 1 to 5. After voting on the three proposed options, the stakeholders agreed on using a weight range of 1 to 5. In addition, the participants agreed on not including the 'Zero' to the scoring. This was followed by a 'ranking exercise' where the participants agreed to add a weighing factor by filling a ranking sheet of criteria. The results are shown Table 3.2. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon The given priorities (defined as “Criterion” in Table 3.2) set for prioritization were based on the following developed criteria: Complying with the provisions of the Stockholm Convention Impact on the environment and on human health National, regional and global requirements Financial resources Availability and existence of technical solutions Time consideration Impact on unemployment and economical development All aspects of the above proposed priorities were reviewed and adjusted to the specific requirements and conditions of each inventory. Each technical report focused on the infrastructure, the available capacity gaps and the existing barriers in the current legislation which in turn, slowed down the adoption of the Stockholm Convention. During prioritization, the identified capacity gaps were analyzed and leveled. Based on these gaps and group of barriers, the main priorities were identified within each inventory assessment. During the prioritization session, several points of discussion and bottleneck issues were raised among the groups and an overview of the project was given to the participants to clarify and simplify issues. Moreover, a presentation was given to show the methodology followed in the inventories of each categories. 3.2.3. Priority Setting With respect to the prevailing situation of POPs in Lebanon, and following discussions, the participants grouped ranked the priority areas as shown in Table 3.3. Table 3.2 Results of Ranking Exercise Nº Criterion Ranking Weights 1 Technical Feasibility 2 4 2 Financial Requirements 1 5 3 Relevance to Provisions of the Stockholm Convention 5* 1 4 Socio-economic Benefits 3 3 5 Urgency 4 2 * Relevance to Provisions of the Stockholm Convention being undoubtedly one major criterion, it was ranked as least important (Number 5) in order to better level the other factors. Table 3.3. Priority Areas Priority Area Dioxins & Furans PCBs Pesticides Total Score Rank Score Rank Score Rank Raising Awareness 35 2 43 2 35 3 113 Institutional Strengthening & Capacity Building 30 4 38 3 37 2 105 Strengthening the Legal Framework 41 1 45 1 19 8 105 Mobilizing Financial Resources 35 2 30 4 28 5 93 Promoting Research in Chemical Management 35 2 30 4 25 7 90 Promoting Improved Technologies 31 3 26 6 26 6 83 Improving Data Management & Monitoring 24 5 23 8 34 4 81 Programs Improving National Infrastructure 15 6 24 7 39 1 78 Managing Hot Spots & Stockpiles 31 3 27 5 17 9 75 Total 277 286 260 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 62-63 In general, PCB related issues ranked the highest followed by PCDD/PCDF. Pesticides ranked the last, and thus are judged to be the least important of all POPs sectors (the sectors being PCBs, PCDD/PCDF, and pesticides). Overall, the highest ranked priority area was 'raising awareness' followed by 'strengthening the legal framework' and finally 'institutional strengthening and capacity building'. However, results per sector show a different picture; under the PCDD/PCDF, the highest priority area ranked was 'strengthening the legal framework' followed by 'raising awareness', 'mobilizing financial resources', and 'promoting research in chemical management'; 'managing hot spots and stockpiles' and 'promoting improved technologies' ranked third. As for PCBs, the highest ranking priority area was 'strengthening the legal framework' followed by 'raising awareness' and 'institutional strengthening and capacity building'. The pesticides priority ranking did not differ that much from the above mentioned two, except that the first ranking priority area was 'improving the national infrastructure' followed by 'institutional strengthening and capacity building' and 'raising awareness'. 3.3. Activities, Strategies and Action Plans Sections 3.3.1 through 3.3.17 present specific activities, strategies and action plans for POPs management consistent with the UNEP guidelines on how to present National Implementation Plans. Each section explains how the given activity, strategy or action plan is related to the Stockholm Convention and provides a summary of background information and findings. For clarity, each activity, strategy and action plan is then presented in a separate, stand-alone, table. The tables provide a description of each action (Description), the tasks under each action (Tasks), the responsible implementing partners (Responsibility), the estimated cost and the time-frame for each task. The timeframe is provided in ranges by task77. Calculating the cost of executing the National Implementation Plans for the Management of Persistent Organic Pollutants is based on many assumptions and subject to much uncertainty. However, providing such an approximation or estimate would deliver a better and more realistic idea to decision-makers of the costs involved, and thereby mobilize the funding needed to implement the action plans. This report outlines the assumptions undertaken for each respective action plan in order to breakdown the costs of implementation and gives an indication of the total costs of implementation of all action plans, giving them in terms of net present value of costs (discounted at 0% and at 3%). Many of the costs incurred would occur in the future, as the project timeline spans from the several years up to the year 2025. Therefore, discounting the costs to be incurred in the future to the present in order to attain the Net Present Value (NPV) would be necessary. The implicit weighting of the present over the future is known as discounting and the rate at which the weight changes is the discount rate. Discounting is used due to two main reasons, that of time preference and that of the productivity of capital. Time preference refers to the concept of uncertainty and impatience when considering a future cost or benefit and to the concept of opportunity costs in that there may be opportunities for generating further benefits from having a good now rather than later (productivity of capital). Therefore, any cost(s) to be incurred in the future would be discounted, and the rate of discount would be taken to be 3%, a standard rate used in many countries. Therefore, the NPV of costs would be: NPV = X / (1+r)t Where X is the total cost to be incurred over all years in consideration, 'r' is the discount rate (3%) and 't' is the time frame, or the number of years, where the costs would be incurred. Discounting would occur to Action Plans considered medium term (2010-2015) or long term (2016-2025) and not to Plans considered short term (2006-2010) in implementation time. 77 ST: short-term (1-5 years), MD: medium-term (6- 10), LD: long-term (10-20 years) POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon In Lebanon, studies, audits, sampling, projects (e.g. Environmental Impact Assessments) and wage rates have, more or less, a standard known market rate. After conferring with several local environmental and financial consultancies, the following rates of projects, audits, sampling, wages and studies were inferred; Environmental Impact Assessment Studies for small projects (e.g. industrial facility) amounts to about 5,000 USD and for larger ones around 15,000 USD. 20 thousand USD for small projects to environmental consultancies 20-30 thousand USD for medium projects to environmental consultancies 100-200 thousand USD for large projects to environmental consultancies Audits of small industries or establishments amounts to about 5,000 USD Audits of medium-large industries would cost between about 10,000 USD - 150,000 USD Sampling (of substances or other to test in labs) amount to about 2,500 USD per facility Fees for Junior Expert consultants amounts to about 150 USD/day Fees for Senior Expert consultants amounts to about 350 USD/day Fees for government employee (on-site visit) 40 USD/day Transportation cost 20 USD/day/vehicle Workshop is about 30 USD/head (which includes logistics and brunch/lunch), 150 USD/junior expert training hired, 350 USD/senior expert hired for training, and equipment at USD 250/day. Other rates and assumptions would be taken on a base to base basis 3.3.1. Activity 1: Institutional and Regulatory Strengthening Measures 3.3.1.1. Compliance and Objectives under SC This activity falls under the requirements of Article 5, a, ii of the Stockholm Convention: an evaluation of the efficacy of the laws and policies of the Party relating to the management of such releases. Objectives include: • Update existing legislation based on gaps and weaknesses of existing legal framework; this includes reviewing the mandates of key institutions; and • Develop mechanisms for enforcement of legal framework such as the creation of inspection units for the control of chemicals at their different stages (import, export, formulation/production, emission, storage, packaging, use, marketing and disposal). 3.3.1.2. Background information and Findings The current legislation in Lebanon does not adequately address the management of POPs. Emission and disposal standards regarding POPs do not exist and control is very limited. In particular: • Decision 52/1 (dated 29/07/1996) provides emission release standards based on three environmental receptors (air, water, soil) but does not include emission values for POPs. • Decision 8/1 (dated 30/01/2001) revised Decision 52/1 by providing detailed environmental limit values for classified industrial establishments as well as wastewater treatment plants. The values cover emissions into air and water matrices but do not mention POPs. • Decision 71/1 (dated 19/05 /1997) lists hundreds of imported waste material contaminated with chemicals that are restricted and/or banned from entering the country. Dioxins and Furans congeners are listed without any specifications and concentrations. • Law 8735 (dated 23/08/1974) addresses in vague terms public cleanness and sanitation. It does not however ban open dumping and burning of solid waste. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 64-65 D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 1. 1: A da pt E xi st in g an d O n go in g Le gi sl at io n A dd re ss in g H ea lth R is k Is su es fr om P O Ps C he m ic al s R ev ie w a nd u pd at e ex is tin g le gi sl at iv e 1. U pd at e D ec re e N o. 1 18 02 to d ev el op o cc up at io na l s ta nd ar ds a nd M oL , M oP H 14 ,0 00 U SD ST in st ru m en ts to r ed uc e an d el im in at e co nd iti on s sp ec ifi c fo r PO Ps c he m ic al s (2 m an m on th ) PO Ps e m is si on s pu rs ua nt to th e SC 2. U pd at e La w N o. 6 59 (M oE T, 1 0/ 08 /2 00 5) "C on su m er P ro te ct io n L aw " M oE T, M oP H 14 ,0 00 U SD ST to d ev el op c on su m er p ro te ct io n st an da rd s an d m on ito ri ng fo r PO Ps in fo od p ro ce ss in g in du st ri es a nd fo od s ol d on th e m ar ke t 3. U pd at e D ec is io n N o. 5 2/ 1 (2 9/ 07 /1 99 6) : S pe ci fic at io ns a nd M oE T, M oE 14 ,0 00 U SD ST co nc en tr at io ns to li m it ai r, w at er , a nd s oi l p ol lu tio n. I nt ro du ce a m bi en t st an da rd s fo r PO Ps r el ea se s in d iff er en t e nv ir on m en ta l m ed ia 4. U pd at e D ec is io n N o. 8 /1 (3 0/ 01 /2 00 1) : E nv ir on m en ta l l im it va lu es fo r M oE 14 ,0 00 U SD ST em is si on s an d di sc ha rg es fr om c la ss ifi ed e st ab lis hm en ts a nd w as te w at er tr ea tm en t p la nt s. I nt ro du ce s ta nd ar ds fo r D io xi ns /F ur an s at s ou rc es m en tio ne d in th e de ci si on . A dd n ew s ta nd ar ds fo r so ur ce s un de r so ur ce s II in A nn ex C o f A rt ic le 5 o f t he C on ve nt io n. 5. U pd at e D ec re e La w N o. 8 73 5 (2 3/ 08 /1 97 4) : P re se rv at io n of th e pu bl ic M oP H 14 ,0 00 U SD ST cl ea nn es s: B an o pe n du m pi ng a nd b ur ni ng o f s ol id w as te . A ct io n 1. 