Documents
Resources
Learning Center
Upload
Plans & pricing Sign in
Sign Out

Introduction World Bank

VIEWS: 6 PAGES: 179

									                                                                       E1198
                                                                        v. 2
Ministry of Ecology and Natural Resources of the Republic of Moldova




GEF PAD Grant for Preparation of
Sustainable Persistent Organic
Pollutants (POPs) Stockpiles
Management Project

ENVIRONMENTAL IMPACT
ASSESSMENT AND ENVIRONMENTAL
MANAGEMENT PLAN




June 30, 2005
Ministry of Ecology and Natural Resources of the Republic of Moldova




GEF PAD Grant for Preparation of
Sustainable Persistent Organic
Pollutants (POPs) Stockpiles
Management Project

ENVIRONMENTAL IMPACT
ASSESSMENT AND ENVIRONMENTAL
MANAGEMENT PLAN




June 30, 2005




                                                        File no:        TR - 01

                                                        Date of issue   30.06.2005

                                                                        RUM, VAL, TAB,
                                                        Prepared:
                                                                        VIB, CBU

                                                        Revised         08.06.05

                                                        Checked:        VAL, CBU

                                                        Approved:       TAB
Environmental Impact Assessment Report                                                       Page   3 of 179




TABLE OF CONTENTS
Map of Location ............................................................................................... 5
Abbreviations and Acronyms ......................................................................... 8
Executive Summary ....................................................................................... 10
1      Introduction....................................................................................... 24
1.1    Background ......................................................................................... 24
1.2        Objectives and Scope of the Environmental Assessment ................... 25
1.3        Methodology ........................................................................................ 26
1.4        Organisation of the EA Report ............................................................. 28
2          Description of the Project ................................................................ 29
2.1        Project Objectives................................................................................ 29
2.2        Project Beneficiaries and Project Area ................................................ 29
2.3        Project Components ............................................................................ 30
2.4        Project Financing, Coordination & Support .......................................... 33
3          Legal and Institutional Framework ................................................. 35
3.1        National Policies, Strategies and Programs ........................................ 35
3.2        National Legislation and International Obligations ............................... 37
3.3        Applicable National and International Standards ................................. 43
3.4        Administration and Enforcement.......................................................... 46
3.5        National and WB Environmental Assessment requirements ............... 49
4          Description of the Environment (Baseline) .................................... 54
4.1        Biophysical Environment ..................................................................... 54
4.1.1      Location and Topography ................................................................... 54
4.1.2      Climate ............................................................................................... 54
4.1.3      Geology and Soils .............................................................................. 55
4.1.4      Water Resources ................................................................................ 56
4.1.5      Natural Systems, Habitats, Biodiversity and Protection ...................... 58
4.2        Socio-Economic Environment.............................................................. 60
4.2.1      Economic Evolution of Moldova and Poverty Issues .......................... 60
4.2.2      Current Features of the Agricultural Sector ....................................... 63
4.2.3      Energy sector ..................................................................................... 65
4.2.4      Health and Education ......................................................................... 66
4.3        Current pesticides and PCBs related information ................................ 68
4.3.1      Obsolete pesticides concern: history and state of centralization ........ 68
4.3.2      Environmental Contamination with POPs ........................................... 71

ECOS
Environmental Impact Assessment Report                                                      Page   4 of 179


4.4        Risk assessment ................................................................................. 74
5          Project Alternatives .......................................................................... 87
5.1        Without Project Alternative .................................................................. 87
5.2        GEF Project Alternatives ..................................................................... 91
5.2.1      Disposal options ................................................................................. 92
5.2.2      Siting of facilities ................................................................................. 98
5.2.3      Transportation routes within Moldova ................................................. 98
5.2.4      Methods of collection, packaging and storage .................................. 100
6          Environmental Impacts .................................................................. 102
6.1        The Current Threat (Without project alternative) ............................... 102
6.2        Project Benefits ................................................................................. 106
6.3        Project Impacts .................................................................................. 108
6.3.1      Generic nature of impacts ................................................................ 108
6.3.2      Specific project direct negative impacts per components ................. 115
6.4        Effects of Environment on the Project ............................................... 118
6.5        Cumulative effects ............................................................................. 118
6.6        Residual effects ................................................................................. 119
7          Environmental Management Plan ................................................. 121
7.1        Mitigation Plan ................................................................................... 121
7.2        Monitoring Plan.................................................................................. 135
7.3        Institutional Strengthening ................................................................. 144
8          Public Involvement and Information Disclosure .......................... 150
8.1        Public Consultation during Project Preparation ................................. 150
8.2        Public Involvement during Implementation ........................................ 152
9      Conclusions .................................................................................... 154
ANNEXES...................................................................................................... 155
Annex 1. List of Preparers .......................................................................... 156
Annex 2. References .................................................................................... 157
Annex 3. Record of Public Consultations Meetings ................................. 159
Annex 4. Contents of the Technical Appendix (in a separate volume) ... 166
Annex 5. Comparative review of WB Operational Policies, relevant Moldovan
         and EU legislation ........................................................................ 167
Annex 6. State of Centralization of Obsolete Pesticides .......................... 172
Annex 7. Map of location of warehouses ................................................... 176
Annex 8. Methodology Applied for Risk Assessment of Central Warehouses
         ....................................................................................................... 177
Annex 9. Map of integrated risk assessment and ranking of central pesticide
         warehouses .................................................................................. 179




ECOS
Environmental Impact Assessment Report   Page   5 of 179




Map of Location




ECOS
Environmental Impact Assessment Report                                                          Page   6 of 179



Moldova: Short country profile

The Republic of Moldova is a small, landlocked and densely populated country
located in the South-Eastern part of Europe, bordering Romania and Ukraine. The
country has a population of 4.3 million people of which 0.7 million live in
Transnistria, Moldova's most industrialized region. Transnistria (secessionists region,
is de facto - politically and institutionally - separated from the rest of the country.
Out of the total population, 54% are rural inhabitants, most of them involved in
agriculture activities. The prevalence of rural population has important social,
economic, political and environmental consequences.

Moldova remains the poorest country in Europe despite recent progress from its
small economic base. Despite good economic growth over the last three years
poverty continues to be a serious problem, with per capita income in 2003 less than
US$5431, which makes Moldova one of the poorest states in Europe. More than a
half of the population has consumptions levels below the internationally comparable
absolute poverty line of US$2.15 per day, and a majority falls into the category of
chronically poor2.

Moldova enjoys a favorable climate and good farmland but has no major mineral
deposits. As a result, the economy depends heavily on agriculture, featuring fruits,
vegetables, wine, and tobacco. Moldova must import almost all of its energy supplies
from Russia. Energy shortages contributed to sharp production declines after the
breakup of the Soviet Union in 1991.

As part of an ambitious reform effort, Moldova introduced a convertible currency,
freed prices, stopped issuing preferential credits to state enterprises, backed steady
land privatization, removed export controls, and freed interest rates. The government
entered into agreements with the World Bank and the IMF to promote growth and
reduce poverty. The economy returned to positive growth, of 2.1% in 2000, 6.1% in
2001, 7.2% in 2002, and 6.3% in 20033. The Strategy for Economic Growth and
Poverty Reduction forecasts a growth of 5% in 20054. The economy remains
vulnerable to higher fuel prices, poor agricultural weather, and the skepticism of
foreign investors.

The main environmental problems are those that relate to water pollution
(particularly ground water pollution), hazardous wastes, soil degradation/pollution,




1
    Source: National bank of Moldova. www.bnm.md
2 Moldova:   Public Economic Management Review, Report No. 25423-MD, Poverty Reduction and Economic Management
Unit, Europe and Central Asia Region, The World Bank, Washington, DC, February 20, 2003, p. 4
3 Source: Department of Statistics and Sociology, 2004 Statistical Yearbooks
4 Strategy of Economic Growth and Poverty Reduction (2004-2006), Chisinau, May 2004


ECOS
Environmental Impact Assessment Report                                 Page   7 of 179



and loss of biodiversity. Although Moldova has limited forest coverage (10%), the
wood harvest increased significantly in recent years, alongside with reduction of
necessary activities for forestation and for combating of forest diseases. As the main
sources of drinking water supply for rural areas is ground water, and pollution of this
resource has been increasing in recent years, the quality drinking water supply is
considered one of the country’s most important social and environmental problems.
The management of wastes (including hazardous wastes) is an other major
environmental concern having a significant adverse impact on country’s waters and
soils as well as on the public health.




ECOS
Environmental Impact Assessment Report                                Page   8 of 179




Abbreviations and Acronyms
ADR              International Carriage of Dangerous Goods by Road
CIS              Commonwealth of Independent States
CLRTAP           Convention on Long-Range Transboundary Air Pollution
DDD              Dichloro-diphenyl-dichloroethan
DDE              Dichloro-diphenyl-dichloroethilene
DDT              Dichloro-diphenyl-trichloroethan
DES              Department for Emergency Situations
DFID             Department for International Development (UK Government Agency)
DOC              Department of Customs
DSM              Department of Standardization and Metrology
EA               Environmental Assessment
EE&EIA           Ecological Expertise and Environmental Impact Assessment Law
EIA              Environmental Impact Assessment
EMP              Environmental Management Plan
FAO              UN Food and Agriculture Organization
GDP              Gross Domestic Product
GEF              Global Environment Facility
GOST             State Standard (in former USSR)
GRM              Government of the Republic of Moldova
HCB              Hexachlorobenzene
HCH              Hexachlor-cyclo-hexane
HMS              Hydrometeorological Service
IMDG             International Maritime Dangerous Goods
IMF              International Monetary Fund
ISO              International Standards Organization
JICA             Japan International Cooperation Agency
MAC              Maximum Allowable Concentration
MAFI             Ministry of Agriculture and Food Industry
ME               Ministry of Energy
MECTD            Ministry od Ecology, Construction and Territorial Development
MEM              Ecological Movement of Moldova, NGO
MENR             Ministry of Ecology and Natural Resources
MOD              Ministry of Defense

ECOS
Environmental Impact Assessment Report                                Page   9 of 179



MOHSP            Ministry of Health and Social Protection
MOTRM            Ministry of Transport and Road Management
NATO             North Atlantic Treaty Organization
NEAP             National Environmental Action Plan
NEHAP            National Environmental Health Action Plan
NGO              Non-Governmental Organization
NIP              National Implementation Plan
OHSE             Occupational Health, Safety and Environment
OP               Operational Policy
PAD              Project Appraisal Document
PAH              Poly-aromatic hydrocarbons
PCB              Polychlorinated Biphenyls
PCM              Public Consultation Meeting
PCT              Polychlorinated Terphenyls
PDF B            Project Development Facility (type B Grant)
PIU              Project Implementation Unit
POPs             Persistent Organic Pollutants
ppm              Part per million
PPP              Public Participation Plan
REC              Regional Environmental Center
RID              Carriage of Dangerous Goods
RISP             Rural Investment and Services Project
RPIEDM           Regulation on Public Involvement in Elaboration and Decision-
                 Making in Environmental Protection Area
SA               Social Assessment
SEI              State Ecological Inspectorate
SIDA             Swedish International Development Agency
SNIP             Construction Norms and Rules (in former USSR)
Tacis            Technical Assistance to NIS countries
ToC              Table of Contents
ToR              Terms of Reference
UN               United Nations
UNDP             United Nations Development Programme
UNEP             United Nations Environment Programme
USAID            United States Agency for International Development
US$              USA currency
WB               The World Bank
WTO              World Trade Organization


ECOS
Environmental Impact Assessment Report                                 Page   10 of 179




Executive Summary
Introduction

All World Bank and GEF projects are subject to existing Bank safeguard operational
policies and procedures, with OP 4.01: Environmental Assessment, serving as an
umbrella one. OP 4.01, § 3 stipulates that an “Environmental Assessment (EA) takes
into account the natural environment ... human health and safety; social aspects ...
transboundary and global environmental aspects. EA considers natural and social
aspects in an integrated way.” The entire EA process as set in the referred policy
applies to “projects and components funded under the Global Environment Facility.”
These safeguard policies require inter alia that: affected groups and local NGOs
must be informed and consulted as part of EA process and project design and
planning. GEF Instrument and policies stipulate that all GEF-financed projects have
to provide for full disclosure of non-confidential information, and consultation with,
involvement and participation as appropriate of, major groups and local communities
throughout project cycle.