2: Im pr ov e En fo rc em en t M ec ha ni sm s & M ea su re s fo r PO Ps C he m ic al s C on tr ol D ev el op m ec ha ni sm s to s tr en gt he n 6. R ev ie w th e sa m pl in g & a na ly si s in sp ec tio n pr og ra m a t c us to m s to LC A 16 ,0 00 U SD ST th e en fo rc em en t o f P O Ps le gi sl at io n in cl ud e in er t m at er ia ls in a dd iti on to th e ac tiv e in gr ed ie nt s of p es tic id es • Id en tif y ha rm fu l o r ba nn ed in er t m at er ia ls in p es tic id es th at n ee d to b e te st ed , b as ed o n in te rn at io na l s ta nd ar ds a nd lo ca l r eq ui re m en ts • A ss es s th e te ch ni ca l a nd h um an r es ou rc es o f i ns pe ct io n te am s un de r th e M oA a t C us to m s to s am pl e fo r an d an al yz e ne w in er t m at er ia ls ; a nd pr op os e fu tu re r ec om m en da tio ns . • Im pl em en t t he u pd at ed in sp ec tio n pr og ra m w ith th e co lla bo ra tio n an d kn ow le dg e of a ll re le va nt s ta ke ho ld er 7. E nh an ce c on tr ol o f s m ug gl in g an d ill eg al e nt ry a nd e xi t o f P O Ps M oA , L C A 37 ,0 00 U SD C on tin uo us u p pe st ic id es a nd c he m ic al s to 2 02 5 • Id en tif y w ea kn es se s, s tr en gt hs a nd g ap s in th e sm ug gl in g co nt ro l m ec ha ni sm s of th e co un tr y. M ak e su re to in vo lv e re le va nt s ta ke ho ld er s in th is e xe rc is e • D ev el op a p la n to e nh an ce s m ug gl in g co nt ro l w ith d ue c on si de ra tio n to e nf or ce m en t m ec ha ni sm s. A ga in , m ak e su re to in vo lv e re le va nt st ak eh ol de rs in th e pl an d ev el op m en t. • En fo rc e or im pl em en t t he p la n to s tr en gt he n sm ug gl in g co nt ro l. T ab le 3 .4 A ct iv it y 1: I ns ti tu ti on al a nd R eg ul at or y St re ng th en in g M ea su re s POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e 8. E nh an ce in sp ec tio n of p es tic id es o ut le ts & d is tr ib ut io n re ta ile rs w ith M oA 32 ,0 00 U SD ST L T re sp ec t t o pr od uc t e xp ir y da te s, la be lin g re qu ir em en ts , h yg ie ne & o th er st an da rd s: • Id en tif y w ea kn es se s, s tr en gt hs a nd g ap s in th e in sp ec tio n of p es tic id es ou tle ts a nd d is tr ib ut io n re ta ile rs • D ev el op a p la n fo r m or e ef fe ct iv e in sp ec tio n • En fo rc e or im pl em en t t he p la n fo r m or e ef fe ct iv e in sp ec tio n an d pe rf or m an ce s el f ev al ua tio n A ct io n 1. 3: S tr en gt he n th e In st itu tio na l F ra m ew or k St re ng th en th e ex is tin g in st itu tio na l 9. C on du ct a n in st itu tio na l s tu dy to d et er m in e m os t a pp ro pr ia te M oE 25 ,0 00 U SD ST fr am ew or k an d as se ss th e ne ed to m ec ha ni sm fo r PO Ps m an ag em en t, en fo rc em en t, an d co m pl ia nc e to cr ea te a P O Ps fo llo w u p in st itu tio n st an da rd s (C om m itt ee & c om m is si on s or in st itu tio n or fo ca l p oi nt ) 10 . R ev ie w a nd u pd at e m an da te s of k ey in st itu tio ns (M oE , M oI , M oP H , M oE 20 ,0 00 U SD ST M oA ); w he re r eq ui re d, h um an r es ou rc e w ith s pe ci fie d ex pe rt is e le ve ls is to b e gi ve n po si tio ns a t t he m in is tr y. A ct io n 1. 4: D ev el op a nd E nf or ce R eg ul at io ns to P ro hi bi t t he M an uf ac tu re o r U se o f P C Bs a nd P C B C on ta in in g Eq ui pm en t A lth ou gh d ec is io n 71 /1 b an s th e 11 . M oE in c ol la bo ra tio n w ith th e M in is tr y of In du st ry a nd th e M in is tr y of M oE U SD 1 4, 00 0 ST im po rt o f P C Bs , o th er d ec is io ns a nd En er gy a nd W at er s ho ul d is su e a jo in t d ec re e th at : 20 06 2 00 8 la w s ar e re qu ir ed to p ro hi bi t t he • Pr oh ib it s th e m an uf ac tu re a nd u se o f P C Bs a nd P C B eq ui pm en t m an uf ac tu re o r us e of P C Bs a nd P C B • D ef in es a p ha se o ut p la n fo r PC B co nt ai ni ng tr an sf or m er s co nt ai ni ng e qu ip m en t • D el in ea te s ro le s an d re sp on si bi lit ie s fo r th e di sp os al o f P C B oi l a nd eq ui pm en t A ct io n 1. 5: E nf or ce th e Im po rt B an o n A ll C om po un ds L is te d in D ec is io n 71 /1 (A nn ex 2 , 1 99 7) In cl ud in g PC Bs To e nf or ce th e ba n on th e co m po un ds 12 . T o en fo rc e th e ba n, M oE s ho ul d se nd a m em o (b ay an ta ar ifi h) to M oE & L C A N o di re ct c os t ST lis te d in D ec is io n 71 /1 , M oE w ou ld Le ba ne se C us to m s i nd ic at in g w hi ch p ro du ct s a nd e qu ip m en t m ay c on ta in (& o th er in st itu tio ns ) 20 06 2 00 7 ne ed to w or k m or e cl os el y w ith PC Bs ( pr od uc ts a nd c he m ic al s ta nd ar ds u se d by te st in g la bo ra to ri es C us to m s (M O F) sh ou ld b e ex em pt ed ) A ct io n 1. 6: E st ab lis h a C he m ic al s M an ag em en t U ni t a t E D L ED L ha s ex pr es se d in te re st in 13 . E st ab lis h a ch em ic al s m an ag em en t u ni t a t E D L w ith s im pl e PC B ED L U SD 1 0, 00 0 M T es ta bl is hi ng o ne c en tr al u ni t f or te st in g ca pa bi lit ie s (d en si ty , f la ri ng , e tc .). R ou tin e ED L op er at io ns in cl ud e ch em ic al s m an ag em en t. oi l f ilt ra tio n, te st in g, r ep la ce m en t, et c. T he se o pe ra tio ns a re c ur re nt ly im pl em en te d by v ar io us d ep ar tm en ts a nd th er ef or e w ou ld b en ef it fr om be in g ce nt ra liz ed POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 66-67 3.3.2. Activity 2: Measures to Reduce or Eliminate Releases from Intentional Production and Use 3.3.2.1. Compliance and Objectives under SC This activity is consistent with Article 3 of the Stockholm Convention according to which Lebanon shall: • Prohibit or eliminate the production and use, import and export of Annex A chemicals, and production and use of Annex B chemicals; • Guarantee that Annex A and B chemicals are imported only for the purpose of environmentally sound disposal; and • Protect human and environmental health via measures to minimize or prevent releases. 3.3.2.2. Background Information and Findings Lebanon does not intentionally produce PCBs. Twenty seven samples from EDL transformers and substations were collected and analyzed to support the PCB inventory. The results included the identification of (a) seven in-service transformers at the Jieh power plant containing 37,115 kg of PCB oil, and (b) records showing 13 tonnes of PCB oil imported in 2002; these findings represent the only known cases of intentional PCB use. This activity seeks to conduct a comprehensive inspection of EDL transformers to identify other transformers that may be using PCB oil. The proposed action plan will also locate and phase-out the 13 tonnes of PCBs imported that were imported in 2002. There are no real measures in place to enforce legislation prohibiting the use, production or formulation of POPs pesticides. Such measures control only entry and exit of these chemicals through banning of import and export (Decision 94/1), thus rendering smuggled and locally formulated or produced POPs pesticides practically 'legal'. However, due to the absence of such activities in the country, as found by the preliminary POPs Pesticides Inventory, no obligations are necessary on this account. It is also recommended that amendments be made to Decision 94/1 to include the prohibition of use, production and formulation of POPs pesticides. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon T ab le 3 .5 A ct iv it y 2: M ea su re s to R ed uc e or E li m in at e R el ea se s fr om I nt en ti on al P ro du ct io n an d U se D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 2. 1: C on du ct a C om pr eh en si ve In sp ec tio n of T ra ns fo rm er s to Id en tif y Po te nt ia l R el ea se s of P C Bs N ot a ll su bs ta tio ns w er e vi si te d fo r 14 . S am pl e an d an al yz e di el ec tr ic o il in in s er vi ce (a ) p ow er , ( b) M oE in c oo rd in at io n U SD 1 ,8 00 ,0 00 ST ( by 2 01 0) th e in ve nt or y an d no t a ll tr an sf or m er s tr an sm is si on a nd (c ) d is tr ib ut io n tr an sf or m er s us in g: w ith E D L an d ot he r w er e te st ed fo r PC Bs . T he • D en si ty te st s (e as y to ol k it) pr iv at e po w er u til iti es co m pr eh en si ve in sp ec tio n w ill e nt ai l • C hr om at og ra ph y an al ys is vi si tin g al l t he s ub st at io ns in L eb an on 15 . E ns ur e ze ro P C B re le as e fr om in u se tr an sf or m er s: fo llo w U N EP M oE /E D L U SD 2 0, 00 0 ST ( by 2 01 0) to in ve st ig at e po ss ib le r el ea se s of P C Bs pr oc ed ur es fo r po ss ib le P C B le ak s fr om in u se tr an sf or m er s. T he 16 . I de nt if y an d im pl em en t m iti ga tio n m ea su re s fo r le ak in g in s er vi ce M oE U SD 2 0, 00 0 ST ( by 2 01 0) in sp ec tio n sh ou ld c ov er E D L as w el l PC B co nt ai ni ng tr an sf or m er s as o th er p ri va te p ow er u til iti es . It w ill id en tif y an d re co m m en d th e m os t su ita bl e m iti ga tio n m ea su re s fo r le ak in g tr an sf or m er s. A ct io n 2. 2: M on ito r pa st a nd c ur re nt o il im po rt s O ff ic ia l r ec or ds fr om L eb an es e 17 . I ns tr uc t C us to m s to b e m or e vi gi la nt in r el at io n to o il im po rt s M oE a nd o th er m in is tr ie s U SD 6 ,0 00 ST cu st om s au th or iti es s ho w th at 1 3 (s ou rc e an d or ig in , p ro pe rt ie s, q ua nt iti es , e tc ). (I nd us tr y, In te ri or , E co no m y to nn es o f P C B oi l e nt er ed th e co un tr y 18 . I nv es tig at e th e fa te o f 1 3 to nn es o f P C B oi l i m po rt ed in 2 00 2 & T ra de ) U SD 3 ,6 00 ST in 2 00 2. T he o il w as im po rt ed b y a (n or th L eb an on ) pr iv at e bu ye r (p os si bl y in th e fo rm o f lu br ic at io n oi l) in th e no rt h. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 68-69 3.3.3. Activity 3: Production, Import and Export, Use, Stockpiles and Wastes of Annex A POPs Pesticides (Annex A, Part 1 Chemicals) Since the preliminary POPs Pesticides Inventory in Lebanon did not register production, use, import or export of these substances and has established the absence of their stockpiles and waste, no improvement of the current management and treatment practices of Annex A pesticides is deemed necessary. However, it is recommended that future actions be taken, within the country's financial and technical capacity, to strengthen the existing system for tracking POPs chemicals from entry to final use through inspection of pesticides outlets and distribution retailers, improvement of the customs categorization system to identify individual pesticides, and enforcement of reporting of POPs pesticides if identified. Additional efforts for improvement could include systematic monitoring of environmental POPs pesticides levels in order to confirm the findings of the inventory that these chemicals do not represent a true problem in Lebanon to the environment or human health. A national monitoring plan, including sampling and analysis requirements, has been developed and proposed in the preliminary Inventory, and is described in detail in section 3.3.16, Activity 3.3.16: Research, Development and Monitoring. 3.3.4. Activity 4: Production, Import and Export, Use, Identification, Labeling, Removal Storage and Disposal of PCBs and Equipment Containing PCBs (Annex A, part II chemicals) 3.3.4.1. Compliance and Objectives under SC Activity 3.3.4 seeks to formulate and implement a management plan for PCB containing equipment and waste products in a manner that is environmentally friendly and that will not harm public health. According to Article 6 of the Stockholm Convention, Lebanon must develop appropriate strategies for identifying products and articles in use. The article also recommends parties to handle, collect, transport and store the waste in an environmentally sound manner. Disposal must destroy or irreversibly transform the Persistent Organic Pollutant. 3.3.4.2. Background Information and Findings Building on Activity 3.3.2, this activity aims to identify all the sources of PCB release and use in Lebanon by developing a comprehensive inventory of PCBs. Appropriate removal, storage and disposal methods should then be implemented. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon T ab le 3 .6 A ct iv it y 4: P ro du ct io n, I m po rt a nd E xp or t, U se , I de nt if ic at io n, L ab el in g, R em ov al S to ra ge a nd D is po sa l o f P C B s an d E qu ip m en t C on ta in in g P C B s (A nn ex A , p ar t II c he m ic al s) D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 4. 1: P re pa re a C om pr eh en si ve In ve nt or y of P C Bs in L eb an on T he in ve nt or y sh ou ld a ss es s an d 19 . S ec ur e fu nd s to im pl em en t a c om pl et e in ve nt or y (b ui ld in g on th e M oE , U N D P U SD 3 ,0 00 ST in ve st ig at e PC B pr od uc ts a nd pr el im in ar y in ve nt or y) (2 00 6 0 8) eq ui pm en t i n se ve ra l s ec to rs in cl ud in g 20 . C ol le ct a nd a na ly ze s am pl es fr om : M oE , C A S U SD 1 50 ,0 00 ST en er gy . T he C en tr al A dm in is tr at io n of C lo se d ap pl ic at io ns St at is tic s ca n pr ov id e su pp or t i n ca se O pe n ap pl ic at io ns (2 00 6 0 8) su rv ey s ar e ne ed ed (s ee A ct io n 2. 1) . Pa rt ia lly c lo se d ap pl ic at io ns 21 . D et er m in e th e ac tu al n um be r of tr an sf or m er s th at w ou ld r eq ui re M oE , E D L, o th er N o di re ct c os t ST ph as e ou t a nd d ec om m is si on in g po w er u til iti es (2 00 6 0 8) A ct io n 4. 2: D ev el op a P la n fo r Ph as in g ou t P C B T ra ns fo rm er s ED L an d ot he r po w er u til iti es o w n an d 22 . D is cu ss w ith E D L an d ot he r po w er u til iti es a lte rn at iv e op tio ns fo r M oE , E D L U SD 5 0, 00 0 ST op er at e m an y tr an sf or m er s th at ph as in g ou t P C B co nt ai ni ng tr an sf or m er s (e .g ., re tr o fil lin g, (T ec hn ic al A ss is ta nc e) co nt ai n (o r ha ve c on ta in ed ) P C B oi l. de co m m is si on in g an d re pl ac em en t, en d of s er vi ce ) t o co m e up w ith a T he a ct io n w ill d ev el op a nd im pl em en t ph as e ou t p la n a ph as e ou t p la n fo r PC B co nt ai ni ng 23 . S ec ur e fu nd s fo r th e gr ad ua l p ha se o ut a nd r ep la ce m en t o f i n se rv ic e M oE , G EF U SD 3 ,0 00 M T tr an sf or m er s an d ot he r PC B eq ui pm en t tr an sf or m er s by 2 02 5 id en tif ie d du ri ng th e in ve nt or y. A ct io n 4. 3: D ev el op a nd Im pl em en t a P la n fo r th e D is po sa l o f P C B O il an d Eq ui pm en t A p la n fo r th e di sp os al o f P C B oi l a nd 24 . I de nt if y PC B de st ru ct io n fa ci lit ie s fo r th e tr an sp or t a nd d is po sa l o f M oE Se e Ta sk 2 2 ST eq ui pm en t s ho ul d ta ke in to c on sid er at io n PC Bs a nd P C B co nt am in at ed e qu ip m en t th e so ci al a nd e co no m ic c on di tio ns o f 25 . S ee k en do rs em en t f or d is po sa l p la n M oE U SD 3 ,0 00 M T th e go ve rn m en t a nd p ri va te 26 . S ec ur e fu nd s fo r th e di sp os al o f P C B oi l a nd e qu ip m en t M oE , G EF U SD 3 ,0 00 M T es ta bl is hm en ts . T he p la n w ill in ve st ig at e 27 . I m pl em en t & m on ito r th e di sp os al p la n Pe r de cr ee (T as k 1 1) U SD 1 ,5 00 ,0 00 LT (b y 20 25 ) th e m os t c os t ef fe ct iv e di sp os al o pt io ns an d id en tif y th e m os t s ui ta bl e de st ru ct io n an d di sp os al s ite . POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 70-71 3.3.5 Activity 5: Production, Import and Export, Use, Stockpiles and Wastes of DDT (Annex B chemicals) if used in the Country An action plan for DDT has not been developed due to no production, use, import or export and absence of stockpiles and wastes of DDT in the country, as recorded by the preliminary POPs Pesticides Inventory. Similarly to Annex A pesticides (section 3.3.3), DDT can be included in the strengthening of the existing tracking system for POPs chemicals, if this activity is undertaken. 3.3.6. Activity 6: Register for Specific Exemptions and the Continuing Need for Exemptions Lebanon did not register any exemptions to Annex A and Annex B chemicals, and is not likely to do so in the future. Therefore, no action plan has been developed to address this issue under Article 4 of the SC. This Activity will be elaborated in the future in the event that Lebanon files for exemption. 3.3.7. Action Plan 7: Measures to Reduce Releases from Unintentional Production 3.3.7.1. Compliance and Objectives under SC The aim of this activity is to take action pursuant to Article 5 of the convention to reduce unintentional releases of PCDD/PCDF, HCB and PCBs formed as a by-product of certain industrial processes. According to Article 5 of the Convention, Lebanon shall: • Develop and implement an action plan designed to identify, characterize and address the release of these chemicals • Promote the application of available, feasible and practical measures • Require the use of substitute or modified materials, products and processes 3.3.7.2. Background Information and Findings There are few industrial establishments in Lebanon that could unintentionally produce POPs. Foremost among them are medical waste incinerators which typically lack quenchers; some surveyed industries lack Air Pollution Control (APC) systems such as brick and glass. Emission releases occur mainly from uncontrolled processes such as open dumps and open fires of solid waste, so widespread in the country. PCDD/PCDF has minute releases at some facilities such as secondary copper and secondary aluminum production that respectively have a yearly production of 85 tons and an annual release of PCDD/PCDF of 0.0252 g TEQ/annum in residue for copper and a yearly production of 955 tons aluminum with a release of 0.138 g TEQ/annum of PCDD/PCDF in the air and 0.38 g TEQ/annum in the residue. This action plan ensures the investigation of several industrial source categories and the introduction of BAT/BEP for all sources. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon T ab le 3 .7 A ct io n P la n 7: M ea su re s to R ed uc e R el ea se s fr om U ni nt en ti on al P ro du ct io n D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 7. 1: P ro m ot e B A T /B EP T ec hn iq ue s at k no w n es ta bl is hm en ts u nd er S ou rc es II a nd II I a nd o bl ig e th em a t f ut ur e So ur ce s II Po ss ib le u ni nt en tio na l e m is si on a nd 28 . M ed ic al W as te in ci ne ra tio n (s ou rc e II ) M oE , M oP H U SD 7 50 ,0 00 M T co nt am in at io n of P C Bs a nd D io xi ns • Id en tif y th e lo ca tio n an d st at us (w as te in ci ne ra te d, q ua nt ity , A PC s, e tc .) (C A S: S ur ve y) ca n oc cu r fr om a t l ea st e ig ht a ct iv iti es of e xi st in g m ed ic al w as te in ci ne ra to rs in L eb an on (b as ed o n M oP H st ud y) in L eb an on : • Pr om ot e go od w as te m an ag em en t p ra ct ic es in h os pi ta ls (e .g ., w as te 1) M ed ic al w as te in ci ne ra tio n m in im iz at io n, s eg re ga tio n at th e so ur ce b y w as te ty pe , w as te s re cy cl in g) . 2) Se co nd ar y co pp er p ro du ct io n • Pr om ot e ap pr op ri at e tr ea tm en t o f b ot to m a sh es a nd r es id ue s fr om fl ue 3) Se co nd ar y al um in um p ro du ct io n ga s t o re du ce P C D D /P C D F re le as es in to th e en vi ro nm en t d ur in g in ci ne ra tio n 4) Pa pe r bl ea ch in g • C on si de r be st a va ila bl e te ch ni qu es in in ci ne ra to rs to r ed uc e em is si on s; 5) Le ad p ro du ct io n re m ov e ch lo ri na te d pr od uc ts a nd h ea vy m et al s, e ns ur e go od c om bu st io n 6) Te xt ile d ye in g w ith c hl or an il co nd iti on s (t ur bu le nc e, te m pe ra tu re , r es id en ce ti m e) 7) Le at he r dy ei ng w ith c hl or an il • B an in ci ne ra tio n of P V C m ad e m at er ia ls a nd p ro m ot e it s re pl ac em en t 8) O pe n bu rn in g of w as te w he n po ss ib le b y ot he r no n ch lo ri na te d pl as tic s 9) T ra ns po rt at io n • Pr ov id e al te rn at iv es to in ci ne ra tio n: s te ri liz at io n (s te am , a dv an ce d st ea m , dr y he at ), m ic ro w av e tr ea tm en t, al ka lin e hy dr ol ys is , o r b io lo gi ca l t re at m en t, ea ch fo llo w ed b y la nd fil lin g. 29 . S ec on da ry c op pe r pr od uc tio n (s ou rc e II ) M oE U SD 1 0, 00 0 ST • Ex pl or e av ai la bl e m et ho ds fo r em is si on r ed uc tio n • C on du ct a ud its a t e xi st in g pl an ts in L eb an on a nd e va lu at e re co m m en de d so lu tio ns s uc h as : p re so rt in g, c le an in g fe ed m at er ia ls , m ai nt ai ni ng te m pe ra tu re s ab ov e 85 0° C , u til iz in g af te rb ur ne rs w ith r ap id q ue nc hi ng , ac tiv at ed c ar bo n ad so rp tio n an d fa br ic fi lte r de d us tin g. 30 . S ec on da ry a lu m in um p ro du ct io n (s ou rc e II ) M oE U SD 1 4, 00 0 ST • Ex pl or e av ai la bl e m et ho ds fo r em is si on r ed uc tio n • C on du ct a ud its a t e xi st in g pl an ts in L eb an on a nd e va lu at e re co m m en de d so lu tio ns s uc h as : h ig h te m pe ra tu re a dv an ce d fu rn ac es , o il a nd c hl or in e fr ee fe ed s (if a lte rn at iv es a re a va ila bl e) , a ft er bu rn er s w ith r ap id q ue nc h, ac tiv at ed c ar bo n ad so rp tio n an d de d us tin g fa br ic fi lte rs . POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 72-73 D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 7. 1: P ro m ot e B A T /B EP T ec hn iq ue s at k no w n es ta bl is hm en ts u nd er S ou rc es II a nd II I a nd o bl ig e th em a t f ut ur e So ur ce s II 31 . S ec on da ry le ad p ro du ct io n (s ou rc e II I) M oE 17 ,5 00 U SD ST • Ex pl or e av ai la bl e m et ho ds fo r em is si on r ed uc tio n • C on du ct a ud its a t e xi st in g pl an ts in L eb an on a nd e va lu at e re co m m en de d so lu tio ns s uc h as : t he u se o f p la st ic f re e an d oi l fr ee fe ed m at er ia l, hi gh fu rn ac e te m pe ra tu re s ab ov e 85 0° C , e ffe ct iv e ga s co lle ct io n, a fte rb ur ne rs an d ra pi d qu en ch , a ct iv at ed c ar bo n ad so rp tio n, a nd d e du st in g fa br ic fi lte rs . 32 . T ex til e an d le at he r dy ei ng a nd fi ni sh in g (s ou rc e II I) M oE 10 0, 00 0 U SD ST • C on du ct a s ur ve y to id en tif y si te s of p ro du ct io n of te xt ile a nd le at he r us in g ch lo ri na te d dy es in L eb an on • C on du ct a s tu dy to a ss es s po ss ib le a lte rn at iv e m et ho ds o f e m is si on s re du ct io n • C on du ct a ud its a t e xi st in g pl an ts in L eb an on a nd e va lu at e re co m m en de d so lu tio ns a t i de nt ifi ed in du st ri es s uc h as : R ed uc e th e us e of d io xi n co nt am in at ed b io ci de s an d dy es tu ffs in th e pr od uc tio n ch ai ns fo r le at he r an d te xt ile p ro du ct io n. • Pr om ot e al te rn at iv e ch em ic al s or lo w c on ce nt ra tio ns o f c he m ic al s us ed su ch a s pe nt ac hl or op he no l a nd c hl or on itr of en (f or e xa m pl e, d is til le d or o th er w is e pu ri fie d ch em ic al s) . 33 . O pe n bu rn in g of s ol id w as te (s ou rc e II I) : S ee T as k 35 34 . T ra ns po rt at io n (S ou rc e II I) C us to m s, M oI M 20 ,0 00 U SD ST • Pr om ot e th e us e of th e ca ta ly st a t n ew im po rt ed c ar s A ct io n 7. 2: In tr od uc e En vi ro nm en ta lly S ou nd W as te M an ag em en t T ec hn ol og ie s to S to p th e U ni nt en tio na l R el ea se o f P C Bs fr om U nc on tr ol le d Bu rn in g of M un ic ip al S ol id W as te a nd fr om M ed ic al W as te In ci ne ra to rs A ct io n 7. 