Moldovan EA and socio-environmental legislation, which is similar to policy
objectives and operating principles, and the scope of Bank’s safeguard policies,
together with other relevant national laws and stipulations of ratified international
obligations, requires preparation of an environmental impacts assessment (EIA),
transparent and timely information disclosure and meaningful public consultations.
EIA together with project’s documentation is subject to a state ecological expertise
review, which seeks to ensure that the proposed operation is consistent with
applicable laws, international obligations and provides adequate mitigation and
monitoring of potential adverse socio-environmental impacts, and that it enhances
project’s benefits.

Project Objective

The main development objective of the project is to protect the environment and
human health through the sustainable management of POPs pesticides and PCBs
stockpiles. This objective will be achieved by environmentally safe disposal and
management of POPs, creating national capacities for implementation of the
Stockholm Convention requirements and of those stipulated under other relevant
Conventions and Protocols ratified by Moldova. As POPs routinely escape from
storage sites and from contaminated locations into the wider environment by
volatilization, by ground and surface water run-off and by other means, the global
project objective is to prevent threats to the quality of the global and regional



ECOS
Environmental Impact Assessment Report                                  Page   11 of 179



hydrological cycle, the environment, human health and well-being, and to ensure that
the POPs pollution will not recur in the future.

Project Description

The proposed project is consistent with and anchored in the Country Assistance
Strategy for the Republic of Moldova for 2005-2005 and the Poverty Reduction
Strategy Paper. The project, which incorporates international best practice and
lessons from preparing GEF-approved operations in the Slovak Republic, People’s
Republic of China and the Philippines, has four main components, which are in turn
divided into sub-components and activities. These include:

1. Environmentally Sound Disposal of Obsolete POPs Stockpiles
1.A – POPs Obsolete Pesticides Sub-Component
        (i) – Immediate repackaging and centralization of obsolete pesticides
        (ii) – Inventory and risk assessment
        (iii) – Transportation and Final disposal
1.B – PCBs Sub-Component
        (i) – PCBs detailed inventory
        (ii) – Feasibility study of remediation measures at Vulcanesti substation
        (iii) – PCBs disposal
2. Sustainable POPs Management
        (i) – Strengthening POPs institutional capacity
        (ii) – Inventory, monitoring and enforcement activities
        (iii) – Training and capacity building for POPs handling
3. POPs Public Awareness and Replication Activities
4. Project Management

Moldovan Socio-Economic and Environmental Conditions

Republic of Moldova is a small, landlocked country of 33,800 sq. km with a
population of about 4.3 million, with about 0.7 million people living in Transnistria
(a secessionist region, where no project activities are proposed under the project, and
the most industrialized part of the country.) Over 54% of population lives in rural
areas, about 50% has consumption levels below the international absolute poverty
line. The natural population growth in the last 6-7 years was negative, and population
health, particularly of children and elder people, showed signs of deterioration.

After 10 years of downturn, the economy returned to positive growth – during 2000-
2003 GDP grew by 24.1%, with the private sector accounting of almost 100% in
agricultural production, 95% in retail trade and over 80% in manufacturing. At the
same time, national development remains vulnerable to economic shocks related to
high fuel prices, energy dependence, low foreign investors’ confidence, climate and
natural changes (e.g. floods, droughts, earthquakes.)

Moldova has fertile soils and moderate continental climate, which determine high
dependence of national economic growth on agricultural production. The main

ECOS
Environmental Impact Assessment Report                                  Page   12 of 179



environmental problems are related to surface and underground water pollution, soil
contamination and increasing erosion, deforestation and loss of biodiversity, which
in turn have negative impact of population health and society well-being. While
forests cover about 9.6%, flora and fauna is protected on less than 2% of the territory
of Moldova.

In spite of the fact that Moldova never produced POPs PCB and prohibited POPs
pesticides back in early 1970s, over 50 years of overuse of pesticides and other toxic
chemicals left a damaging legacy: more than 5,650 tons of obsolete and prohibited
pesticides, with more than 1,700 tons remain scattered all over the country and stored
in 347 ramshackle storage facilities and over 4,000 tons buried in a 1974 built
landfill (including 560 tons of DDT); over 20,000 PCB-containing power capacitors
are stockpiled in 20 electric substations, with Vulcanesti substation housing about
12,000 – these are estimated to contain 380 tons of PCBs (the content of PCB in over
22,800 transformers if still unknown.) A pilot investigation, conducted during
project’s EIA preparation within POPs sites boundaries showed that soil pesticides
contamination exceeded national maximum allowable concentrations (MAC) for as
much as 10-20 times, and PCB contamination at the Vulcanesti site exceeded MAC
for over 1,000 times.

To address and prevent increasingly high risks to population and the environment,
the GRM undertook in 1997-2003 a series of regulatory and practical actions trying
to at least contain deteriorating situation. These included four GRM’s decisions
regarding pesticides’ repackaging, centralization and restoring, and allocating limited
financial resources from the budget and the National Environmental Fund to
implement them. The State Ecological Inspectorate of the MENR elaborated a
number of environmental and engineering criteria for assessing and selecting among
them suitable facilities for centralized storage in all 32 rayons of Moldova.

Moldovan Institutional Framework

Legal Framework

Since independence, Moldova has worked towards improving and shaping its own
environmental regulatory framework – to-date, over 100 laws, regulations, standards
and norms, deal with environmental and natural resources protection, use and
management in various sectors of economy have been adopted. The GRM uses a
combination of command-and-control and market-based economic instruments to
ensure their implementation and enforce compliance. Over 25 Moldovan legal and
regulatory acts deal in general terms with managing the full life-cycle of toxic and
hazardous substances and wastes, though they do not name specifically POPs
regulated by the Stockholm Convention. The above-referred acts and procedures
regulate various economic activities generating pollution; mandate environmental
impact assessment, ecological expertise and audit for pesticides and toxic substances
as well as development activities; establish environmental registration, permitting,
licensing and reporting requirements; define standard-setting, testing and monitoring
processes; regulate import, export, transportation, storage, disposal and destruction of

ECOS
Environmental Impact Assessment Report                                 Page   13 of 179



various toxic, hazardous substances, wastes, technologies and processes; provide
incentives and enforcement mechanisms.

Since 1991, Moldova actively participates in international, regional and bilateral
environmental cooperation, signing 17 and ratifying 16 international conventions,
including: Basel Convention on Transboundary Movements of Hazardous Wastes
and their Disposal; Espoo Convention on Environmental Impact Assessment in a
Transboundary Context; Geneva Convention on Long-range Transboundary Air
Pollution and Aarhus Protocol on Persistent Organic Pollutants. Moldova signed the
Stockholm Convention on Persistent Organic Pollutants on May 23, 2001 and
ratified it on February 19, 2004. On January 27, 2005, Moldova acceded to the
Rotterdam Convention on the Prior Informed Consent Procedure for Certain
Hazardous Chemicals and Pesticides in International Trade. Moldovan legislation
stipulates traditional hierarchy of ratified international environmental obligation and
norms over national ones.

At the same time, the existing regulatory framework does not stipulate 12 POPs
regulated by the Stockholm Convention and clearly define management public and
private sector responsibilities for banned POPs life-cycle. Legal framework requires
amending and clarifying existing stipulation and ensuring that certain provisions of
the Stockholm Convention and related international agreements are timely and
completely transposed into the body of national legislation, standards and norms.

Administrative Framework

In accordance with the Constitution: the President is responsible for the state of the
environment in the republic in front of the global community; and inter alia for
approving general principles of environmental policy and adopting laws, national
limits for the use of natural resources, standards for pollutants emissions and
discharges, for industrial and communal wastes accumulation; payments rates for use
of natural resources and environmental pollution, and wastes accumulation; national
environmental and related programs and plans.

The GRM implements a national environmental policy; establishes incentives to
facilitate environmental protection, clean production and reuse and neutralization of
industrial and communal wastes; coordinates environmental activities of ministries,
agencies and locals authorities; decides on siting and regimes of waste disposal and
treatment testing grounds; stimulates environmental information dissemination and
education; develops market base mechanisms of environmental management seeking
to reduce wastes generation, toxic substances emissions and discharges.

The following GRM’s agencies have responsibilities related to sustainable POPs
management:

MENR – is the primary authority responsible for: coordination national and sectoral
environmental and natural resources management, monitoring and control;
environmental inspection and enforcement; environmental standards; implementation

ECOS
Environmental Impact Assessment Report                                   Page   14 of 179



of various international obligations; control and compliance enforcement particularly
for production, storage, transportation, use, neutralization and burial of toxic and
hazardous products and substances and their wastes. It has to clear (concur to) all
Statutes, Lists and Registers on toxic and hazardous products and substances
prepared and maintained by other ministries and agencies as well as to siting of
specialized testing grounds for neutralization and burial of hazardous and toxic
products, substances and their wastes. MOH – is the primary authority responsible
for ensuring quality of population health. It establishes and maintains a National
Register of Potentially Toxic Chemical Substances and lists new substances when
necessary; amends a Statute on Procedures (Means and Methods) for the Use and
Elimination of Hazardous Products and Substances and their Wastes; issues
conclusion (opinion) regarding a Statute on Procedures for Transporting, Storing
and Use of Mineral Fertilizers and Pesticides and a List of Chemical and Biological
Means of Plants Protection and their Growth Stimulation; issues permits and
licenses authorizing activities related to use and management of hazardous products
and substances; approves maximum permitted concentrations (MPC) for pollutants in
soil, water, air and food products; conducts a toxicological-hygiene expertise of toxic
chemicals and issues authorizations for their registration as well as conducts sanitary-
epidemiological expertise. MAFI – monitors and controls compliance with
applicable laws, regulations and standards regarding use and management of
pesticides and mineral fertilizers; drafts a List of Chemical and Biological Means of
Plants Protection and their Growth Stimulations and submits it for the approval by
the Republican Inter-agency Council on Testing of Chemical and Biological Means
for Plants Protection and their Growth Stimulation; tests the above referred chemical
and biological substances and issues licenses for pesticides’ and fertilizers’ import
and export as well as maintains a registry database of their application; establishes
and maintains a network of laboratories for analysis and control of fertilizers and
pesticides quality, and monitors their concentrations in soil, forage and all
agricultural products. DES – concurs and control importing, exporting,
transportation, use and neutralization of hazardous products and substances,
particularly chemical, biological, explosives and flammables; issues permits for
importing and exporting to and from, and transporting through the Moldovan
territory of hazardous shipments as well as registers and maintaining the lists of such
shipments; approves the lists of public and private sector judicial persons which use
and are certified to transport hazardous and toxic substances; develops and approves
rules, procedures and requirements for accident and emergency preparedness and
mitigation related to transportation and use of hazardous and toxic substances.