1: P ro m ot e B A T /B EP T ec hn iq ue s at k no w n es ta bl is hm en ts u nd er S ou rc es II a nd II I a nd o bl ig e th em a t f ut ur e So ur ce s II M an y co m m un iti es c on tin ue to p ra ct ic e 35 . E nd or se a nd im pl em en t s ol id w as te m an ag em en t l aw : M in is tr y of In te ri or / M oE $1 00 ,0 00 fo r t ec hn ic al M T B y 20 10 op en b ur ni ng o f M SW ; t he G oL • Pr ep ar e an in ve nt or y of o pe n du m pi ng s ite s st ud y. Im pl em en ta tio n (c on di tio na l o n sh ou ld b an o pe n bu rn in g of M SW a nd • Id en tif y ne ed s fo r du m p cl os ur e an d m ea su re s to d et er o pe n bu rn in g co st s de pe nd s on fin di ng a lte rn at iv e pr ov id e vi ab le a lte rn at iv e so lu tio ns in • Id en tif y m os t c os t e ffe ct iv e m ea su re s fo r du m ps ite r eh ab ili ta tio n pr op os ed s ol ut io ns so lu tio ns ) al l s ix G ov er no ra te s. T he d is po sa l o f • Se e ac tio n 13 .2 (T as k 68 ) o n aw ar en es s ra is in g ho sp ita l w as te in th e M SW s tr ea m 36 . B an th e co d is po sa l o f m ed ic al w as te w ith th e m un ic ip al w as te s tr ea m Sy nd ic at e of H os pi ta ls / Se e 28 ST B y 20 10 m us t a ls o be b an ne d. by e nc ou ra gi ng h os pi ta ls to a do pt c le an er te ch no lo gi es fo r th e M oE / P ri va te S ec to r / N G O s tr ea tm en t a nd d is po sa l o f m ed ic al w as te (e .g ., au to cl av in g) POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3.3.8. Activity 8: Measures to Reduce Releases from Stockpiles and Wastes 3.3.8.1. Compliance and Objectives under SC According to Article 6 of the Stockholm Convention, Lebanon shall: • Identify wastes sites contaminated with chemicals listed in Annex C; and • Manage wastes sites contaminated with chemicals listed in Annex C. 3.3.8.2. Background Information and Findings There are many uncontrolled dumpsites in the country including at least seven large ones and hundreds of small scale village-level dumpsites. Lebanon's two sanitary landfills (Naameh and Zahle) lack effective leachate treatment facilities. Random and routine burning of solid waste results in major Dioxins/Furans releases. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 74-75 T ab le 3 .8 . A ct iv it y 8: M ea su re s to R ed uc e R el ea se s fr om S to ck pi le s an d W as te s D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 8. 1. : R ed uc e R el ea se s fr om b ur ni ng o f W as te s at O pe n D um ps (A ct iv ity 3 .3 .7 ) Se e Ta sk 2 9 Se e Ta sk 2 9 M oE N o di re ct c os t Se e Ta sk 2 9 A ct io n 8. 2. : A ct io ns fo r Id en tif yi ng S to ck pi le s & W as te s ha ve b ee n A dd re ss ed in S ec tio n 3. 3. 11 T as k 1. 48 a nd 1 .4 9 N o st oc kp ile o r w as te id en tif ic at io n R ef er to T as ks 5 2 an d 53 ; If s to ck pi le s or w as te s of P O Ps p es tic id es a re M oA , M oE Se e ta sk s 52 a nd 5 3 C on di tio na l w as p os si bl e du ri ng th e pr oc es s of th e ev er fo un d, th en p ro pe r ac tiv iti es w ill b e de ve lo pe d fo r re du ci ng r el ea se s Pr el im in ar y Pe st ic id es In ve nt or y. fr om th es e st oc kp ile s or w as te s C om pr eh en si ve s ur ve ys a re n ee de d fo r th e co nf ir m at io n of th e ab se nc e or pr es en ce o f w as te a nd s to ck pi le s. A ct io n 8. 3. : R ed uc e R el ea se s fr om P C B co nt ai ni ng T ra ns fo rm er s in Z ou k & B au ch ri eh a s w el l a s & O th er P ot en tia l S ite s an d Su bs ta tio ns U nd er A rt ic le 6 o f t he S C , p ar tie s ar e 37 . S am pl e an d an al yz e di el ec tr ic fl ui ds in Z ou k an d B au ch ri eh to M oE , E D L Se e Ta sk 2 0 ST re qu ir ed to im pl em en t m ea su re s to de te rm in e si ze o f s to ck pi le re du ce o r el im in at e re le as es fr om 38 . S eg re ga te P C B tr an sf or m er s f ro m P C B fr ee tr an sf or m er s (B au ch ri eh o nl y) ED L N o di re ct c os ts ST st oc kp ile s an d w as te s. T he s tr at eg y 39 . L ab el a nd s to re s af el y ou t of s er vi ce P C B co nt ai ni ng tr an sf or m er s in ED L U SD 1 5, 00 0 ST pr op os ed to r ed uc e re le as es fr om Z ou k an d B au ch ri eh u nt il an a pp ro pr ia te d is po sa l m et ho d is d ec id ed PC Bs in cl ud es fo ur s te ps 40 . D et ec t a nd c on ta in p ot en tia l o il sp ill s fr om le ak in g ou t of s er vi ce ED L U SD 2 0, 00 0 ST PC B co nt ai ni ng tr an sf or m er s POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3.3.9. Strategy: Identification of Stockpiles, Articles in Use and Wastes 3.3.9.1. Compliance and Objectives under SC Pursuant to Article 6, the goal of this strategy is to develop procedures that will facilitate the identification of POPs present in unidentified stockpiles and equipment still in use. 3.3.9.2. Background Information and Findings The national inventory determined several PCB stockpiles. The inventories did not find stockpiles of dioxins or pesticides. PCB oil in out-of-service transformers in Zouk was confirmed based on the information provided on the plates and through testing. Articles in use (such as the Jieh power plant transformers) and irreparable transformers containing and contaminated with PCB at the Bauchrieh repair shop were identified using the density test and laboratory analysis. There have been no attempts to identify other PCB applications outside the energy sector. Potential Dioxin contaminated sites are mainly at sites where open dumping of waste and open dumping of wastewater are occurring randomly and illegally. In addition, potentially contaminated sites include landfills such as Naameh, Tripoli, Zahleh where leachate is not treated and sites at preliminary wastewater treatment plants or plants with operation and maintenance problems such as the wastewater treatment plants at the Caza of Hasbaya. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 76-77 T ab le 3 .9 S tr at eg y: I de nt if ic at io n of S to ck pi le s, A rt ic le s in U se a nd W as te s D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 9. 1: U se S ur ve ys to Id en tif y A rt ic le s in U se (i f a ny ) T ho ro ug h in sp ec tio n su rv ey s of 41 . U se fi nd in gs fr om in sp ec tio n su rv ey s of p es tic id es o ut le ts a nd M oA 5, 00 0 U SD ST pe st ic id es r et ai le rs a nd o ut le ts c an b e di st ri bu tio n re ta ile rs to id en tif y ar tic le s in u se if a ny us ed to id en tif y an y re m ai ni ng a rt ic le s in u se in th e co un tr y A ct io n 9. 2: U pd at e In ve nt or y Fi nd in gs R el at ed to S to ck pi le s So fa r st oc kp ile s ha ve b ee n fo un d on ly 42 . I nv en to ry s ho ul d al so in ve st ig at e st oc kp ile s, i. e. , P C B oi l n ot in u se ED L an d ot he r po w er u til iti es S ee T as k 20 ST in Z ou k po w er p la nt a nd B au ch ri eh (s ee T as k 20 a nd T as k 37 ) re pa ir s ho p (s ee S ec tio n 2. 3. 5) . T hi s 43 . L ab el n ew s to ck pi le s th at m ay b e di sc ov er ed A te ch ni ca l c om m itt ee w ill b e N o di re ct c os t ST ac tio n w ill in vo lv e fu rt he r in ve st ig at io n fo rm ed w ith M oE a s Fo ca l of s ub st at io ns a t o th er p ow er u til iti es Po in t f or d at a co ns ol id at io n su ch a s th e Li ta ni R iv er A ut ho ri ty a nd th e Q ad is ha p la nt . A ct io n 9. 3: In sp ec t I nd us tr ie s w he re P C B Pr od uc ts & P C B co nt ai ni ng E qu ip m en t m ay b e U se d Se ve ra l i nd us tr ie s co ul d ha ve o ld P C B 44 . T ra in in sp ec to rs o n ho w to d et ec t p ot en tia lly c on ta m in at ed e qu ip m en t M oE U SD 2 0, 00 0 ST oi l s to ck pi le s an d/ or c on ta m in at ed 45 . L ab el s to ck pi le s id en tif ie d at in du st ri es a nd e xe rc is e co nt ai nm en t M oE a nd s pe ci al iz ed fi rm $5 0, 00 0 fo r te st in g ST eq ui pm en t n ot in u se o n th ei r pr em is es . pr oc ed ur es an d la be lin g St oc kp ile as se ss m en t T hi s ac tio n se ek s to u nc ov er n ew sh ou ld b e (in du st ri al ) s to ck pi le s, if a ny . T he co m pl et ed b y in sp ec tio n te am w ill n ee d to b e tr ai ne d 20 08 to id en tif y th e di ffe re nt s ou rc es , pr od uc ts a nd e qu ip m en t c on ta m in at ed w ith P C Bs POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3.3.10. Activity: Manage Stockpiles and Appropriate Measures for Handling and Disposal of Articles in Use After deciding on the tools needed to identify stockpiles and contaminated sites in Lebanon (Activity 3.3.9), this activity focuses on identifying appropriate measures to manage, handle and destroy stocks and articles in use, remedy contaminated sites and other hot spots of concern to public health and the environment. The objectives of this activity are to: • Promote the safe elimination of existing stocks • Identify and de-contaminate sites that are polluted with POPs chemicals • Sample and monitor environmental matrices (air, water, soil, sediments) and biota (food, occupation). 3.3.10.1. Background Information and Findings As explained earlier in Section 3.3.9, PCB stockpiles were found in the Zouk power plant (out-of-service transformers) and Jieh power plant (in-use transformers), as well as the Bauchrieh repair shop. The stockpiles are not stored in an environmentally safe manner and are usually kept on site. Contaminated in-use transformers have not been labeled. Contaminated sites were never sampled, nor remedied. Contaminated sites will need to be sampled, and all contaminated oil on site will need to be disposed of in an environmentally sound manner. According to the preliminary PCB inventory, treatment and disposal of contaminated articles and equipment should occur abroad (most probably in Europe). The following activity will attempt to achieve compliance with Article 6 of the Stockholm Convention. Because the findings related to POPs pesticides were insignificant, the following actions are recommendations (not obligations) and should also be addressed: • Implement a national sampling and analysis program for identification of sites contaminates with POPs pesticides; • Develop or use proposed plan (Preliminary POPs Pesticides Inventory) to conduct screening and detection of contaminated sites; • If contaminated sites are identified, then develop a remediation plan that assesses remediation options fitting to Lebanese circumstances, and develop legislation on POPs pesticides/chemicals polluted sites; • Perform an assessment of potential POPs pesticides/chemicals contaminated media to avoid its re-use (especially soil). POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 78-79 T ab le 3 .1 0 A ct iv it y 10 : M an ag e St oc kp il es a nd A pp ro pr ia te M ea su re s fo r H an dl in g an d D is po sa l o f A rt ic le s in U se D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 10 .1 : T re at /D is po se P C B O il as w el l a s Ir re pa ra bl e PC B co nt am in at ed T ra ns fo rm er s in a n En vi ro nm en ta lly S ou nd M an ne r A ll PC B st oc kp ile s an d ar tic le s in u se 46 . I de nt if y th e m os t s ui ta bl e di sp os al o pt io n (s ee T as k 24 2 7) M oE / M oE W C on so lid at e w ith T as k 25 ST b y 20 08 th at w er e lis te d in th e in ve nt or y w ill 47 . D is po se o f P C B oi l a nd c on ta m in at ed e qu ip m en t a cc or di ng to th e M oE / M oE W Se e Ta sk 2 7 M T B y 20 12 ha ve to b e tr ea te d an d di sp os ed fe as ib ili ty s tu dy fi nd in gs pu rs ua nt to U N EP g ui de lin es A ct io n 10 .2 : I m pr ov e Pr oc ed ur es fo r H an dl in g T ra ns fo rm er s at E D L W ar eh ou se in B au ch ri eh A ll ED L da m ag ed tr an sf or m er s 48 . O rg an iz e th e ex is tin g re pa ir & m ai nt en an ce r eg is tr y an d re vi ew o ld ED L U SD 1 ,5 00 ST co nv er ge to B au ch ri eh fo r re pa ir. tr an sa ct io ns . St ar tin g in 2 00 6 T ra ns fo rm er s m ay te nd to le ak d ur in g 49 . T es t o il & s cr ap m et al b ef or e au ct io ni ng (s ee T as k 48 ) ED L U SD 1 ,5 00 ST tr an sp or t t o an d fr om th e re pa ir s ho p. St ar tin g in 2 00 6 Ir re pa ra bl e tr an sf or m er s ar e so ld a s sc ra p m et al . T he re a re n o re co rd s of th e fa te o f t he s cr ap m et al POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3.3.11. Strategy: Identification of Contaminated Sites (Annex A, B and C Chemicals) and Remediation in an Environmentally Sound Manner 3.3.11.1. Objective and Compliance under SC This activity falls under the requirements of Article 6 of the Stockholm Convention. Its main objectives are to: • Identify contaminated sites; and • Propose alternative treatment methods that aim at reducing and eliminating the release of Dioxins/Furans. 