The GRM, ministries and departments are in a state of continuous transformation:
they are merged and/or split and new short-live ones are created (their functions and
responsibilities are not timely reflected in their respective Statutes, and are often in-
consistent with existing legislation), senior officials are rotated with increasing speed
thus preventing preservation of institutional continuity and memory; and a number of
technical professional staff is reduced to bare bones, causing to question GRM’s
capabilities to manage and implement numerous already adopted programs and plans
as well as ratified international obligations.

ECOS
Environmental Impact Assessment Report                                   Page   15 of 179



Local Authorities are responsible for: ensuring compliance with applicable
legislation and standards; approving, with MENR concurrence, the limits for use of
local natural resources and accumulation of wastes, and for emissions and
discharges, except for those, which cross local boundaries; monitoring construction
and operation of purification facilities and devices at public and private enterprises as
well as implementation of measures aimed at prevention air, water and soil pollution;
developing local environmental protection programs and managing local
environmental funds; ensuring timely and transparent public participation and
information disclosure.

Project Alternatives

A thorough, unbiased, transparent and early assessment of project alternatives from
an environmental and social perspectives was one of the most important
contributions the EIA made to improving the project’s design, planning and ultimate
decision-making to ensure that selected options are environmentally and socially
sustainable, and are economically feasible. Consideration of alternatives was in line
with the overall project objective, and it unleashed creative design and planning
focused at project’s cost-effectiveness, flexibility and ease in implementation. This
approach sent an important message to all stakeholders, particularly potentially
affected local communities and NGOs that decisions regarding technologies and
locations for POPs removal and destruction would be taken based on objective
evaluation of potential socio-environmental costs and benefits, and the need to meet
Moldovan international obligations.

In the course of preparing the EIA, the local team visited and prioritized all 37
proposed pesticide centralized temporary storage facilities in accordance with the
significance of their potential risk, taking into account the capacity to store the
proposed POPs pesticides tonnage. The integrated risk matrix will be used in
elaborating the schedule and routes for final repackaging and transporting to a
selected destruction facility abroad.

Consideration of available project options built on the national process of alternatives
elaboration which took place in the country during 1997-2003, and particularly
within POPs NIP preparation and related public discussions. Short-listed alternatives
were discussed with local stakeholders and their views were taken into consideration
when proposing the preferred option(s.) Public participation was beneficial to EIA
process in two ways – it helped to 1) solicit and obtain information and views of real
importance, and 2) build consensus by creating a two-ways transparent and
respectful communication process, and ultimately establishing trust and enhancing
acceptability of selected alternatives. Public consultations were covered in national
press, radio and TV. Project’s public participation in analyzing alternatives became
one of the best ways to counter the “not in my backyard” syndrome in relation to
POPs management (created in the country by some GRM’s arbitrary decisions
earlier, and by perceived GRM’s inability to keep its promises). Local NGOs
acknowledged that project’s public participation at two stages in EIA preparation
was a transparent, timely, balanced, and responsive to stakeholder views.
ECOS
Environmental Impact Assessment Report                                 Page   16 of 179



As three of proposed project’s components are in essence supportive of institutional
development and strengthening activities with no potential for adverse socio-
environmental impacts, the EIA, though analyzing all project’s components, has
primarily focused on and evaluated two key scenarios for the project’s component 1
I. “No Project or Business as Usual,” and II. “With Project.” Within the latter
scenario, the following alternatives have been analyzed: II.1) “recoverery and local
long-term storage,” II.2) “local land-filling,” II.3) “final destruction in Moldova,”
and II.4 “final disposal/destruction abroad.” Within each alternative, in order to
incorporate best international practice additional siting, design, technology options
were also considered.

The project’s EIA was based on the assumptions that: 1) Moldova does not have
financial resources, technical capabilities and facilities for POPs environmentally
safe long-term storage, disposal and destruction; 2) there is a vocal public opposition
to POPs local long-term storage, land-filling and destruction; 3) there is POPs
disposal/destruction overcapacity in abroad (in the Western Europe, primarily by
incineration at certified facilities; a limited number of non-combustion commercial
technologies is also available; 4) there are many commercial licensed vendors, who
are in a position to offer Moldova a package deal (repackaging-transportation-
incineration) at currently low market prices, and who have access to the referred
certified destruction facilities; 5) Moldovan POPs matrixes are suitable for disposal
and destruction abroad.

I – “No Project or Business as Usual scenario” - rejected

Analysis of this option has involved projecting what would likely to happen if the
proposed GEF project is not undertaken, and the GRM would continue a) current
activities, with limited and drying out funding, to repackage and transport obsolete
POPs pesticides from over 347 sites to a to-be-determined temporary storages
located in each of 32 Moldovan rayons, i.e. local administrative territories, and b)
doing nothing in regard to a high risk PCBs storage and dump in Vulcanesti, which
requires urgent action.

Both sub-scenarios were rejected, because: all POPs pesticides and PCBs known
storages and dumps have exceeded the end their designed life-time, and have no
fencing, protection and containment; some might have been built in violation of
environmental and construction norms and standards, and not to all then mandated
specifications; some might have started leaking already and/or would start leaking
for sure, without proper maintenance, in the near future, including creating
emergency situations; some storages are loosing their integrity and increasingly
threatening the environment and public health; continuing with limited work, without
adequate funding, proper design, planning, EIA or environmental audits, without
site’s monitoring, safeguarding and decontamination will lead to higher socio-
environmental risks; ongoing repackaging and centralization is reported to be poorly
managed and implemented in violation of applicable OHSE requirements; low public
awareness and lack of timely, transparent and meaningful public consultations as
well as “broken promises” will lead to increasing public opposition and conflict
ECOS
Environmental Impact Assessment Report                                   Page   17 of 179



situations with local population and authorities; there is an uncertainty whether POPs
will remain among the GRM’s priorities. Ultimately the EIA found that this scenario
invited growing unnecessary health and environmental risks, and higher costs in the
future. Ad-hoc and un-coordinated POPs-related activities, scattered allover the
country, contribute little to regional or global objectives, and the PCB problem will
remain unattended. No-project scenario will certainly lead to Moldova failing to
comply with its international obligations under the Stockholm and related
conventions.

II – “With Project scenario”

II.1 – “Recover and long-term storage” - rejected

Recovering and putting POPs pesticides and PCBs from scattered storages and
dumps to a priority centralized sites and electric sub-stations, without proper
inventory, maintenance, monitoring, training of the personnel and safeguards, will
increase the potential for socio-environmental harm due to their vulnerability of
being released by natural disasters (slides, floods, etc.,) accidents or human failures.
More importantly, much higher costs for these POPs final disposal/destruction will
be required at a later date. Furthermore, vocal public opposition to previous GRM’s
attempts to arbitrarily decide the location of long-term storage sites will certainly
increase as in public perception this option does not differ from “business as usual”
alternative. The EIA reviewed two other possible variants under this scenario: a)
creating one centralized storage for all POPs utilizing old military facility, and b)
building a new one. Both were rejected due to vocal public opposition to the former,
and lack of suitable site or the need for a time-consuming and costly feasibility, EA
and public consultations regarding the latter.

II.2 – “Land-filling” – rejected.

Though land-filling of pesticides has been used in Moldova in late 1970s, this
scenario was rejected due to: poor experience with the existing landfill; a high
“sunk” cost; need for a timely, expensive and comprehensive site selection and
feasibility, including geological, and EIA studies. High operating, maintenance and
monitoring costs also contributed to rejecting this alternative. In addition, this option
triggers lengthy land allocation process by various local and national authorities as
well as time-consuming negotiations to obtain numerous licenses and permits.
Furthermore, PCB wastes with concentrations greater then 500ppm are banned from
landfill disposal. Lack of local capabilities to develop a technical design in
accordance with best international practice and standards, and the need to contract
expensive international consulting was another reason against this option. Significant
public opposition is almost assured under this scenario. Also important is the fact
that POPs will still require destruction at a later data, but at a much higher cost.

II.3 – “Final disposal/destruction in Moldova: i) mobile decontamination; ii)
incineration; iii) non-combustion destruction – rejected


ECOS
Environmental Impact Assessment Report                                                             Page   18 of 179



All the above reasonably available options were rejected due to: the lack of readily
available commercial technologies for i-iii in Moldova; prohibitively high costs of
deploying technologies in i-iii, including for labor, utilities, supplies, materials,
amortization, administration, etc.; the need for an expensive, time-consuming and
comprehensive site selection and feasibility, including geological, health and EIA,
studies; inadequate quantities of POPs waste streams to justify expensive upgrading,
leasing or construction of a dedicated facility(ies) for i-iii with waste pre-treatment,
crusher and control units, and on-line monitoring; the long period required (3-5
years) to deploy and/or build facilities for technologies in ii-iii in view of lacking
national environmental regulatory, technical and monitoring capabilities,
prohibitively long licensing and permitting, and subsequently long period for
upgrading or construction; the uncertainty regarding GRM’s willingness to host
incineration or non-combustion technology-type facility, and vocal public
opposition; the lacking and/or unclear liability regime; the possibility that non-
combustion and/or mobile decontamination technologies will not perform to
specifications; existing incineration overcapacity in Western Europe and low prices
for incineration abroad. Ultimately, the EIA found that any potential Moldovan POPs
disposal/destruction facility will unlikely be able to compete in the international
market place, thus making no economic, in addition to socio-environmental, reason
to be implemented.

II.4 – “Final disposal abroad: i) incineration – proposed, ii) non-combustion –
rejected

The export to the Western Europe of POPs pesticides and PCBs repackaged wastes
for incineration remains both legal and cheaper alternative, compared to non-
combustion technologies, and a preferred option5. In accordance with UNEP 1998
assessment, there were over 30 licensed and operating incineration facilities in
Europe. Due to incineration overcapacity in the Western Europe, market prices for
incineration are low and are projected to be low in the near future. The benefit of this
alternative is that POPs will be destructed at a commercial, licensed, smoothly
functioning and well-monitored facility, which meets the requirements of the
Stockholm Convention, EU and host-country legislation and applicable international
agreements, and has 99.99% destruction efficiency.

The project activities in POPs pesticides and PCBs sites as well as transportation of
the repackaged POPs to a selected destruction facility will be, in addition to
contractor(s)’ self-monitoring and reporting, supervised by the duly national




5
 “The conclusion is that incineration is not only the best, but the most cost effective. Incineration is still most
widely used and most competitive in Europe and US.” World Bank Office Memorandum from Mr. Steve
Gorman, GEF Executive Coordinator to Mr. Leonard Good, CEO/Chairman, GEF, dated April 25, 2005 at:
http://thegef.org/Documents/Project_Proposals_for_Endorsem/China_-_PCB_Mngt_Demo.pdf.

ECOS
Environmental Impact Assessment Report                                Page   19 of 179



authorities, like Environmental Inspectorate, DES and the PIU, assisted by
independent environmental management consultants. This supervision will also
include verification of socio-environmental monitoring and a pilot cleanup of the
PCB site. The verification should be reviewed and cleared by appropriate national
authorities and the World Bank/GEF.

The EIA reviewed and proposed a number of alternative transportation routes by
road and rail to the national border, which ensure compliance with the Moldovan
regulations on transporting dangerous goods by road and rail as well as with
applicable requirements under the Basel convention and European agreements, like
ADR, RID and IMDG. The EIA report also considered two environmentally and
socially safe options for direct and intermediary shipments of POPs to their final
destruction facility. All these alternatives should be refined and adapted when the
destruction facility and the recipient country is agreed upon.

Environmental Impacts

The EIA has found that the proposed project will not have significant adverse
environmental impacts on human populations or environmentally important areas
(e.g. wetlands, forests, grasslands, and other natural habitats) that are sensitive,
diverse, or unprecedented, and may take place in areas broader than individual sites
or facilities subject to physical works. The project’s potentially adverse socio-
environmental and health impacts are anticipated to be negligible to medium in
magnitude and potential significance. All impacts are primarily site specific, can be
contained within the existing POPs pesticides and PCBs site boundaries, and none of
them is irreversible.

The main potential adverse direct, cumulative and indirect socio-environmental
impacts are related to: possible POPs pesticides and PCBs leakages and
contamination at and nearest area around storages and burial sites during repackaging
at 347 old sites and centralization in the selected 37 storage facilities due to the
presence of heavy machinery and increasing numbers of workers for about week-
long time periods; possible air pollution, soil and water contamination during POPs
burial openings, excavation, accidents during national and international
transportation, temporary storage prior to export shipment, and final
disposal/destruction in a territory of a host country; remaining environmental
pollution and contamination of over 347 former POPs sites without timely and
effective clean-up and rehabilitation, which may lead to expanding the “footprint” of
POPs pollution and increasing adverse health and socio-economic impacts; socio-
environmental impact of POPs disposal/destruction facility in a host country;
inadequately wide public consultations, information disclosure and conflicts among




ECOS
Environmental Impact Assessment Report                                     Page   20 of 179



various interest groups; the lack of adequate budgeting and poor implementation of
proposed environmental and social mitigatory, monitoring and institutional
development measures as stipulated in the EMP; the weakening of political will and
changes in national priorities.

The EIA report noted that for all potential adverse socio-environmental impacts from
all project activities (which are similar and site-specific, but spatially dispersed, well-
defined and well-understood) generic avoidance, prevention, minimization,
containment, mitigation measures, outlined in numerous environmentally due
diligence, occupational, health safety (EHS) and emergency preparedness
requirements, procedures, protocols and standards, are readily available and easily
adapted, when different from local ones, to the Moldovan circumstances and POPs
waste streams. These have been translated in a comprehensive EMP.

Information Disclosure and Public Participation

The project’s EIA public consultations built on and continued comprehensive nation-
wide public dialogue with diverse national and international stakeholders and
awareness campaign which had stared during POPs NIP preparation in 2002.

The MENR and PIU announced the national 1st public consultations on a draft ToR
for the EIA and Table of Content (ToC) for an EIA report, and posted both
documents together with a project brief well in advance on web-sites of the PIU and
REC, which had a network of over 250 local NGOs. Further public announcements
were made in the media, and PIU sent e-mail invitations to over 150 groups and
individuals. Director of the PIU and Stockholm Convention National Focal Point
were key contact/resource persons for public inquiries.

The 1st public consultations, at screening/scoping stage in EIA, on draft EIA
ToR/ToC drafts took place on February 18th, 2005 with about 40 people in
attendance. The PIU, local and international consultants made extensive
presentations on project’s objectives, potential scope and components, introduced
both drafts and explained the applicable Moldovan and World Bank legislation and
safeguard policies. Stakeholders found both drafts to be good quality documents
which adequately reflected on the proposed scope of the project, potential socio-
environmental costs and benefits, and the requirements of Moldovan legislation. The
comments were summarized in the public consultation minutes and subsequently
addressed in the EA and EMP. The participants of the 1st round of public
consultations urged the PIU and MENR to: a) continue and expand a well-
established process of information dissemination and public dialogue regarding
EA/SA and project processing through PIU/REC web-sites and mass media; b) post
the final EIA ToR/ToC and SA ToR on the PIU web-site; c) hold intermediary
consultations with selected affected communities and local NGOs on a draft EIA
report at the time of arrival of World Bank pre-appraisal mission in May 2005; d)
ensure that EIA report and the EMP are public accessible and available in Moldova.

Prior to public consultations on a draft EIA report, project and EIA preparation were
enlightened and enhanced by intermediary local town-hall meetings and regional

ECOS
Environmental Impact Assessment Report                                 Page   21 of 179



workshops with primary stakeholders organized under the SA conducted by a local
NGO. Town-hall meetings were organized in all 32 administrative units of the
country. These were supported by focused classes on “POPs and Human Health” in
selected schools, conducted by the SA consultant jointly with the Ministry of
Education. Three regional workshops followed and took place in the northern,
southern and central parts of Moldova. To facilitate SA, project-specific and POPs-
related booklets in Moldovan and Russian languages were prepared and disseminated
at the above-referred meetings. During March-May 2005, the SA consultant
developed and implemented a comprehensive information dissemination and
awareness campaign in local media, including national and local newspapers, radio
stations and TV, and the REC network. A series of POPs-related articles appeared in
the Moldovan environmental monthly Natura, which has a wide outreach through
the circulation of about 20,000 and 8,000 subscribers, including all government
agencies, local mayor’s offices, educational establishments and public libraries.

While drafting an EIA report, conducting field surveys and pilot sampling to define
priorities, the local EIA team visited all proposed centralized storage sites and held
comprehensive discussions with local stakeholders ranging from representatives of
mayors’ offices to local civil society groups. These local comments and observations
were factored into the EIA and timely communicated to project’s technical and SA
teams, and the PIU.

The 2nd public consultations to discuss a draft EIA report, announced in national
newspapers, PIU and REC web-sites and network, took place on May 19, 2005, and
a draft EIA report was placed on the PIU and REC web-sites. Special invitations to
participate were sent to mayors of all 32 administrative units, where a PCB dump and
temporary POPs pesticides storage facilities are or to be located, as well as to key
stakeholders from the government, the private sector, academia and NGOs. Over 50
participants were actively engaged in discussing the draft EIA report and supported
the proposed alternative to engage a certified contractor to ensure due diligent,
environmentally and social safe collection, transportation and destruction of POPs
pesticides and PCBs in a to-be-identified licensed facility abroad. All participants
urged the GRM and the Bank to finalize and approve the project at the earliest
possible date, and particularly to speed-up its implementation.

At the same time, the participants expressed a number of concerns, particularly
related to: the GRM’s failure to comply with existing regulations and to keep its
promises regarding temporary nature of POPs storage (in a few locations, POPs
pesticides have been sitting in a centralized storage for over 2 years; poor
coordination among government agencies and donors (e.g. NATO, GEF, MOD and
MENR); inadequate prioritization and monitoring of activities within the on-going
POPs pesticides centralization process (implemented by the MOD); potential for
environmental and social risks during repackaging, excavation and transportation of
POPs due to human failure; lack of financial resources and technical means to
complete pesticides repackaging and centralized storage on-time. These issues were
addressed in the final EIA report and appropriate mitigation, monitoring and

ECOS
Environmental Impact Assessment Report                                 Page   22 of 179



institutional measures were elaborated in the project’s EMP. Other related to
collection and destruction of prohibited pesticides which might still remain in private
possession.

Environmental Management Plan

The project EMP outlines a) the mitigation, monitoring, and institutional measures to
be taken during project implementation to avoid or control potential adverse socio-
environmental impacts and to enhance project’s benefits, and b) the actions,
responsibilities and costs needed to implement these measures. The continuous,
consistent and comprehensive public consultation process helped to design
achievable EMP. Information on progress with implementing mitigation, monitoring,
institutional and awareness building activities will be shared with the public. Civil
society and NGOs will be engaged in project monitoring and implementation.

The EMP was formulated in a way that it is easy to use. References within the plan
are clearly and readily identifiable. It provides linkages to other relevant project
components and activities. The EMP was a basis for negotiations and reaching
agreement with the GOM on a project’s key socio-environmental performance
standards and outcomes. EMP requirements will be translated into bidding and
contract documents to ensure that EMP-derived obligations are clearly
communicated to contractors. None of potential socio-environmental impacts were
found to have significant, sensitive, diverse, or unprecedented adverse effects on
human populations, key social parameters and fabric of Moldovan society or
environmentally important areas (e.g. wetlands, forests, grasslands, and other natural
habitats) that are broader than individual sites and facilities subject to physical
works, or selected existing transportation routes to national borders.

The project’s various inherent socio-environmental risks, specifically those related to
recovery and excavation, repackaging, transportation, destruction of pesticides and
PCB pilot clean-up activities are easily mitigated by: comprehensive POPs inventory
and risk assessment; diligently and rigorously applying, monitoring and enforcing
readily available Moldovan OHSE requirements and internationally acceptable best
practice, standards and guidelines; utilizing commercially available and
internationally acceptable POPs mitigation, and destruction technologies; engaging,
through World Bank-approved transparent international procurement / tendering /
bidding process, of commercial licensed vendor(s) to collect, repackage, transport
and destruct POPs pesticides and PCBs at an existing licensed facility in a selected
Western European country in accordance with EU and host country legislation,
standards and applicable international agreements; improving POPs management
though regulatory modernization and administrative strengthening, capacity building,
raising public POPs awareness and civil society engagement.

Subsequently, for all project components and activities (which are similar in scope
and are site-specific, but are spatially dispersed) that are well-defined and well-
understood, the EA has referred to, developed and outlined in the EMP generic
avoidance, prevention, minimization, containment and mitigation, environmental due

ECOS
Environmental Impact Assessment Report                                                      Page   23 of 179



diligence, occupational, health safety (OHS) and emergency preparedness
requirements, procedures, protocols and standards of Moldova and those that were
readily available and easily adapted to Moldovan circumstances and waste streams
from internationally accepted and commercially available best practice, consistent
with applicable standards and stipulations of international conventions acceptable to
the World Bank.6 Technical requirements and best practice will provide a consistent
“how to” manuals that will guide the process of investigating and conducting
cleanups. The timing, frequency, and duration of mitigation, monitoring, institutional
and public outreach measures are specified in an implementation schedule, showing
links with the overall project implementation plans.

Licensed contractors bidding invited to participate in a bidding process must
demonstrate expertise and experience in the field, and access to certified
disposal/destruction facilities in a designated Western European country. Quality
control will be through intensive technical supervision by the PIU assisted by an
international environmental consultancy. Cost estimates and sources of funds were
specified for implementing all measures contained in the EMP, integrated into the
total project costs, and factored into GEF grant negotiations.

Though the clean-up and rehabilitation of POPs sites (and corresponding the liability
issue) are not financed and addressed under the project, the EIA recommended the
GRM to consider these problems on a priority basis. Cleanup standards endorsed by
the GRM, and, in their absence, those from EU and/or stipulated by WHO/UNEP
should provide a consistent measure to determine “how clean” a site must be to
protect public health and the environment.

Conclusion

Implementation of the project with well-defined EMP, with adequately budgeted and
clearly defined mitigation, monitoring and capacity building activities and
institutional responsibilities, will ensure inter alia: avoiding, preventing and
mitigating potential adverse socio-environmental impacts and enhancing project’s
environmental benefits; cleaner and safe waters and soils, agricultural products;
protecting biodiversity; improving access to global markets of local products;
increasing aesthetical and economic values of various environmental media and
property, and stimulating tourism.