3.3.11.2. Background Information and Findings Since the three preliminary inventories could only identify sites that were potentially contaminated with POPs, it is important to investigate these potential sites to ascertain the presence or not of a stockpile. Such an action plan has been developed for POPs pesticides in the preliminary inventory, along with suggested remediation options for contaminated media. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 80-81 T ab le 3 .1 1 St ra te gy : I de nt if ic at io n of C on ta m in at ed S it es (A nn ex A , B a nd C C he m ic al s) a nd R em ed ia ti on in a n E nv ir on m en ta ll y So un d M an ne r D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 11 .1 : D el in ea te D io xi ns /F ur an s C on ta m in at ed S ite s Id en tif ic at io n an d sp ec ifi ca tio n of s ite s 50 . C on du ct a p re lim in ar y pi lo t i nv es tig at io n to id en tif y ho t s po ts M oE (C A S: s ur ve y) U SD 2 0, 00 0 ST co nt am in at ed w ith D io xi ns /F ur an s 51 . S am pl in g an d an al ys is a t c on ta m in at ed s ite s (s oi ls w ith d io xi ns ) M oE U SD 1 00 ,0 00 ST A ct io n 11 .2 : I de nt if y, A ss es s an d R em ed ia te P O Ps P es tic id es C on ta m in at ed S ite s Im pl em en ta tio n of a n at io na l s am pl in g, 52 . P er fo rm a n as se ss m en t o f p ot en tia l P O Ps p es tic id es c on ta m in at ed s ite s M oE U SD 2 00 ,0 00 M T an al ys is a nd r em ed ia tio n pl an fo r th e to a vo id r e us e of c on ta m in at ed m ed ia (p ar tic ul ar ly s oi l) by m ak in g us e de te ct io n an d m an ag em en t o f P O Ps of th e pr op os ed p la n (in th e Pr el im in ar y PO Ps P es tic id es In ve nt or y) to pe st ic id es c on ta m in at es s ite s co nd uc t s cr ee ni ng a nd d et ec tio n of c on ta m in at ed s ite s 53 . I f c on ta m in at ed s ite s ar e id en tif ie d, th en d ev el op a nd im pl em en t a m M oE U SD 3 50 ,0 00 LT ap pr op ri at e r em ed ia tio n pl an fo r Le ba no n, a nd d ev el op le gi sl at io n th at ad dr es se s PO Ps p es tic id es ' po llu te d si te s A ct io n 11 .3 : C ol le ct a nd A na ly ze S oi l a nd G ro un dw at er S am pl es fr om e ac h Po te nt ia lly C on ta m in at ed P ow er P la nt & S ub st at io n to D et er m in e Ex te nt o f C on ta m in at io n, if a ny T hi s ac tio n ai m s to in ve st ig at e PC B 54 . C ol le ct & a ss es s so il sa m pl es fr om e ac h po te nt ia lly c on ta m in at ed M oE , E D L U SD 2 0, 00 0 ST co nt am in at io n in w at er b od ie s an d po w er p la nt a nd s ub st at io n 20 06 2 00 7 so il ne ar h ot sp ot s (e .g . s ub st at io ns h it 55 . C ol le ct & a ss es s w at er s am pl es fr om e ac h po te nt ia lly c on ta m in at ed Sp ec ia liz ed la bo ra to ri es in U SD 2 0, 00 0 ST by a ir s tr ik es ) si te s ne ar p ow er p la nt a nd s ub st at io n us in g qu al ity a ss ur an ce a nd q ua lit y co lla bo ra tio n w ith M oE a nd 20 06 2 00 7 co nt ro l m ea su re s (Q A /Q C ) ED L A ct io n 11 .4 : D ec on ta m in at e th e W el l a t t he B au ch ri eh R ep ai r Sh op a nd th e Su rr ou nd in g Pe ri m et er if w el l i s fo un d to C on ta in P C Bs (> 50 p pm ) Te st s co nd uc te d in 1 99 5 an d 20 00 56 . C on du ct a c om pl et e en vi ro nm en ta l a ss es sm en t o f t he w el l a nd M oE U SD 1 5, 00 0 ST 2 00 6 sh ow ed P C B in d is po sa l w el l i n de te rm in e w he th er o r no t t he w el l c on st itu te s a st oc kp ile B au ch ri eh r ep ai r sh op . E D L ha s si nc e 57 . D ev el op a nd im pl em en t a r em ed ia tio n pl an if fo un d to c on ta in P C Bs M oE , M oE W U SD 4 ,5 00 ,0 00 ST 2 00 7 cl os ed th e w el l. T he s ite h ow ev er in a pp re ci ab le a m ou nt s re m ai ns a p ot en tia l h ot sp ot a nd s ho ul d be r em ed ie d to p re ve nt g ro un dw at er co nt am in at io n. A ct io n 11 .5 : E xp lo re th e fe as ib ili ty o f d ec om m is si on in g th e B au ch ri eh R ep ai r Sh op (H & S Im pa ct s to o H ig h) T he B au ch ri eh r ep ai r sh op is lo ca te d 58 . A ss es s th e fe as ib ili ty o f r el oc at in g an d de ce nt ra liz in g th e re pa ir ED L, M oE U SD $ 20 ,0 00 ST 2 00 8 in a h ig hl y ur ba ni ze d re si de nt ia l a re a sh op /w ar eh ou se (s ev er al h ou se s ar e ad ja ce nt to th e si te ). 59 . S ec ur e fu nd s to : ED L U SD 1 00 ,0 00 M T Pu bl ic h ea lth a nd s af et y is su es a re v er y • Im pl em en t r el oc at io n pl an O R al ar m in g (in ha la tio n of o il fu m es m ay • U pg ra de e xi st in g w ar eh ou se to m ee t b as ic e nv ir on m en ta l a nd H & S co nt ai n PC Bs ) st an da rd s POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3.3.12. Activity 12: Facilitating or Undertaking Information Exchange and Stakeholder Involvement 3.3.12.1. Objective and Compliance under SC According to the Article 9 of the Convention, each party shall facilitate or undertake the exchange of information relevant to the 1) reduction or elimination of the production, use and release of POPs and 2) alternatives to POPs including information relating to their risks as well as to their economic and social cost. This activity aims to: • Strengthen the link among relevant private and public stakeholders; • Organize and disseminate information among institutions; and • Establish a mechanism involving several stakeholders to gather data on all POPs chemicals. 3.3.12.2. Background Information and Findings Statistics on industrial production, emissions and waste stream is limited; similar data for informal industries is even more scant. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 82-83 T ab le 3. 12 A ct iv it y 12 : F ac il it at in g or U nd er ta ki ng I nf or m at io n E xc ha ng e an d St ak eh ol de r In vo lv em en t D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 12 .1 : I nf or m at io n ex ch an ge o n PO Ps w ith C on ve nt io n Se cr et ar ia t ( C S) C ur re nt ly a va ila bl e PO Ps r el at ed 60 . C om pi le in fo rm at io n on P O Ps a nd s ub m it it to th e C on ve nt io n M oE U SD 1 ,5 00 ST in fo rm at io n is k ep t c en tr al iz ed a t t he Se cr et ar ia t a nd th e in di ca te d EC C oo rd in at in g C en tr e U N D P/ M oE P O Ps O ff ic e, in cl ud in g 61 . R ec ei ve in fo rm at io n fr om th e C on ve nt io n Se cr et ar ia t a nd th e EC M oE N o di re ct c os t ST th e 3 Pr el im in ar y In ve nt or ie s, N at io na l C oo rd in at in g C en tr e an d co or di na te th e ac tiv iti es w ith in vo lv ed a nd Pr of ile , a nd th e H ea lth a nd co nc er ne d pa rt ie s En vi ro nm en t P ro fil e A ct io n 12 .2 : F or m a C en tr al iz ed D at ab as e fo r PO Ps C en tr al iz e in fo rm at io n re ga rd in g 62 . D ev el op a n on l in e da ta ba se th at p ro vi de s pr ot ec te d ac ce ss to d iff er en t M oE C A S U SD 5 0, 00 0 ST fa ci lit ie s em itt in g di ox in s/ fu ra ns st ak eh ol de rs a nd to th e pu bl ic A ct io n 12 .3 : E xc ha ng e In fo rm at io n on P O Ps C he m ic al s D ev el op a s ys te m o f d at a co lle ct io n 63 . I de nt if y al l i nf or m at io n so ur ce s (in st itu tio ns , i nd us tr ie s, la bo ra to ri es , M oE , M oA , M oI U SD 7 ,5 00 ST an d ex ch an ge a m on g di ffe re nt or ga ni za tio ns , m in is tr ie s, p es tic id e re ta ile rs ) st ak eh ol de rs A ct io n 12 .4 : P ro m ot e In vo lv em en t o f P ro du ce rs a nd R et ai le rs in D at a Lo gg in g In vo lv em en t o f p es tic id es r et ai le rs in 64 . I de nt if y an d in vo lv e al l p es tic id es ' p ro du ce rs a nd d is tr ib ut or s in d at a M oA , M oE U SD 2 ,0 00 ST da ta ba se lo gg in g an d in fo rm at io n lo gg in g ex ch an ge w ou ld im pr ov e th e ov er al l pe st ic id es m an ag em en t o n a na tio na l sc al e A ct io n 12 .5 : C om pu te ri ze E D L A rc hi ve s ED L fil es a nd r ec or ds a re s to re d fo r up 65 . E D L ne ed s to im pr ov e da ta m an ag em en t a nd a va ila bi lit y. F or e xa m pl e, ED L U SD 5 0, 00 0 M T to 1 5 ye ar s af te r w hi ch th ey a re u su al ly it m ay c on si de r ap pl yi ng fo r IS O 90 01 :2 00 0 (q ua lit y m an ag em en t s ys te m ) de st ro ye d. A rc hi ve s ys te m a t E D L is an d co m pu te ri zi ng it s ar ch iv es . pr im iti ve . O il sp ec s ar e us ua lly n ot re co rd ed w he n te nd er in g. A ct io n 12 .6 : P ro m ot e th e M oE li br ar y to S er ve a s a N at io na l I nf or m at io n C en te r fo r PO Ps C he m ic al s C ur re nt ly th e lib ra ry a t M oE is o pe n to 66 . O bt ai n th e ap pr ov al o f t he m in is te r an d D G to d es ig na te th e M oE M oE N o D ir ec t C os t ST th e pu bl ic d ur in g of fic ia l w or ki ng h ou rs . lib ra ry a s th e N at io na l I nf or m at io n C en te r on P O Ps in L eb an on To e ns ur e th e su st ai na bi lit y an d 67 . M ak e co pi es o f a ll PO Ps r el at ed m at er ia l t o be s to re d in M O E Li br ar y M oE U SD 1 ,0 00 ST in fo rm at io n ex ch an ge w ith th e pu bl ic fo r un re st ri ct ed d is cl os ur e it is re co m m en de d to p ro m ot e th e M oE lib ra ry a s a na tio na l i nf or m at io n ce nt er fo r PO Ps s in ce th e Pr oj ec t o ff ic e is lo ca te d at th e M oE POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3.3.13. Activity 13: Public Awareness, Information and Education 3.3.13.1. Objective and Compliance under SC This activity falls under the requirements of Article 10 of the Stockholm Convention and aims at the: 1) Promotion and facilitation of POPs awareness in policy and decision-making, provision of information to the public, development and implementation of awareness and education to specialized and especially minority target groups, public participation in addressing these issues, providing public access to information, training of specialized individuals, as well as Development and implementation of education and training programs at the national and international levels; and 2) Facilitation of POPs information provision at the national, sub-regional, and regional levels, via data sheets and reports, mass media, and information centers. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 84-85 T ab le 3 .1 3 A ct iv it y 13 : P ub li c A w ar en es s, I nf or m at io n an d E du ca ti on D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 13 .1 : C on du ct A w ar en es s & T ra in in g A ct iv iti es b y Pr ep ar in g In fo rm at iv e M at er ia l o r U se R ea dy M at er ia l f or In fo rm at io n D is se m in at io n & T ra in in g at D iff er en t L ev el s A w ar en es s ac tiv iti es s ho ul d in cl ud e 68 . T ar ge t u ni ve rs iti es : M oE H L, M oA U SD 1 60 ,0 00 2 Ev er y 3 ye ar s pr ep ar at io n, & d is tr ib ut io n of tr ai ni ng sp ec ifi ca lly 2 0% o f L eb an es e un iv er sit y le ve l s tu de nt s an d 70 % o f L eb an es e M oE , M oI , M oP H D ur at io n: 2 0 & a w ar en es s m at er ia ls a cc or di ng to un iv er si tie s/ hi gh er a ca de m ic in st itu tio ns th at a re g eo gr ap hi ca lly w or ki ng d ay s id en tif ie d ta rg et g ro up s, tr ai ni ng & w el l di st ri bu te d St ar t: 20 06 fo llo w u p ba se d on p re pa re d m at er ia ls , 69 . T ar ge t f ar m er s: M oA , M oE U SD 2 60 ,0 00 2 Ev er y 3 ye ar s m ed ia c ov er ag e fo r th e or ga ni ze d at le as t 1 00 0 fa rm er s (d ire ct tr ai ni ng ) & a m in im um o f 5 0% o f a gr ic ul tu ra l D ur at io n: 3 5 ev en ts , a nd o th er c om pl em en ta ry as so ci at io ns (b y co ve ra ge o f f ar m er n um be r & g eo gr ap hi ca l d is tr ib ut io n) , w or ki ng d ay s in fo rm at iv e aw ar en es s ac tiv iti es th at a re g eo gr ap hi ca lly w el l di st ri bu te d am on g C az as a nd a gr ic ul tu ra l St ar t: 20 06 ar ea s. M ai n fo cu s: O pe n bu rn in g of a gr ic ul tu ra l w as te . 