6
 E.g.: in accordance with OP 4.09, § 7 “The Bank requires that any pesticides it finances be manufactured,
packaged, labeled, handled, stored, disposed of, and applied according to standards acceptable to the Bank.”
Footnote 7 further stipulates that “[t]he FAO's Guidelines for Packaging and Storage of Pesticides (Rome, 1985),
Guidelines on Good Labeling Practice for Pesticides (Rome, 1985), and Guidelines for the Disposal of Waste
Pesticide and Pesticide Containers on the Farm (Rome, 1985) are used as minimum standards.”

ECOS
Environmental Impact Assessment Report                                                        Page   24 of 179




1 Introduction
1.1    Background

The use of pesticides and other chemicals, toxic to both human health and the
environment, grew dramatically during the last 40 years in Moldova. Due to poor
management practices and the imposition of bans in the use of particular chemicals,
Moldova has accumulated over the years large amounts of PCBs and obsolete
pesticides, in particular POPs7. This poses a serious threat to human health, the local
and global environment. These substances possess toxic characteristics, are
persistent, accumulate in the tissues of most living organisms and are likely to cause
adverse human health or environmental effects near to and distant from their sources.

The total current amount of obsolete pesticides in Moldova is estimated at 5,650
tons8, including about 3,940 tons buried at a pesticide dump in the South of the
country and 1,7129 tons stored in over 300 poorly equipped or unfitted facilities
which lack proper monitoring and security. On the other side, about 20,000 PCB-
containing power capacitors are stockpiled at 20 electrical substations allover the
country. The total PCB content in these capacitors is estimated at 380 tons while the
total weight of the capacitors is approximately 1,080 tons. The power capacitors are
situated outdoors and PCBs leak from corroded equipment to the soil below the
capacitor batteries. The investigation of soil quality in the vicinity of obsolete
pesticides and PCBs stockpiles showed varying degrees of environmental
contamination posing problems of occupational health and endangering the public
health at large.

Moldova has severe public health and environmental problems linked to the intensive
use of pesticides in the past. The existence of obsolete (including POPs) pesticides
stockpiles and lack of remediation are a continuous threat to the health of thousands
of people. Poverty and ignorance push the local inhabitants e.g. to dismantle the old
pesticide stores for construction materials, to use the proximal (contaminated) lands
for crop production or grazing the cattle. Long-term exposure to POPs in such ways




7
  POP-pesticides as addressed under the Stockholm Convention are: aldrin, dieldrin, endrin, chlordane,
heptachlor, DDT, mirex, hexachlorobenzene and toxaphene.
8
  National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004.
9
  This number is provided in the registers kept by MAFI. More detailed on-site inventories showed that the total
amount is likely to be more substantial and could be between 2,500 and 3,000 tons.

ECOS
Environmental Impact Assessment Report                                                    Page   25 of 179



is likely to produce insidious chronic effects and irremediably affect people’s health.
Besides direct health effects, this may have notable impacts on the economy of rural
regions by undermining the opportunities for organic agriculture and the export
potential of food products, thus affecting the income of small farmers and the rural
poor.

The Government of Moldova acknowledges that elimination of POPs will serve the
long-term interests of public health, environment, and economic development of the
country. In October 2004, the POPs National Implementation Plan was approved10
aiming to provide a framework and management options in order to meet the
obligations taken by Moldova by joining the Stockholm Convention on Persistent
Organic Pollutants and to reach the national objectives and priorities regarding the
POPs. The Government initiated repackaging of obsolete pesticides and their storage
in a limited number of sites under more controlled conditions. Repackaging all
obsolete pesticides in the country is expected to be finalized by the end of 2005.
These activities provide an immediate solution to the current situation where
pesticides are widely dispersed and present a serious environmental and health
hazard. At the same time, the national authorities do not have capacity to handle the
problem of PCBs in power equipment present at a number of sites. The Government
of Moldova formulated a request to the GEF to assist in providing a more sustainable
solution to the POPs problem thus helping the country to comply with its obligations
under the Stockholm Convention. On the basis of this demand, the Moldova
Stockpiles Management Project is being prepared.

1.2    Objectives and Scope of the Environmental Assessment

The identification of the potential effects of the project lead to the conclusion that
despite its focus on mitigating a major source of environmental risk, the project itself
is potentially a source of significant adverse impacts. Therefore, the project was
classified as category A, according to World Bank policies, resulting in the need for
the preparation of a comprehensive environment assessment study, which was
conducted as part of the preparation of Moldova Stockpiles Management Project.
The findings and recommendations of this study are summarized in the present
report.

The objective of the environment assessment study is to evaluate the potential
environmental risks and impacts associated with the project and to identify ways of
improving project selection, siting, planning, design, and implementation by
preventing, minimizing, mitigating or compensating for adverse environmental
impacts and enhancing positive impacts. The environment assessment should include




10
  Government Decision No. 1155 of 20.10.2004 on the approval of the National Strategy and the National
Implementation Plan for the Stockholm Convention on persistent organic pollutants.

ECOS
Environmental Impact Assessment Report                                  Page   26 of 179



an Environmental Management Plan focusing on three generic areas: mitigation
measures, institutional strengthening and training, and monitoring.

It is important to point out that, the environmental assessment seeks to provide
comprehensive analysis limited - besides the PCBs - to obsolete/POPs pesticide
stocks stored at former public locations, and therefore it excludes obsolete pesticides
from private households. In addition, the environmental assessment does not extend
to issues related to manufacturing, distribution and application of pesticides.

Furthermore, since the World Bank will be the project implementing agency for
GEF, the preparation of the environmental assessment study was guided by the
requirements of the World Bank’s environmental safeguard policies (under the
umbrella of Operational Policy 4.01), as well as the international framework for
regulating hazardous chemicals and hazardous waste, and the national environmental
regulations.

1.3    Methodology

The WB has classified the project under Category A, due to the reason that persistent
organic pollutants are triggered. The environmental impacts may affect an area
broader than the sites or facilities subject to physical works. This environmental
assessment is being treated as a combination of sectoral environmental review and
more in deep assessments of critical projects sites. That is why selective, affordable,
participatory approach has been applied for EA study. Internationally accepted
methodological steps have been implemented, as follows:

Screening. This stage has been applied to determine whether a proposed project
might have significant environmental impacts. The project is beneficial by its
intention of destruction of POPs stock in the country. The obvious project benefits at
local/regional/national and international levels have been revealed and discussed
during the NIP preparation. The stakeholders and public consultations came to the
conclusion that no major environmental, health and social negative impacts are to be
expected from the project. Those remaining ones can be avoided and mitigated by
applying the international best practices and enforcing compliance. Nevertheless the
potentially affected environment may include human beings, soil, water resources,
and natural habitats, and that is why the EMP is focusing on sensitive project areas.

Scoping. The scoping stage included initial environmental examination of proposed
project activities. The outline of the Environmental Assessment has been drafted
through experts’ discussions and public consultation. The EA study boundaries lie
within the country limits, as the project has countrywide application, but emphasising
on the central rayon stores for obsolete pesticides and the Vulcanesti electric station,
as a major project component related to the PCBs stockpiles management. Two
major alternatives have been discussed namely “without project” and “with project”,
considering different project configurations.



ECOS
Environmental Impact Assessment Report                                                       Page   27 of 179



Environmental Assessment baseline. Since the project sites are spread all over the
country the description of environment has been focused on the key national
environmental concerns and aspects relevant to POPs, as well as on social and
economic country features. The findings obtained during the screening and scoping
stages guided and limited baseline description. Relevant specific information has
been collected at rayon level, including general, weather, natural disaster risks,
hydrology, soil, groundwater, flora, fauna, and protected areas information. The EA
team visited all 37 sites where centralisation of obsolete pesticides has already been
or will be implemented, as well as all identified PCBs stockpile sites (12 locations).
For each visited site, a short description and evaluation of possible environmental
impacts, identification of sensitive areas and simplified risk assessment has been
conducted. The simplified scoring matrix developed allowed ranking of central stores
against anticipated risks. The number of old and evacuated pesticides warehouses has
been reviewed by field examination in order to develop “without project” alternative
and identify residual impacts.

The study has also included a program of environmental sampling and analysis for
POPs pesticides and PCBs. The sampling program has been prepared by the EA
team, clarified by the PIU and implemented by the Hydrometeorological Service and
the State Environmental Inspectorate.

Project alternatives and assessment. Various POPs elimination alternatives have
been extensively discussed in the country for a long time. The realistic and
affordable options have been evaluated at the stage of the NIP preparation11, and,
further, have been developed by the project teams. Project impacts have been
assessed both as negative and positive ones. Among various methodologies for
impacts prediction and description the matrixes and network approaches has been
applied, as this methods allows visualising direct and indirect impacts, showing
relations between environmental components and presenting “cause-response” links.
Selected criteria were considered for determining the significance of an impact.
Criteria included severity, extent, duration, frequency, possibility of occurrence, and
possibility of reversibility. The findings of the assessment have been extensively
discussed during workshops and have been generally agreed by stakeholders and
public communities.

Environmental Management Plan. The EMP is incorporating a set of measures to
ensure the project implementation is undertaken in an environmentally sound manner
and without adverse socio-economic impacts. The EMP is focusing on three generic
areas: mitigation, institutional strengthening/training, and monitoring. All three




11
     National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004

ECOS
Environmental Impact Assessment Report                                                 Page   28 of 179



elements of EMP have been described and the responsibilities of various institutions
have been identified.

Stakeholder Participation. The method used during the EA study pertinent to the
public participation process is the participation by consultation. This is actually what
both national legislation12 and the WB OP 4.01 on Public Consultation and
Disclosure required. Its overall goal is to ensure transparency in decision making and
to provide for stakeholders the possibility to participate in the process of project
design and for designer - to improve the design of the project as well as to select the
best mitigating the environmental impact measures based to a considerable extent on
the concerned public ideas and views.

1.4    Organisation of the EA Report

The report is organized in 9 chapters. Chapter 1 provides a brief description of
project background, as well as the objectives and methodology for the environmental
assessment. Chapter 2 describes the Moldova Stockpiles Management Project
development objective and components. Chapter 3 reviews the policy and
institutional framework under which the environmental assessment has been
prepared. Chapter 4 summarizes baseline conditions across the country. Chapter 5
gives a brief overview of the analysis of alternatives considered for dealing with the
obsolete pesticides and PCBs stockpiles in Moldova. Chapter 6 presents the key
environmental and social impacts associated with the project. Chapter 7 presents the
Environmental Management Plan, including estimated costs, implementation and
monitoring arrangements. Chapter 8 summarizes the participatory approach used in
preparing the environmental assessment. Finally, Chapter 9 provides the conclusions
of this report. The report has an Appendix, which includes site-specific data and
other detailed information.




12
  Law on Environmental Expertise &Environmental Impact Assessment - No 851 from 29.05.96 and the
Regulation on Public Involvement and Participation in Environmental Decision Making – approved by
Governmental Decision No 72 from 25.01.2000.

ECOS
Environmental Impact Assessment Report                                  Page   29 of 179




2 Description of the Project
The Moldova Stockpiles Management Project grew out of the deep concern of
Moldovan society about and the sustained efforts of national authorities to rid the
country of an estimated 3,000 tons of stockpiles of obsolete and highly toxic
pesticides and 20,000 PCB-containing electric capacitors. Besides, it has to be
ensured that policy and institutional frameworks are put in place so that the problem
does not reoccur. Putting this into practice has taken about 2.5 years of preparatory
work, inter alia, enabling Moldova to assess the problems in this field and to prepare
the National Implementation Plan for the Stockholm Convention on POPs focused
primarily on measures that can mitigate the direct negative impacts on environmental
health and human well-being.

2.1    Project Objectives

The main development objective of the project is to protect the environment and
human health through the sustainable management of POPs pesticides’ and PCBs
stockpiles. This objective will be achieved by environmentally safe disposal and
management of POPs, and by creating national capacities for implementation of the
Stockholm Convention requirements and of those stipulated under other relevant
international Conventions and Protocols ratified by Moldova.

The project will complement ongoing national activities in this area, specifically
activities required under the Government Decision No. 1389 of 24/11/2003 on
collection, centralized storage and neutralization of obsolete pesticides. It will build
synergy with other IDA projects including the Energy II project, which includes
several activities with regard to detailed inventory and safe storage of PCBs in
energy sector. The project will also be linked with the World Bank-supported
Moldova Trade and Customs project, particularly in supporting development of
Moldovan Department of Customs capabilities related to monitor POPs
import/export, transportation, identification and reporting activities.

2.2    Project Beneficiaries and Project Area

The Moldova Stockpiles Management Project is designed to eliminate or reduce a
major source of risk to human health and the environment. Therefore, the benefits
coming from the project are mostly in terms of risk reduction, improvement of life
quality, and capacity building. The project will reduce threats on biodiversity since
the elimination of POPs stockpiles and their sound management would decrease the
pollutant burden and possible impacts on wildlife, domestic animals and humans. It
will contribute to improved water (including drinking water) quality by preventing


ECOS
Environmental Impact Assessment Report                                   Page   30 of 179



future contamination and threats to the water resources. The project will address land
degradation by preventing soil pollution by various POPs and especially by
pesticides. Besides its health and environmental benefits, the project would
contribute to poverty reduction and the country’s sustainable development.

The project will target areas – and surrounding communities – where obsolete
pesticides and PCB stocks are, or were, stored.

2.3    Project Components

The project will consist of four components.

Component I. Environmentally sound disposal of obsolete POPs stockpiles

This component will support on-the-ground investments for environmentally safe
disposal of obsolete POPs, including co-financing for repackaging and centralized
safe storage of obsolete pesticides, and PCBs in the energy sector, as well as their
final destruction. These activities are priority activities specified in the POPs
National Implementation Plan that was approved by Moldovan Government on
October 20, 2004 (No. 1155). There are two sub-components under this component:

A. POPs obsolete pesticides subcomponent

The Government of Moldova initiated repackaging and centralized storage of
obsolete pesticides and expects to finalize the operation in all counties by the end of
2005. These activities provide an immediate solution to the current situation where
pesticides are widely dispersed and present a serious environmental and health
hazard. However, the type of packaging used does not meet UN requirements and
most of the pesticides repackaged have not been labeled for identification purposes.
This subcomponent will finance quantification, identification and packaging of the
pesticides in UN approved containers which will then render the materials safe for
transportation and destruction. The following activities will be conducted:

(i)     Immediate repackaging and centralization of obsolete pesticides. It is
assumed that the GoM, with the support of Milieukontakt, a Dutch NGO which has
initiated a regional project on obsolete pesticides, will continue conducting this job
and will finish repackaging and centralized storage of all Moldova obsolete
pesticides. Milieukontakt will carry out demonstration work on quantifying,
identifying, packaging and storing of the pesticides in selected rayon(s), in
accordance with FAO guidelines and UN requirements. The GoM will continue to
repackage, transport and store the pesticides using the methodology applied
previously which do not fully meet UN standards due to budget constraints.
Although the materials will need to be repackaged in project financed containers, the
process of collecting the obsolete pesticides in closed plastic barrels reduces the risks
associated with handling and transport to a central station, and centralizing the
pesticides from 300+ sites to about 30, will greatly reduce the level of effort required
when packaging them in UN approved containers.

ECOS
Environmental Impact Assessment Report                                   Page   31 of 179



(ii)    Inventory and risk assessment. Many of the obsolete pesticides that have been
repackaged and centrally stored are unidentified. The purpose of this activity is to
quantify and identify the obsolete pesticides. The analytical laboratory which is
being financed by NATO will assist in this component.

A risk assessment of storage sites will also be carried out on the basis of data
gathered as part of the inventory. The risk assessment exercise will provide a risk
ranking for sites where pesticides are currently stored or were previously stored. On
the basis of this national register of sites and their risk ranking, decisions can be
made regarding prioritization of sites for further action.

(iii) Repackaging for transportation and final disposal. The objective of this
activity is to eliminate all obsolete pesticides as well as empty containers that
previously held obsolete pesticides and associated materials that have been heavily
contaminated including soil and building materials which can be removed from their
current location. The preferable option for final disposal is the export of the waste for
treatment or destruction in another country where appropriate licensed, registered
and monitored facilities dedicated for management of hazardous waste exist.
Repackaging, labelling, transportation and destruction (or other treatment) would be
carried out by a contractor appointed through international tender and selected on the
basis of both technical and financial evaluations of bids received.

B. PCBs subcomponent

This subcomponent will support the following activities:

(i)     PCBs detailed inventory. This activity will finance an inventory of PCBs in
capacitors, transformers and other electrical equipment in use at power substation
sites and large electricity consumers, as well as of PCB-contaminated equipment
used or stockpiled. According to the inventory undertaken as part of the NIP
preparation, almost 20,000 PCB-containing capacitors are located at 20 electrical
substations throughout the country. The total PCB content in this equipment is
estimated at 380 tons while the total weight of the capacitors is approximately 1,080
tons. Besides the use in the energy sector capacitors are widely used by large
consumers of electricity. An inventory of capacitors held by electricity users has not
been undertaken yet. Based on expert judgement the total PCB content of those
capacitors is roughly estimated at 20-50 tons. The project will assist in conducting
the full inventory of PCBs in capacitors in the country.

According to an inventory of the electrical equipment a total of 22,806 power
transformers are in use in the country. The total content of oil in transformers is
approximately 18,000 tons whereas about 5,400 tons are in use in switches, inductors
and other equipment. Whether this equipment is or not contaminated with PCBs is
largely unknown. The project will provide for the inventory of contamination of oils
in transformers and other electrical equipment.



ECOS
Environmental Impact Assessment Report                                  Page   32 of 179



(ii)    PCBs disposal. The PCB-containing capacitors in the electrical substations
are a significant and growing menace to the environment. The project will support
the final disposal of the PCBs contained in capacitors in a specialized facility abroad.
All capacitors at the substations are to be dismantled from the batteries, packed in
UN-approved IBC containers, stored for a short time at the substations before final
shipment for disposal outside the country. This would include excavating broken
capacitors buried at the Vulcanesti station.

(iii) Feasibility study of remediation measures at the Vulcanesti substation. Due
to the incidents with capacitor explosions and leakage by corrosion the steel
construction holding the capacitors at the Vulcanesti substation and the ground below
may be highly contaminated. The project will conduct a feasibility study to identify
the most cost-efficient measures for preventing further dissipation of the PCBs from
the contaminated site to the surrounding. The study will include an exact mapping of
the contaminated sites, sampling and analysis, mapping of PCBs contamination
levels, site environment characterisation, risk assessment, and assessment of different
site cleanup designs. After decision on the site cleanup design a detailed work
schedule for cleanup including standard safety procedures will be prepared. The
feasibility study and remediation of the Vulcanesti station may serve as
demonstration project for future remediation measures at other substations and other
contaminated sites.

Component II. Sustainable POPs Management

Within this component three groups of activities will be financed:

(i)     Strengthening POPs institutional capacity. The project will support: (i)
developing integrated POPs management, including creation within the MENR of a
Center on Chemical Safety and strengthening of Waste Management Sector to
coordinate and manage Moldovan national obligation related to the transposition of
modern regulations and international obligations under several international treaties
related to POPs and specifically Basel, Stockholm, LRTAP and its Aarhus Protocol
(and potentially Rotterdam Convention); and (ii) conducting a revision of existing
legal and institutional arrangements (gap analysis; comparing EU legislation and
Convention requirements – preparation of Table of Concordance; revision of
international obligations related to POPs and hazardous wastes and updating of
national legislation in this area). These activities will include development of a
regulation on the responsibilities of electrical equipment owners to notify and label
the equipment; development of guidelines for identifying PCB-containing
equipment. It is also proposed to develop a license system for undertakings involved
in decontamination, dismantling and removal of PCB-containing transformers, as
well as to develop a system for management of PCB-containing waste and obsolete
PCB-containing equipment as an integrated part of a general hazardous waste
management system.

(ii)   Inventory, monitoring and enforcement activities. This subcomponent will
finance support for the: (i) strengthening the enforcement capacity (MENR,

ECOS
Environmental Impact Assessment Report                                Page   33 of 179



Department of Customs, Ministries of Energy, Agriculture and Industry) to ensure
compliance with regulatory controls; (ii) developing innovative financial
mechanisms for environmentally safe disposal of POPs (and hazardous waste) and
for sustainable POPs (and hazardous waste) management; (iii) developing procedures
and guidelines for monitoring and reporting, as well as for creating a new permitting
system, based on the EU IPPC Directive; and (iv) improving environmental
monitoring by upgrading the analytical laboratory capacity for conducting POPs
analyses and identification.

(iii) Training and capacity building for POPs handling. This subcomponent will
support relevant training activities for target beneficiaries - MENR, ecological
inspectors, Hydrometeorological Service, Moldelectrica. A special attention will be
on training for the Moldelectrica and other staff that would do the actual work for
POPs inventory, repackaging and restoring on the ground. Guidelines and Procedures
will be prepared for environmental inspectors and the staff involved in POPs
handling. Additionally there will be developed special Guidelines for safe re-
packaging POPs pesticides and PCBs.

Component III. POPs public awareness and replication activities

This component will be based on the Communication Strategy prepared by the GEF
POPs enabling activities project. The component will support public awareness and a
participation program on POPs related environmental and health problems, as well as
replication of project results across the region. The project will also support
improving inter-agency information sharing and information management system as
well as strengthening of National Environmental Information Center - relation to
EIONET and relevant international Convention Secretariats; database of
comprehensive, accurate and regularly updated aggregated information quantifying
POPs, with the possibility for upgrading (by other sources and projects) for other
relevant environmental information.

Component IV. Project Management

This component will finance implementation of the project including, incremental
operating costs of the PIU, audit services, and monitoring and evaluation.

2.4    Project Financing, Coordination & Support

It is expected that total project cost will be at the level of US$ 13.22 million. The
GEF will finance US$ 7.2 million which will be complemented by financing from
the Government of Moldova (US$ 1.47 million including IDA credits Energy II and
RISP 2, as well as in-kind contribution from project beneficiaries), and other donors
at the level of about US$ 4.55 million.

The GEF project will build on the baseline activities that are being/will be
undertaken by the Government of Moldova by providing additional support to
overcome identified threats. GEF resources and common efforts coordinated by the

ECOS
Environmental Impact Assessment Report                                  Page   34 of 179



Government, interested Ministries and local population, will allow implementation of
an efficient management system for obsolete POPs stockpiles including safe storage.
GEF funding will provide the resources essential to accelerate the POPs activities,
demonstrate the need for a holistic approach to POPs sustainable stockpiles
management and safe elimination, and undertake a public outreach program.