70 . T ar ge t m un ic ip al iti es & th e ge ne ra l p ub lic : M oI M ,M oE U SD 7 90 ,0 00 2 Ev er y 3 ye ar s C ov er 7 0% o f L eb an es e m un ic ip al iti es w ith e ve n ge og ra ph ic al d is tr ib ut io n. D ur at io n: 2 5 M ai n fo cu s: S ol id w as te m an ag em en t, C ar m ai nt en an ce . w or ki ng d ay s St ar t: 20 06 71 . T ar ge t i nd us tr ie s: M oI , M oE U SD 2 28 ,0 00 3 Ev er y 3 ye ar s 10 0% o f a ll un in te nt io na l d io xi n pr od uc in g in du st rie s u nd er c at eg or ie s I I & II I D ur at io n: 2 0 w or ki ng d ay s St ar t: 20 06 72 . P ro vi de E D L te ch ni ci an s w ith a w ar en es s m at er ia l o n he al th a nd s af et y M oE /U N D P, E D L U SD 1 0, 00 0 ST gu id el in es fo r PC B ha nd lin g (3 4 d ay s) A ct io n 13 .2 : A nn ou nc e th e M in is tr y of E nv ir on m en t ( M oE ) P ub lic L ib ra ry to b e th e C en tr al In fo rm at io n So ur ce fo r PO Ps R el at ed D at a T he re c ur re nt c en tr al iz at io n of 73 . E ns ur e th e pu bl ic a va ila bi lit y of th is in fo rm at io n, & m ak e su re th at M oE U SD 1 0, 00 0 St ar t: O ct 2 00 5 re po rt in g at th e M oE w ou ld fa ci lit at e th e av ai la bi lit y of th is in fo rm at io n so ur ce is w el l kn ow n to th e En d: D ec 2 00 5 th e es ta bl is hm en t o f t he M oE li br ar y st ak eh ol de rs & g en er al p ub lic (6 6, 6 7) as a n at io na l P O Ps in fo rm at io n so ur ce 1 C os t i s in di ca te d pe r lib ra ry u pd at e in U SD c ur re nc y; a nd in cl ud es p ri nt in g do cu m en ts a nd r ep or ts fo r re co rd k ee pi ng a t t he li br ar y as w el l a s e / m ai lin g st ak eh ol de rs o n in fo rm at io n up da te s 2 C os ts a re in di ca te d as to ta l c os ts o f a w ar en es s ca m pa ig ns in U SD c ur re nc y; a nd w as c al cu la te d ba se d on th e fo llo w in g lo ca l c os t e st im at io ns : ( 1) 1 0, 00 0 U SD fo r pr ep ar at io n of n ew tr ai ni ng m at er ia ls , ( 2) ju n io r ex pe rt c os t p er d ay o f t ra in in g is 1 50 U SD ; ( 3) s en io r ex pe rt c os t p er d ay o f t ra in in g is 3 50 U SD ; ( 4) tr ai ni ng e xp er t c os ts in cl ud e al l f oo d an d tr an sp or ta tio n ex pe ns es , c ou ns el in g an d ad vi si ng , t ra in in g an d aw ar en es s ac tiv iti es , a nd o th er m is ce lla ne ou s ex pe ns es ; ( 5) e ac h pr oj ec t r eq ui re s on e ju ni or a nd o ne s en io r ex pe rt u nl es s ot he rw is e in di ca te d, a nd (6 ) e st im at ed c os ts d o no t i nc lu de m ed ia c ov er ag e an d tr ai n in g/ aw ar en es s m at er ia l p ri nt in g; (7 ) T he re w ou ld b e 7 to ta l c am pa ig ns s pa nn in g up to 2 02 5, a nd th er ef or e di sc ou nt r at e of 3 % w as ta ke n. 3 Sa m e sp ec ifi ca tio ns a s ab ov e (* ), bu t w ith tw o ju ni or a nd o ne s en io r ex pe rt p er p ro je ct POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3.3.14. Activity 14: Effectiveness Evaluation 3.3.14.1. Objective and Compliance under SC The objectives, of this activity which falls under the requirements of Article 16 of the Stockholm Convention, are: 1) Evaluation of the SC effectiveness 4 years after its entry into force and then periodically at intervals to be decided by the COP; and 2) Facilitation of effectiveness evaluation via provision of comparable monitoring data for Annex A, B and C chemicals, based on available scientific, environmental, technical and economic information. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 86-87 1 C os t i s To ta l c os t o f i nv en to ri es (u p un til 2 02 5 ev er y th re e ye ar s) in U SD c ur re nc y; a nd w as e st im at ed b as ed o n th e le ve l o f w or k re qu ir ed in lo ca l c os t e st im at io ns fo r ea ch P O Ps c at eg or y as fo llo w s: (1 ) T he D io xi ns a nd F ur an s in ve nt or y in cl ud es a fu ll sc re en in g of a ll re le va nt r eg is te re d an d (if p os si bl e) n on r eg is te re d in du st ri es ; ( 2) th e PC Bs in ve nt or y in cl ud es s am pl in g an d an al ys is e ffo rt s in P C B co nt am in at ed o ils an d m at er ia ls , ( 3) th e PO Ps P es tic id es in ve nt or y in vo lv es li m ite d fie ld w or k in a dd iti on to r ep or tin g, d at a ga th er in g, e tc . 2 C os t i s in di ca te d as to ta l m on ito ri ng ta sk s in U SD c ur re nc y; a nd w as c al cu la te d ba se d on th e fo llo w in g lo ca l c os t e st im at io ns : ( 1) ju ni or e xp er t c os t p er d ay o f c on su lti ng is 7 5 U SD ; ( 2) s en io r ex pe rt c os t p er da y of c on su lti ng is 1 50 U SD ; ( 3) tr ai ni ng e xp er t c os ts in cl ud e co un se lin g an d ad vi si ng ; a nd (4 ) t he p ro je ct r eq ui re s on e ju ni or a nd o ne s en io r ex pe rt u nl es s ot he rw is e in di ca te d T ab le 3 .1 4 A ct iv it y 14 : E ff ec ti ve ne ss E va lu at io n D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 14 .1 : D ev el op a M on ito ri ng P ro gr am fo r A ss es sm en t o f D ue P ro gr es s & E ffe ct iv en es s of P ro po se d & A do pt ed A ct io ns , i .e . I m pl em en t t he M ea su re s D ef in ed b y th e C O P fo r C om pa ra tiv e M on ito ri ng D at a T hi s ef fe ct iv en es s m on ito ri ng is to b e 74 . P re pa re g ui de lin es fo r th e ve ri fic at io n an d up da tin g fo r th e N IP w ith M oE 5, 00 0 U SD ST do ne in te rn al ly fo r se lf ev al ua tio n as du e re ga rd to th e do cu m en ts o f t he c on fe re nc e to th e SC w el l a s fo r th e as se ss m en t o f f ut ur e 75 . F re qu en tly u pd at e th e th re e pr el im in ar y in ve nt or ie s an d as se ss p ro gr es s M oE , P ri va te S ec to r 18 4, 00 0 U SD LT (e ve ry 3 y ea rs )1 ac tiv iti es / ap pr oa ch es to b e un de rt ak en , in e st im at ed e m is si on s' re du ct io n (I n co lla bo ra tio n w ith : & s ha ll in cl ud e qu an tit at iv e an d M oI , M oP H & M oA ) qu al ita tiv e m ea ns o f a ss es sm en t r el at ed 76 . D ev el op m ea su ra bl e in di ca to rs fo r ea ch p ro po se d ac tio n (s uc h as th e M oE , P ri va te S ec to r $4 7, 00 02 Fr eq ue nc y: E ve ry 6 to ti m e ef fic ie nc y, q ua lit y of w or k, pe rc en ta ge c ov er ag e of a w ar en es s pr og ra m s) r ef le ct iv e of e ac h ta sk (I n co lla bo ra tio n w ith : ye ar s LT w or k m et ho do lo gy , c os t e ff ic ie nc y ac hi ev em en ts a nd m et ho di ca lly e va lu at e ea ch ta sk u po n co m pl et io n M oI , M oP H & M oA ) am on g ot he rs 77 . E va lu at e ea ch a ct iv ity a nd ta sk b as ed o n tim e an d bu dg et : e st im at ed M oE , P ri va te S ec to r 5, 00 0 U SD 5, 00 0 U SD S T ve rs us a ct ua l (I n co lla bo ra tio n w ith : M oI , M oP H & M oA ) 78 . A cq ui re m on ito ri ng d at a re qu ir ed b y th e C O P us in g ex is tin g m on ito ri ng M oE 5, 00 0 U SD ST pr og ra m s an d m et ho ds 79 . I nc lu de m on ito ri ng r es ul ts in th e cu rr en t r ep or t t o th e C O P M oE N o di re ct c os ts 80 . P er fo rm A ud it s by a na ly zi ng m on ito ri ng r ep or ts s ub m itt ed to M oE M oE , P ri va te S ec to r 25 ,0 00 U SD M T an d ra nd om m on ito ri ng POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3.3.15. Activity 15: Reporting 3.3.15.1. Objective and Compliance under SC Pursuant to the requirements under Article 15, the objectives of this activity are to report to the COP and Secretariat on: 1) Measures that were undertaken to implement the provisions of the SC and their effectiveness in meeting the obligations of this convention (Section 0); and 2) Data or data estimates on the quantities of production, import and export, as well as countries of origin, and destination, of the Annex A and B chemicals. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 88-89 T ab le 3 .1 5 A ct iv it y 15 : R ep or ti ng D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 15 .1 : C om pi le In fo rm at io n on th e Ty pe s (a ct iv e in gr ed ie nt ) a nd Q ua nt iti es o f P es tic id es b ei ng P ro du ce d, Im po rt ed a nd E xp or te d, a nd th e Ty pe s (a ct iv e in gr ed ie nt ), Q ua nt iti es , Lo ca tio ns o f P O Ps P es tic id es b ei ng D is tr ib ut ed , U se d, a nd S to ck pi le d in L eb an on Fu ll up da te d st at is tic al d at a on th e 81 . R eq ue st a nd c ol le ct in fo rm at io n fr om c us to m s, o ut le ts / re ta ile rs a nd 6, 00 0 U SD ST pr es en ce a nd lo ca tio n of P O Ps en d us er s (m ai nl y fa rm er s) pe st ic id es w ill b e co m pi le d an d 82 . U se th e ga th er ed in fo rm at io n to p re pa re a d at ab as e an d 'm at er ia l 3, 00 0 U SD su bm itt ed to th e C O P ba la nc e' to b e us ed in fu tu re u pd at es o f t he P O Ps p es tic id es in ve nt or y A ct io n 15 .2 : P re pa re a nd S ub m it N at io na l R ep or ts to th e C on fe re nc e of th e Pa rt ie s (C O P) R ep or ts w ill b e su bm itt ed to u pd at e 83 . C om pi le in fo rm at io n on r el ev an t e ffo rt s an d ac tiv iti es 75 0 U SD ST th e C O P on p ro gr es s w ith r es pe ct to 84 . D ev el op a nd s ub m it a re po rt r ef le ct in g on th e ef fe ct iv en es s of th e 5, 00 0 U SD M T im pl em en ta tio n of S C r eq ui re m en ts ad op te d m ea su re s an d re co m m en da tio ns / su gg es tio ns fo r im pr ov em en t A ct io n 15 .3 : D ev el op a D at a C ol le ct io n Sy st em fo r PO Ps E m is si on fr om In di vi du al E nt er pr is es C at eg or y so ur ce s II w ill s ub m it re po rt s 85 . s ub m it ye ar ly r ep or ts c on ce rn in g B A T /B EP p ra ct ic es ; i ts in tr od uc tio n, 95 ,0 00 U SD ST M T L T to e va lu at e th e ef fic ie nc y of th e im pl em en ta tio n, a nd d iff ic ul tie s fa ce d in tr od uc ed B A T /B EP w ith r es pe ct to PC D D /P C D F em is si on s 3.3.16. Activity 16: Research, Development and Monitoring 3.3.16.1. Objective and Compliance under SC This activity falls under the requirements of Article 11 of the Stockholm Convention. This activity mainly focuses on: 1) Undertaking research, development, monitoring and cooperation related to POPs and, where relevant, to their alternatives and to candidate POPs, including sources, levels, trends, environmental releases and transport, effects on human health and the environment, reduction and elimination of releases, among other; and 2) Taking action, within the country's capabilities, to support and develop activities pertaining to POPs research, to strengthen POPs research capabilities, to promote access to and exchange of POPs data, among others. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 90-91 T ab le 3 .1 6 A ct iv it y 16 : R es ea rc h, D ev el op m en t an d M on it or in g D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 16 .1 : P ro m ot e an d C on du ct H ea lth R el at ed R es ea rc h an d St re ng th en P O Ps R es ea rc h Pr oj ec ts in L eb an on T he H ea th a nd E nv ir on m en t P ro fil e 86 . P er fo rm a na ly si s of s am pl es ta ke n fr om th e lo ca l p op ul at io n an d M oE , N C SR 20 0, 00 0 U SD M T re po rt e xp os ed th e nu m er ou s da ta lo ca l f oo d sa m pl es fo r PO Ps c he m ic al s ga ps in P O Ps h ea lth is su es in L eb an on 87 . A ss es s en vi ro nm en ta l a nd o cc up at io na l e xp os ur e an d he al th r is ks M oE , N C SR 20 0, 00 0 U SD M T as so ci at ed w ith th es e ch em ic al s. I de nt if y pr io ri ty r es ea rc h ar ea s fo r fu nd in g an d pr ov id e fin an ci al r es ou rc es . 