The ongoing government commitment to the project is evident by the activities
underway to address POPs. In 2003-2004, 4 million MDL were allocated for the
centralized storage from the State Budget and the National Ecological Fund. In 2005,
the allocated budget was raised to 6 million MDL. With this financing, the Ministry
of Defence and the Department for Emergency Situations have started repackaging
and safely storing obsolete pesticides. To-date, more than 1,700 tons of these
substances have been repackaged and stored. In 7 out of a total of 37 districts the
work has been completed. In another 14 districts the MOD together with DES have
initiated repackaging. Moldova will support the project activities further with funds
within the World Bank WB Energy II project. The Energy II project provides US $
0.2 million for activities related to PCBs disposal in the energy sector.

The Government of Moldova has launched discussions with bilateral donors (France,
Denmark, Turkey, NATO) regarding investment and technical assistance for
complete destruction of obsolete POPs. So far, two co-financing arrangements have
been reached including:
●    Euro 0.125 million NATO project on upgrading MAFI analytical laboratory
     capacity to identify the content of obsolete pesticides. Based on the request of
     Moldovan Government, NATO will provide laboratory equipment as well as its
     operating costs for the next 2 years.
●    Euro 0.77 million MILIEUKONTAKT project on elimination of acute risks of
     obsolete pesticides. This project will support demonstration activities for
     obsolete pesticide storage sites remediation as well as technical assistance for
     conducting these activities, and for strengthening institutional capacities in this
     regard. Furthermore, the project will support a broad information dissemination
     and public awareness campaign.

Further consultations are needed to identify complementarities for the proposed
activities and projects and possible co-financing.




ECOS
Environmental Impact Assessment Report                                Page   35 of 179




3 Legal and Institutional Framework
3.1       National Policies, Strategies and Programs

The most important policy documents developed over the last decade relevant to the
environment protection in general and particularly to the management of toxic and
persistent chemicals are:

The National Implementation Plan (NIP) for the Stockholm Convention on
Persistent Organic Pollutants (POPs), approved by the Government in October
200413, provides a policy framework and describes interventions which are needed to
reach the national objectives and priorities regarding management of POPs and
enabling Moldova to reach its obligations under Stockholm Convention;

The Economic Growth and Poverty Reduction Strategy Paper (2004-2006) is the
overarching policy framework for the sustainable development of the Republic of
Moldova in the medium term. It serves as the basis for developing and implementing
new assistance strategies by international financial organizations and donor
countries, as well as for the preparation of the annual state budgets for 2005 and
2006. The environmental component of the Paper makes direct reference to the POPs
centralized environmental sound storage and destruction as a short-term action;

The Mid-term Strategy for Socio-economic Development of the Republic of
Moldova to 2005, approved by the GRM in 2001, stipulates that ecological-
economic goals shall include: regulating impacts from economic activities on the
environment; preventing environmental pollution and ensuring environmental quality
and rehabilitation; improving methods for utilization of natural resources and
ensuring their continuous and safe exploitation; improving environmental education;
enhancing environmental research and implementation of environmentally clean
technologies. Also it is mentioned that international environmental standards will be
introduced in all sector of national economy, particularly the ISO 14000 standards.

The Concept of the Environmental Policy of the Republic of Moldova (2001)14 is
the document which formally replaced the Republic of Moldova National
Environmental Action Plan (NEAP) which (the latter) has determined the




13
     Government Decision no. 1155 of 20 October 2004.
14
     Approved by Parliament Decision No 605-XV of 2 November 2001.

ECOS
Environmental Impact Assessment Report                                 Page   36 of 179



development of the environment management system of the country within 1996–
2000. The Concept has two key objectives to: 1) prevent and reduce negative impacts
of economic activity on the environment, natural resources and health of the
population within a framework of national sustainable development, and 2) ensure
ecological security of the country. Main directions of Moldavian environmental
policy include inter alia application of two principles – “economy through ecology”
and “cost-benefit”. Relevant to the current study the following statements present in
Concept should be mentioned: introduction of clean technologies and improvement
emissions & discharges purification, wastes minimization, collection, neutralization,
recycling and reduction of their toxicity. Politically the Concept is clearly oriented
toward European integration.

The National Environmental Health Action Plan (NEHAP, 2002) provides
directions for the next 10 years for protecting human health and assigns
responsibilities among Government agencies, with specific focus on aligning the
country with EU by ensuring harmonization with its policies, procedures and
practices. NEHAP has a few references to POPs, including in: § 4.1-Water
stipulating elaboration of a POPs decontamination system for waste water
discharges; § 4.2-Air stipulates development of POPs air emissions monitoring
systems and of a program for “neutralization” of the referred emissions; § 4.3-Soil
seeks to encourage improving existing legislation and elaborating new maximum
allowed concentration for various POPs as well as provides for establishing a
national POPs inventory; § 4.5-Food – stipulates improved control of pesticides
contamination of food; § 4.10-Natural Catastrophes and Industrial Accidents
provides for creation of a national register of potentially toxic chemicals; § 5.1-
Sectors of the economy provides for elaboration of a control system for electrical
transformers, which contain PCB; § 5.4-Agriculture stipulates developing regulations
regarding importing, storage and use of pesticides.

The National Program for Industrial and Consumption Wastes Utilization
(2000)15 was developed based on the principle of wastes minimization, their
maximum economic utilization and ecologically justified disposal of wastes. The
Program seeks to promote ecologically clean production aiming at reduction and
prevention of wastes accumulation, pollution prevention and ecological
effectiveness. The scope of applicable standards is defined as well as reference is
made to the requirements of the Basel Convention and relevant rules of EU.

The Energy Strategy until 2010 (approved in 2000) set the strategic goals of the
energy sector: increase of energy efficiency and energy supply, ensure the energy
production and environmental safety. The Strategy is focusing on introducing less




15
     Adopted by Government Decision No. 606 of 28 June 2000.

ECOS
Environmental Impact Assessment Report                                  Page   37 of 179



polluting energy technologies aimed at preventing and minimizing environmental
pollution.

The National Program on Ecological Safety (approved in 2003) tackles the natural
and man-made impacts which may result in the degradation of environmental
ecosystems and may affect the human health. Among considered man-made impacts
are those arising from the industry, agriculture, power engineering etc. and those due
to transboundary pollution and wastes generation. The actions to be taken to secure
the ecological safety include comprehensive monitoring, risk assessment, ecological
insurance, prevention and warning system, international and regional cooperation.

The Concept of Sustainable Development of Settlements in Moldova (approved in
2001) promotes the creation of favorable conditions in localities and involving of
population in decision-making process in the field of environmental protection.

The Investment Strategy of the Republic of Moldova (2002)16 proclaimed that one
of the major national investment goals is to attract and increase investment into
environmental protection, raising efficiency of utilization of natural resources and
reducing negative environmental impacts due to economic activity. It also seeks
continuation of harmonizing national legislation and standards with that of EU.

The Strategy to Facilitate Export in 2002 – 2005 stated that Moldova, as a full
WTO member (since May 2001) shall pay great attention to environmental
protection and related requirements of international trade agreements. In addition, in
order to establish a free economic zone with the EU, Moldova must demonstrate
progress in a number of areas, including harmonization of legislation and
standardization.

3.2       National Legislation and International Obligations

National Laws

The laws governing the implementation of the national policies and their
implementation being the most relevant ones toward the persistent organic pollutants
control in Moldova are as follows:

Constitution of the Republic of Moldova (adopted in 1994, amended in 2000). The
overall goal of environmental protection in the country is defined by the Constitution
of the Republic of Moldova which declares that each person has a right for the
ecologically safe environment.




16
     Approved by the Government Decision No. 234 of 27 February 2002.

ECOS
Environmental Impact Assessment Report                                  Page   38 of 179



Law on the Environmental Protection (1993) established a legal foundation for
developing normative acts and regulations applicable to different environmental
media in order inter alia to protect land and subterranean resources, waters and air
from “chemical, physical and biological pollution, and from other impacts.” The law
sets the basic principles of environmental protection, including the priority of
environmental goals, mandatory environmental compliance, environmental liability,
prohibition of implementation of any programs and projects without a positive
conclusion of the state ecological expertise and concurrence by the population in the
area of impacts, payments for use of natural resources and non-compliance, and use
of collected monies for environmental mitigation and rehabilitation.

The Law on Ecological Expertise and Environmental Impact Assessment
(EE&EIA, 1996) determines the goals, objectives and principles of Ecological
Expertise and Environmental Impact Assessment, as well as fundamentals of both
procedures (the detailed description is provided in the sub-chapter 3.5.1 below).

The Law on Regime for Hazardous Products and Substances (1997) establishes
the legal basis for activities related to production, storage, transportation and use of
hazardous and toxic products and substances as well as their import and export in
order to avoid, reduce or prevent their negative impacts on population and
environment.

The Law on Wastes from Industrial Production and Consumption (1997) aims at
fostering efficient management of wastes in order to reduce their amount and
increase recycling, reuse and prevent environmental pollution and degradation. § 3
stipulates that the government develops and approves the State Program for Use of
Wastes of Production and Consumption; coordinates activities of relevant ministries
and department; approves a Statute on Waste Management, establishes limits for
waste disposal, approves Procedures for Using Licenses for Waste Management.

The Law on Payment for Environmental Pollution (1998) proclaims that the aim
of the law is to create an enabling economic system which will: make it unprofitable
to pollute the environment, stimulate construction and operation of waste purification
and utilization systems and introduction of clean processes and technologies as well
as create environmental funds to finance environmental investments.

The Law on Water Protection Zones and Strips of Rivers and Water Bodies
seeks to ensure protection water in rivers and water bodies from pollution, depletion
and degradation as well as to regulate economic (industrial and agricultural)
activities in protected zones and strips. § 13 stipulates certain restrictions on
activities in established water protection zones, particularly prohibiting siting and
construction of storage facilities for mineral fertilizers and pesticides, pesticide
preparation and mixing facilities and construction of waste water treatment facilities.
This article also stipulates a permitting regime to be jointly enforced by MECTD and
MOH. §§ 16 – 18 establish monitoring, control and enforcement regime in protected
zones as well as liability for violation and non-compliance with the law.


ECOS
Environmental Impact Assessment Report                                   Page   39 of 179



The Law on Civil Protection (1994) § 1(1) stipulates that civil defense is a system
of statewide measures and activities implemented in peace and war times in order to
protect population from natural and environmental disasters, accidents and
catastrophes, natural hazards and fires as well as from weapons of mass destruction.
§ 1(7) establish a Department of Civil Defense and Emergency Situations as the
central sectoral public management body.

The Law on Fund of Natural Areas Protected by the State (1998) deals with
various types of specially designated national territories. § 5 refers to Moldovan
obligations and requirements under international conventions, agreements and
treaties, namely: 1992 Convention On Biological Diversity, 1979 Bern Convention
On the Conservation of European Wildlife and Natural Habitats, 1979 Bonn
Convention on Conservation of Migratory Species of Wild Animals and 1971 Ramsar
Convention On the Wetlands of International Importance Especially as Waterfowl
Habitat. § 26(c) prohibits the use and application of mineral fertilizers, herbicides,
pesticides and other toxic chemical substances in protected areas of scientific
importance.