88 . E nc ou ra ge M oE , M oA a nd M oI to in ve st m or e re so ur ce s to p ro m ot e M oE , N C SR 5, 00 0 U SD ST sc ie nt ifi c an d te ch ni ca l r es ea rc h in L eb an on 89 . E nc ou ra ge lo ca l r es ea rc h in st itu tio ns a nd u ni ve rs iti es to c on du ct M oE , N C SR 5, 00 0 U SD ST re se ar ch o n th e ef fe ct s of P O Ps o n re pr od uc tiv e he al th A ct io n 16 .2 : F or m ul at e In sp ec tio n U ni ts to M on ito r D io xi ns /F ur an s C on ce nt ra tio ns a t I de nt ifi ed S ou rc e In sp ec to rs u ni ts a re r eq ui re d to c on tr ol 90 . M ob ili ze re so ur ce s in sp ec tio n un its th at a im a t m on ito ri ng P C D D /P C D F M oE 19 0, 00 0 U SD LT po te nt ia l s ou rc es o f P C D D /P C D F em is si on s at id en tif ie d so ur ce s es pe ci al ly th os e un de r so ur ce s II a nd II I of th e co nv en tio n A ct io n 16 .3 : R eq ui re M on ito ri ng P ro gr am s at th e So ur ce a nd R es ul ts S ub m itt al to M oE fo r R ec or d K ee pi ng a nd A na ly si s M on ito ri ng p ro gr am s sh ou ld b e do ne 91 . R eq ui re id en tif ie d so ur ce s to p er fo rm s el f m on ito ri ng a nd s en d M oE 5, 00 0 U SD M T by th e so ur ce s to e va lu at e th e ef fic ie nc y re po rt s to M oE of th e in tr od uc ed B A T /B EP p ra ct ic es A ct io n 16 .4 : E st ab lis h a M on ito ri ng P ro gr am to V al id at e th e Se nt R es ul ts b y St ak eh ol de rs ' S el f m on ito ri ng a nd to C he ck th e Ef fic ie nc y of th e St ra te gy o f E lim in at in g D io xi ns B y pr od uc ts V al id at io n of m on ito ri ng r ep or ts v ia 92 . A m on ito ri ng p ro gr am s ho ul d be e st ab lis he d by th e in sp ec tio n un it M oE 5, 00 0 U SD M T in sp ec to rs r eg ar di ng s ou rc e an d to v al id at e th e re su lt of th e se lf m on ito ri ng r ep or ts em is si on d at a POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3.3.17. Activity 17: Technical and Financial Assistance Lebanon, a developing country with a $38 billion national debt, will require technical and financial resources to execute the National Implementation Plan, either wholly or partly, and to fulfill its obligations under the Stockholm Convention. Lebanon therefore should articulate specific requests for international funding from donor agencies based on arrangements established by the COP. As explained in the following activity, Lebanon should if possible share its technical expertise with neighboring countries. 3.3.17.1. Objective and Compliance under SC This Activity falls under the requirements of Articles 12 and 13 of the Convention. Its main objectives are to: 1) Recognize the importance of cooperation and provision of timely and appropriate technical assistance to developing country Parties; 2) Consider the particular needs and limitations of developing countries and Parties with economies in transition to strengthen their SC implementation capacity; and 3) Promote regional and sub-regional centers for capacity building and transfer of technology. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 92-93 T ab le 3 .1 7 A ct iv it y 17 : T ec hn ic al a nd F in an ci al A ss is ta nc e D es cr ip tio n Ta sk s R es po ns ab ili ty Es tim at ed C os t T im e Fr am e A ct io n 17 .1 : P ro vi de T ec hn ic al S up po rt to O th er S ta te M em be rs A lth ou gh L eb an on is a d ev el op in g 93 . D ev el op o r pa rt ic ip at e in r eg io na l a nd in te rn at io na l t ra in in g an d/ or O pe n: M oE , M oA , M oI , N G O s, $2 80 ,0 00 1 Fr eq ue nc y: A nn ua lly co un tr y, it c an te ch ni ca lly s up po rt ca pa ci ty b ui ld in g pr og ra m s N C SR , U ni ve rs iti es (A U B, D ur at io n: 4 5 da ys ne ig hb or in g co un tr ie s in th e M EN A LA U , B al am an d) re gi on 94 . E xc ha ng e in fo rm at io n an d te ch ni ca l e xp er tis e w ith p er tin en t r eg io na l M oE , M oA , M oI , N G O s, $1 40 ,0 00 2 C on tin uo us an d/ or in te rn at io na l t ec hn ol og y ce nt er s N C SR , U ni ve rs iti es (A U B, Fr eq ue nc y: A nn ua lly LA U , B al am an d) D ur at io n: 3 6 da ys A ct io n 17 .2 : P ro vi de F in an ci al R es ou rc es fo r Re al iz at io n of th e A ct io n Pl an In a cc or da nc e w ith L eb an on 's lim ite d 95 . M ob ili ze lo ca l f un di ng (i f a ny ) f or N IP im pl em en ta tio n (o r ch em ic al s C oM , U N D P, M oE 77 ,0 00 U SD C on di tio na l fin an ci al r es ou rc es , t he c ou nt y w ill m an ag em en t i n ge ne ra l) St ar t: 20 06 m ob ili ze w ha te ve r m ea ns a nd r es ou rc es D ur at io n: 2 y ea rs it ha s av ai la bl e to im pl em en t t he N IP 96 . D ev el op c os t re co ve ry a nd c os t sa vi ng m ec ha ni sm s th at c om pl em en t o r M oE , M oA , M oI , N G O s 20 ,0 00 U SD ST en ha nc e th e N IP im pl em en ta tio n 1 C os t i s in di ca te d in U SD c ur re nc y; a nd w as e st im at ed b as ed o n lo ca l c os t e st im at io ns a s fo llo w s: (1 ) o nl y 9 lo ca l e xp er ts w ill u nd er go tr ai ni ng fo r 5 w or ki ng d ay s ea ch ; ( 2) e ac h lo ca l e xp er t w ill r eq ui re 5 00 U SD as tr av el a nd v is a co st s an d 10 0 U SD p er d ay a s ex pe ns e co st , a nd (3 ) e ac h re gi on al e xp er t w ill c os t a bo ut 2 00 U SD p er w or ki ng d ay o f t ra in in g; (4 ) S ta te d am ou nt e qu al s to ta l c os t o f a nn ua lly h el d pr og ra m s up to 2 02 5 di sc ou nt ed a t 3 % . 2 C os t i s in di ca te d in U SD c ur re nc y; a nd w as e st im at ed b as ed o n lo ca l c os t e st im at io ns a s fo llo w s: (1 ) e xc ha ng e of h um an r es ou rc es w ill o cc ur w ith 1 2 lo ca l e xp er ts fo r 3 da ys e ac h; (2 ) e xp en se c os t p er d ay p er lo ca l e xp er t i s 40 U SD ; ( 3) tr av el a nd v is a co st p er lo ca l e xp er t p er tr ip if 5 00 U SD ; (4 ) t he e st im at ed c os ts d o no t i nc lu de c or re sp on de nc e an d ot he r no n m en tio ne d ex pe ns es r el at ed to th is a ct iv ity ; a nd (5 ) A m ou nt s ta te d eq ua ls e xc ha ng e of in fo rm at io n an d ex pe rt is e an nu al ly , u p to 2 02 5 at d is co un t r at e of 3 % . POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 3.4. Development and Capacity Building Proposals and Priorities Priority activities for implementation of the provisions of the Stockholm Convention have revealed areas that would require capacity building. In particular, national capacities for the assessment of emissions and releases are in dire need of support. Other areas of capacity building are described below: 1. Proposing mechanisms to improve inter ministerial communication Lebanon needs to identify and propose mechanisms to improve communication among line ministries (MoA, MoE, MoPH, MoF, MoET and MoEW) and other stakeholders (EDL, industries, solid waste operators) such as creating a National Committee for POPs Chemical Management. Lebanon does not have a national committee to monitor and manage chemicals. This committee will assume responsibility for ensuring national inspection of POPs sources and ministerial enforcement of all POPs legislations. 2. Improving data collection and monitoring of POPs emissions and releases Lebanon will need to develop a data collection system. The National Committee for POPs Chemical Management, if enacted, or otherwise MoE, should decide where this system should be built. This will require some organizational, financial and technical support. Efforts must be made by all the relevant stakeholders to take responsibility for continuous monitoring and data collection of emissions and releases of the POPs chemicals. A system for self-monitoring of polluting industries as well as reporting and auditing mechanisms should be developed. To improve data collection, relevant government officials will need to be trained to collect samples and conduct qualitative tests. Training will be required to ensure the development of sufficient technical and professional capacities to implement the tasks required. Credible government agencies should be able to collect samples from any matrix that could contain POPs (soil, water and food). 3. Improving sampling and analysis for POPs in laboratories Field inspectors and laboratory technicians should be trained to perform proper sampling and analysis for POPs under specific POPs monitoring programs. Laboratories in return should be well-equipped for analysis, both technically in equipment and technology as well as professionally in qualified and experienced staff. Personnel from relevant institutions should be trained on the best available technologies/equipment and safety measures to ensure the appropriate collection and analysis of samples. Government institutions often do not have the necessary instrumentation and personal protective equipments for sampling procedures, or the required technology for analysis. Coordination with the Industrial Research Institute (IRI) is important. Government officials and private institutions staff will need to be trained to identify potential POPs sources. Obtained data from monitoring should be added to the centralized POPs information system to keep it regularly updated. 4. Updating the inventory of POPs containing or POPs-contaminated waste stocks and equipment Additional technical and financial support is required to conduct full scale inventories for each of the POPs chemicals. This task will require human resources and will be easier to implement once data collection capabilities are improved. Efforts must be made to investigate all potential sources of POPs including contaminated sites and equipment. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 94-95 5. Storing and disposing POPs containing material and equipment A particularly difficult situation is observed in the handling of POPs containing material, equipment. Lebanon does not host sufficient technical expertise and the know-how in storing and disposing POPs containing material and equipment. Lebanon also lacks the necessary storing and handling equipment and will require financial support to obtain them. 6. Strengthening inspection and identification procedures at customs Efforts must be made to strengthen the inspection and identification procedures at customs to properly identify POPs products possibly entering Lebanon. It is not certain that the Lebanese customs are enforcing and implementing Decision 71/1, banning the import of POPs chemicals from entering Lebanon. It is not known whether customs is actually enforcing the decision. It is also not clear whether custom officials are aware which products entering Lebanon contain and are composed of POPs chemicals. The MoF will need to ensure all the customs officials are trained to identify POPs containing products and material. 7. Training different stakeholders Training should be undertaken for institutions categorized under sources II and III of the SC, where BAT/BEP will be introduced. The main focus of the training should be on incineration infrastructure as well as appropriate site selection and techniques for solid waste management. 3.5. Timetable for Plan Implementation and Measures of Success The implementation schedule of the National Implementation Plan related to the Stockholm Convention was divided into three periods; Short-term (years 1 to 5), Medium-term (years 6 to 10) and Long-term (years 11 to 20). To the extent possible, each task has its own implementation time. Table 3.18 provides a summary of the timeframe allocated per action and task where tasks are presented as numbers under the corresponding year. It is important to note that during the consultations conducted in the priority setting workshop in August 2005, it was determined that awareness raising is one of the most critical areas of intervention and therefore should be addressed from day 1. Increased awareness will generate public pressure and strong demand for improved institutional management and legislation. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon T ab le 3 .1 8 T im et ab le fo r A ct io n P la n Im pl em en ta ti on a nd M ea su re s of S uc ce ss A ct io n Im pl em en ta tio n Ye ar Sh or t te rm M ed iu m t er m Lo ng t er m 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 A ct iv ity 1 : I ns tit ut io na l & R eg ul at or y St re ng th en in g M ea su re s A ct io n 1. 1 1, 2, 3, 1, 2, 3, 1, 2, 3, 1, 2, 3, 1, 2, 3, 4, 5 4, 5 4, 5 4, 5 4, 5 A ct io n 1. 2 6, 7, 8 6, 7, 8 6, 7, 8 6, 7, 8 6, 7, 8 A ct io n 1. 3 9, 10 9, 10 9, 10 9, 10 9, 10 A ct io n 1. 4 11 11 11 11 11 A ct io n 1. 5 12 12 12 12 12 A ct io n 1. 6 13 13 13 13 13 13 13 13 13 13 A ct iv ity 2 : M ea su re s to R ed uc e or E lim in at e R el ea se s fr om In te rn at io na l P ro du ct io n an d U se A ct io n 2. 1 14 ,1 5, 14 ,1 5 14 ,1 5 14 ,1 5 14 ,1 5 16 16 16 16 16 A ct io n 2. 2 17 ,1 8 17 ,1 8 17 ,1 8 17 ,1 8 17 ,1 8 A ct iv ity 4 : P ro du ct io n, Im po rt a nd E xp or t, U se , I de nt ifi ca tio n, L ab el in g, R em ov al S to ra ge a nd D is po sa l o f P C Bs a nd E qu ip m en t c on ta in in g PC Bs A ct io n 4. 1 19 ,2 0, 19 ,2 0 19 ,2 0 19 ,2 0 19 ,2 0 21 21 21 21 21 A ct io n 4. 2 22 ,2 3 22 ,2 3 22 ,2 3 22 ,2 3 22 ,2 3 23 23 23 23 23 A ct io n 4. 3 24 ,2 5 24 ,2 5 24 ,2 5 24 ,2 5 24 ,2 5 25 ,2 6 25 ,2 6 25 ,2 6 25 ,2 6 25 ,2 6 27 27 27 27 27 27 27 27 27 26 ,2 7 26 ,2 7 26 ,2 7 26 ,2 7 26 ,2 7 27 27 27 27 27 A ct iv ity 7 : M ea su re s to r ed uc e re le as es fr om u ni nt en tio na l p ro du ct io n A ct io n 7. 1 28 ,2 9, 28 ,2 9, 28 ,2 9, 28 ,2 9, 28 ,2 9, 29 ,3 0 29 ,3 0 29 ,3 0 29 ,3 0 29 ,3 0 30 ,3 1, 30 ,3 1, 30 ,3 1, 30 ,3 1, 30 ,3 1, 31 ,3 2 31 ,3 2 31 ,3 2 31 ,3 2 31 ,3 2 32 ,3 3, 32 ,3 3, 32 ,3 3, 32 ,3 3, 32 ,3 3, 33 ,3 4 33 ,3 4 33 ,3 4 33 ,3 4 33 ,3 4 34 34 34 34 34 A ct io n 7. 2 35 ,3 6 35 ,3 6 35 ,3 6 35 ,3 6 35 ,3 6 35 35 35 35 35 A ct iv ity 8 : M ea su re s to R ed uc e R el ea se s fr om S to ck pi le s an d W as te s A ct io n 8. 1 37 37 37 37 37 A ct io n 8. 2 38 38 38 38 38 A ct io n 8. 3 39 ,4 0 39 ,4 0 39 ,4 0 39 ,4 0 39 ,4 0 A ct iv ity 9 : I de nt ifi ca tio n of s to ck pi le s, a rt ic le s in u se a nd w as te s A ct io n 9. 1 41 41 41 41 41 A ct io n 9. 2 42 ,4 3 42 ,4 3 42 ,4 3 42 ,4 3 42 ,4 3 A ct io n 9. 3 44 ,4 5 44 ,4 5 44 ,4 5 44 ,4 5 44 ,4 5 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 96-97 A ct io n Im pl em en ta tio n Ye ar Sh or t te rm M ed iu m t er m Lo ng t er m 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 A ct iv ity 1 0: M an ag e st oc kp ile s an d ap pr op ri at e m ea su re s fo r ha nd lin g & d is po sa l o f a rt ic le s in u se A ct io n 10 .1 46 ,4 7 46 ,4 7 46 ,4 7 46 ,4 7 46 ,4 7 A ct io n 10 .2 48 ,4 9 48 ,4 9 48 ,4 9 48 ,4 9 48 ,4 9 A ct iv ity 1 1: Id en tif ic at io n of c on ta m in at ed s ite s an d re m ed ia tio n in a n en vi ro nm en ta lly s ou nd m an ne r A ct io n 11 .1 50 ,5 1 50 ,5 1 50 ,5 1 50 ,5 1 50 ,5 1 A ct io n 11 ..2 52 ,5 3 52 ,5 3 52 ,5 3 52 ,5 3 52 ,5 3 52 ,5 3 52 ,5 3 52 ,5 3 52 ,5 3 52 ,5 3 A ct io n 11 .3 54 ,5 5 54 ,5 5 54 ,5 5 54 ,5 5 54 ,5 5 A ct io n 11 .4 56 ,5 7 56 ,5 7 56 ,5 7 56 ,5 7 56 ,5 7 A ct io n 11 .5 58 ,5 9 58 ,5 9 58 ,5 9 58 ,5 9 58 ,5 9 59 59 59 59 59 A ct iv ity 1 2: F ac ili ta tin g or u nd er ta ki ng in fo rm at io n ex ch an ge a nd s ta ke ho ld er in vo lv em en t A ct io n 12 .1 60 ,6 1 60 ,6 1 60 ,6 1 60 ,6 1 60 ,6 1 A ct io n 12 .2 62 62 62 62 62 A ct io n 12 .3 63 63 63 63 63 A ct io n 12 .4 64 64 64 64 64 A ct io n 12 .5 65 65 65 65 65 65 65 65 65 65 A ct io n 12 .6 66 ,6 7 66 ,6 7 66 ,6 7 66 ,6 7 66 ,6 7 A ct iv ity 1 3: P ub lic a w ar en es s, in fo rm at io n an d ed uc at io n A ct io n 13 .1 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 68 ,6 9 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 70 ,7 1 72 72 72 72 72 72 72 72 72 72 72 72 72 72 72 72 72 72 72 A ct io n 13 .2 73 73 73 73 73 A ct iv ity 1 4: E ffe ct iv en es s Ev al ua tio n A ct io n 14 .1 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 74 ,7 5 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 76 ,7 7 78 78 78 78 78 78 78 78 78 78 78 78 78 78 78 78 78 78 78 A ct iv ity 1 5: R ep or tin g A ct io n 15 .1 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 81 ,8 2 A ct io n 15 .2 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 83 ,8 4 A ct io n 15 .3 85 85 85 85 85 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon A ct io n Im pl em en ta tio n Ye ar Sh or t te rm M ed iu m t er m Lo ng t er m 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 A ct iv ity 1 6: R es ea rc h, D ev el op m en t a nd m on ito ri ng A ct io n 16 .1 86 ,8 7 86 ,8 7 86 ,8 7 86 ,8 7 86 ,8 7 86 ,8 7 86 ,8 7 86 ,8 7 86 ,8 7 86 ,8 7 88 ,8 9 88 ,8 9 88 ,8 9 88 ,8 9 88 ,8 9 A ct io n 16 .2 90 90 90 90 90 90 90 90 90 90 90 90 90 90 90 90 90 90 90 A ct io n 16 .3 91 91 91 91 91 91 91 91 91 91 A ct io n 16 .4 92 92 92 92 92 92 92 92 92 92 A ct iv ity 1 7: T ec hn ic al a nd F in an ci al A ss is ta nc e A ct io n 17 .1 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 93 ,9 4 A ct io n 17 .2 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 95 ,9 6 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 98-99 3.6. Resource Requirements Assessment of the funds is based on cost assessment of individual action plans and strategies. The total cost of the NIP as presented in Table 3 19 amounted to a net present value of about 13.4 USD million when not subject to a discount rate of any sort. When a three percent discount is used however, the net present value of the costs amounts to 11.5 USD million. It is important to note that not all tasks were given estimated costs where cost will have to be determined at some of them and others have no direct cost. In conclusion, Lebanon does not have sufficient financial resources to implement the foreseen activities. Financial support from international organizations and bodies of the Stockholm Convention is expected once Lebanon has endorsed the NIP. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon Table 3.19. Implementation Costs of Activities Covered by the NIP with their Sources of Funding Activity/Action Total Budget Total Budget Required Required (US$) (US$) discounted at 3% Activity 1: Institutional & Regulatory Strengthening Measures Action 1.1 $70,000 $70,000 Action 1.2 $85,000 $73,000 Action 1.3 $45,000 $45,000 Action 1.4 $14,000 $14,000 Action 1.5 No Direct Cost No Direct Cost Action 1.6 $10,000 $9,000 Activity 2: Measures to Reduce or Eliminate Releases from Intentional Production Action 2.1 $1,840,000 $1,840,000 Action 2.2 $9,600 $9,600 Activity 4: Production, Import and Export, Use, Identification, Labeling, Removal Storage and Disposal of PCBs and Equipment Containing PCBs Action 4.1 $153,000 $153,000 Action 4.2 $53,000 $53,000 Action 4.2 $1,506,000 $866,000 Activity 7: Measures to Reduce Releases from Unintentional Releases Action 7.1 $911,500 $793,000 Action 7.2 $100,000 $86,000 Activity 8: Measures to Reduce Releases from Stockpiles and Wastes Action 8.3 $35,000 $35,000 Activity 9: Identification of Stockpiles, Articles in Use and Wastes Action 9.1 $5,000 $5,000 Action 9.2 No Direct Cost No Direct Cost Action 9.3 $70,000 $70,000 Activity 10: Manage Stockpiles and Appropriate Measures for Handling and Disposal of Articles in use Action 10.1 No Direct Cost No Direct Cost Action 10.2 $3,000 $3,000 Activity 11: Identification of Contaminated Sites and Remediation in an Environmentally Sound Manner Action 11.1 $120,000 $120,000 Action 11.2 $550,000 $523,000 Action 11.3 $40,000 $40,000 Action 11.4 $4,515,000 $4,515,000 Action 11.5 $120,000 $106,000 Activity 12: Facilitating or Undertaking Information Exchange and Stakeholder Involvement Action 12.1 $1,500 $1,500 Action 12.2 $50,000 $50,000 Action 12.3 $7,500 $7,500 Action 12.4 $2,000 $2,000 Action 12.5 $50,000 $43,000 Action 12.6 $1,000 $1,000 Activity 13: Public Awareness, Information and Education Action 13.1 $1,448,000 $830,000 Action 13.2 $10,000 $10,000 Activity 14: Effectiveness Evaluation Action 14.1 $460,000 $169,000 Activity 15: Reporting Action 15.1 $9,000 $9,000 Action 15.2 $5,750 $5,750 Action 15.3 $95,000 $55,000 Activity 16: Research, Development and Monitoring Action 16.1 $410,000 $356,000 Action 16.2 $190,000 $110,000 Action 16.3 $5,000 $5,000 Action 16.4 $5,000 $5,000 Activity 17: Technical and Financial Assistance Action 17.1 $420,000 $240,000 Action 17.2 $97,000 $97,000 POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 100-101 References Bashour I., Dagher S., Chamas G., Lteif A., and Kawar N., DDT Residues in Lebanese Soils, Journal of Environmental Health and Science, Part B, Vol. B39, No. 2, Pages 273-283, 2004. 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MoE/ELARD 2005, National Profile on Chemicals Management in Lebanon, Report submitted to MoE/UNEP. MoE/ELARD 2005, Preliminary Inventory on Dioxins and Furans in Lebanon, Report submitted to MoE/UNEP. MoE/ELARD 2005, Preliminary Inventory on POPS Pesticides in Lebanon, Report submitted to MoE/UNEP. MoET, 2005: Ministry of Economy and Trade, National Accounts Committee. Economic Accounts for 1997-2002, Beirut. MoI/UNIDO, 1999. A report on industry in Lebanon 1998-1999 Statistics and Findings. MoI, Beirut. MOSA/UNDP. Ministry of Social Affairs. Population and Housing Survey. 1996 Stockholm Convention on Persistent Organic Pollutants (POPs) - Text and Annexes. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon UNEP Chemicals in cooperation with the Secretariat of the Basel Convention, Inventory of Worldwide PCB Destruction Capacity, December 1998. UNEP Chemicals, Guidelines for the Identification of PCBs and Materials Containing PCBs, August 1999. UNEP Chemicals, PCB Transformers and Capacitors: From Management to Reclassification and Disposal, May 2002. UNEP Chemicals, Proceeding of the Sub regional Workshop on Support for the Implementation of the Stockholm Convention on Persistent Organic Pollutants, Bahrain, November 11, 2001. UNEP Chemicals, Standardized Toolkit for Identification and Quantification of Dioxin and Furan Releases, May 2000. UNEP Chemicals, Survey of Currently Available Non-Incineration PCB Destruction Technologies, August 2000. World Business Council for Sustainable Development - Cement Sustainability Initiative, DRAFT Formation and Release of POPs in the Cement Industry, March 2004. POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon 102-103 Helpfu l Websi tes CCIA: http://www.ccib.org.lb/profile.html ALIL: http://www.ali.org.lb Industrial Syndicates: http://www.industry.gov.lb Environmental NGOs: http://www.moe.gov.lb AUB: http://www.aub.edu.lb LU: http://www.ul.edu.lb USJ: http://www.usj.edu.lb UoB: http://www.balamand.edu.lb BAU: http://www.bau.edu.lb LAU: http://www.lau.edu.lb NDU: http://www.ndu.edu.lb ACTS: http://www.acts-int.com Centre de Chimie: http://www.fs.usj.edu.lb/cdchimie.htm Creen: http://www.fi.usj.edu.lb/esib/rech/centre.jsp?code=CREEN ECL: http://wwwlb.aub.edu.lb/~webcrsl/ IRI: http://www.iri.org.lb/ Lari: http://www.lari.gov.lb/link4.asp LAU: http://www.lau.edu.lb and http://www.lau.edu.lb/centers-institutes/iwret.html. Lebanese Atomic Energy Commission: http://www.cnrs.edu.lb/energycommission.html. Remote Sensing Center: http://www.cnrs.edu.lb/remotesensing.html. http://www.tradeinfo.net/itc.html http://exim.indiamart.com/product-classification http://www.llnl.gov/es and h/hsm/doc 14.14/doc14-14.html#toc14 http://homer.ornl.gov/oepa/guidance/tsca/pcb-disp.pdf http://www.ec.gc.ca/pcb/destruction/eng/c42 e.htm http://www.greenpeacemed.org.mt/23052002b.html POPs - National Implementation Plan - 2006 Ministry of Environment - Lebanon G R A P H IT I Ministry of Environment Azarieh Bldg., Beirut Central District P.O.Box: 11 - 2727, Beirut - Lebanon Phone: +961.1.976 555 Fax: +961.1.976 531 E-mail: pops@moe.gov.lb www.moe.gov.lb/pops