The Law on Transport § 2(2) stipulates that relevant Moldovan international
obligations have priority over provisions of national legislation, norms and standards.
§ 6(3) provides that transport enterprises and facilities shall ensure sustainable use of
land, prevent water-logging, reduction of land quality and soil contamination by
wastes and untreated waste-waters, prevent erosion and land-slides and comply with
environmental legislation. § 9(d)(e) instruct transport enterprises to protect the
environment from negative impacts of transport activities, ensure compliance with
environmental legislation, standards, labor norms as well as certify transport
activities and facilities in accordance with applicable international standards. § 13(4)
prohibits siting of transport facilities, which handle explosives, flammables,
radioactive, poisonous and toxic substances, close to residential areas, protected
natural territories. An appropriate minimum distance shall be approved by special
legislation and norms. § 13(7) established that senders and recipients of explosives,
flammables, radioactive, poisonous, hazardous and toxic shipments must assure the
safety of loads and their transportation and have mobile units and means to prevent
and mitigate accidents during transportation of such items.

The Law on Standardization proclaims standardization as one of major factors in
developing of national economy and environmental protection, and § 3 provides that
the standardization aims at protecting consumers’ rights, ensuring quality of
products, processes and services, safety, health and environmental protection. § 4
stipulate the following standards in Moldova: national standards, professional
standards, and standards of firms. Other standards include: technical regulations,
medico-biological regulations, sanitary norms, sanitary-hygiene norms and rules,
environmental protection norms. § 4(4) stipulate that the above standards and norms
shall be based on the latest achievements of science and technology, international
and regional standards, etc. § 8 stipulate that each ministry, agency and economic
object, irrespective of the form of ownership, shall have a unit responsible for

ECOS
Environmental Impact Assessment Report                                  Page   40 of 179



standardization process and compliance. § 9 establish the process and procedure for
developing and approving national, sectoral, media and product standards.

The Law on Health Protection stipulates that public administration shall take all
necessary social and medical measures to prevent illnesses, improve the
environment, maintain the safe and hygiene life and working conditions, etc. § 17
proclaims the citizens right to health and the preservation of national gene fund,
which assured inter alia by the safe environment. § 19 stipulate that every citizen has
the right for compensation of health damages caused by various negative factors,
including the violation of sanitary-epidemiological norms.

The Law on Licensing Certain Types of Activity (2001) seeks to define legal,
organizational and economic foundation and scope of the licensing activity. § 2
stipulate that a license is a document, issued by a licensing authority, which certifies
the right of a licensee to implement certain activity under the condition of
compliance with stipulated requirements. § 8 provides a list of activities subject to
licensing, including: (32) storage of toxic chemical substances and products.

The Law on Industrial Safety of Hazardous Industrial Facilities establishes legal,
economic and social foundation for safe operation of hazardous installations and
seeks to prevent accidents and timely localization and rehabilitation of their
consequences as well as to protection the environment and population. § 4 and
Annex 1 establish the notion and a list of dangerous production objects. § 5 stipulates
that hazardous activities shall be conducted in accordance with industrial safety
requirements and shall ensure protection of the population and territories from
emergency situations, in accordance with sanitary-epidemiological, environmental,
fire, sanitary-hygiene and construction norms and requirements.

The Law on Access to Information (2000) regulates relationships between
providers and users of information, establishes principles, conditions and procedures
for ensuring access to information, determines the rights of people requesting
information and obligations of providers of information, and creates a mechanism for
protection of the right to access to information. § 4 establishes state principles of
access to information, including the right of any person to search, receiving and
reviewing official information, and prohibits discrimination based on race,
nationality, ethnic origin, language, gender, views, political affiliation and social
origin. § 7 established the scope and procedures for limiting access to information. §
20 stipulate principles of payment for receiving official information. § 21 stipulate
the general principles for protecting the right to access to information.

The Water Code (1993) seeks to ensure sustainable water use, protect water
resources from pollution, contamination and depletion as well as prevent negative
impacts of polluted waters on human health. §§ 8 – 12 established that siting, design,
construction and launching into operation of any new or reconstructed facilities and
other objects is permitted only after completion of a state sanitary-epidemiological
expertise and only when such facilities have water purification and pollution
prevention devices.

ECOS
Environmental Impact Assessment Report                                 Page   41 of 179



The Land Code (1991) proclaims protection of land to have higher priority than
other types of land use activity. §6 stipulates that the State shall financially and
administratively support inter alia development of various types of effective land
management and use, including those aimed at reducing land pollution by waste, and
research regarding interrelationships between environmental and land protection. §
16 requires routine coordination with a national environmental authority regarding
any plans for land development and construction. §31 instruct all industrial,
communal and other land users and owners to prevent any negative impacts of
agricultural lands. The Code establishes different types of land based on the purpose
of their use and mandates respective protection regimes. Chapter XII deals with
protection and improvement of land quality. §80 stipulate that land protection
measure shall be elaborated and implemented at planning, design, construction and
operation or various facilities and technologies. The Code prohibits launching into
operation of any facilities and technologies that do not protect land. §82 stipulates
that in order to protect land quality, environment and health of people, maximum
permissible concentrations of chemical, biological and other active substances in soil
shall be elaborated and approved by separate legislation. This Code is complemented
by the Law on State Land Management, State Land Cadastre and Land
Monitoring (1992).

The Code on Underground Resources (1993) aims at sustainable use of natural
resources, environmental protection and safe mining activities. In accordance with
§35 underground storage of toxic substances and wastes is authorized only under a
special permit to be issued by a national environmental authority, and such storage is
allowed only after the completion of a state ecological expertise. The burial of
extremely toxic and radioactive wastes is established by other legislation.

International Conventions

There are a number of Conventions ratified by Moldova with direct relevance toward
the POPs Project:

Stockholm Convention on Persistent Organic Pollutants (Stockholm, 2001) was
ratified in 2004. The overall objective of the Convention is to protect human health
and the environment from POPs that remain intact in the environment for long
periods, become widely distributed geographically, accumulate in the fatty tissue of
living organisms and are toxic for humans and wildlife.

Convention on the Control of Transboundary Movements of Hazardous Wastes
and their Disposal (Basel, 1989) was ratified in 1998. The goal of the Convention is
“environmentally sound management”, the aim of which is to protect human health
and the environment by minimizing hazardous waste production whenever possible.
Environmentally sound management involves strong controls from the generation of
a hazardous waste to its storage, transport, treatment, reuse, recycling, recovery and
final disposal.



ECOS
Environmental Impact Assessment Report                                 Page   42 of 179



Convention on Long-Range Transboundary Air Pollution (CLRTAP, Geneva,
1979) was ratified in 1995. The Convention aims to protect human and his
environment against air pollution and endeavor to limit and, as far as possible,
gradually reduce and prevent air pollution including long-range transboundary air
pollution.

Aarhus Protocol to CLRTAP on Persistent Organic Pollutants was signed in
1998. The Protocol on Persistent Organic Pollutants (POPs) focuses on a list of 16
substances that have been singled out according to agreed risk criteria. The
substances comprise eleven pesticides, two industrial chemicals and three by-
products/contaminants. The ultimate objective is to eliminate any discharges,
emissions and losses of POPs. The Protocol bans the production and use of some
products     outright    (aldrin,  chlordane,    chlordecone,   dieldrin,   endrin,
hexabromobiphenyl, mirex and toxaphene). Others are scheduled for elimination at a
later stage (DDT, heptachlor, hexaclorobenzene, PCBs). Finally, the Protocol
severely restricts the use of DDT, HCH (including lindane) and PCBs. The Protocol
includes provisions for dealing with the wastes of products that will be banned. It
also obliges Parties to reduce their emissions of dioxins, furans, PAHs and HCB
below their levels in 1990 (or an alternative year between 1985 and 1995). For the
incineration of municipal, hazardous and medical waste, it lays down specific limit
values.

Convention on the Prior Informed Consent Procedure for Certain Hazardous
Chemicals and Pesticides in International Trade (Rotterdam, 1998) was ratified
in 2004. The purpose of this Convention is to promote shared responsibility and
cooperation in the international trade in certain hazardous chemicals. In order to
protect human health and the environment from potential harm, the Convention
facilitates the sharing of information and prior informed consent among joined
countries and contributes to the environmentally sound management of certain
hazardous chemicals. Presently, the Convention covers 27 pesticides (including five
severely hazardous formulations) and five industrial chemicals. Additional
pesticides, industrial chemicals or formulation are added as they meet the
Convention's criteria

Convention on Environmental Impact Assessment in a Transboundary Context
(Espoo, 1991) was ratified in 1993. The Convention sets out the obligations of
Parties to assess the environmental impact of certain activities at an early stage of
planning. It also lays down the general obligation of States to notify and consult each
other on all major projects under consideration that are likely to have a significant
adverse environmental impact across borders.

Convention on Transboundary Effects of Industrial Accidents (Helsinki, 1992)
was ratified in 1993. It is designed at protecting human beings and the environment
against industrial accidents by preventing them as far as possible, by reducing their
frequency and severity and by mitigating their effects. It promotes active
international cooperation between the contracting Parties, before, during and after an
industrial accident.
ECOS
Environmental Impact Assessment Report                                  Page   43 of 179



Convention on Access to Information, Public Participation in Decision-Making
Process and Access to Justice in Environmental Matters (Aarhus, 1998) was
ratified in 1999. The Convention requires guaranteeing the rights of access to
information, public participation in decision-making and access to justice in
environmental matters and refers to the goal of protecting the right of every person of
present and future generations to live in an environment adequate to health and well-
being, which represents a significant step forward in international law.

3.3       Applicable National and International Standards

National Regulations

When talking about the applicability of international and national standards toward
the POPs Project implementation the process driven approach is used. It means that
the subject of analysis was the standards and normative determining the processes of:
    (i)     identification
    (ii)    packaging (packaging for transport and packaging for storage)
    (iii)   transportation and
    (iv)    storage of POPs and PCBs.

The following, pertinent to the POPs issue, Regulations are in force:

Regulation on Transportation of Hazardous Materials on the Territory of the
Republic of Moldova17 stipulates that DES and MECTD are responsible for
supervising of importing, exporting and transportation of hazardous substances and
products. § 5 make MECTD responsible for monitoring and control of hazardous and
toxic wastes across Moldovan borders in accordance with requirements of the Basel
Convention. §7 makes Customs Department responsible for ensuring control and
monitoring and enforcing compliance with applicable legislation and regulations
when hazardous loads are transported across national borders. §9–13 provide a
classification of hazardous shipments, which are subject to different transporting
rules and procedures depending on their toxicity, explosiveness, flammability,
poisonous, etc. as well as introduces UN accepted marking of dangerous goods. In
accordance with §65, MECTD ensures monitoring, control and enforces compliance
with applicable environmental legislation regarding toxic and hazardous substances
and product, while DOC and Road Police monitors and enforces the referred rules.

Regulation on Control over Transboundary Transportation of Wastes and their
Disposal18 sets the national transportation rules complying with the ADR provisions.




17
     Government Decision No. 672 of 28 May 2002.
18
     Government Decision No. 637 of 25 May 2002.

ECOS
Environmental Impact Assessment Report                                 Page   44 of 179



Regulation on National Monitoring and Laboratory Control Network for
Monitoring Environmental Pollution by Radioactive, Poisonous, Highly Toxic
Substances and Bacteriological (Biological) Substances19 sets the objectives, the
structure of this system and designates and designates the implementing agencies,
namely: MOH Centers for Preventive Medicine, MAFI subordinated centers and
laboratories, Hydrometeorological Centre and the MECTD.

Regulation on Assessment of Environmental Impacts of Enterprises subject to
Privatization20 sets the procedure of environmental impact assessment at economic
entities posing environmental risks. The latter include units which produce, store,
pack and/or sell: pesticides, electric equipment containing PCBs, plastic materials,
fertilizers, etc.

Sanitary Regulation on Storage, Neutralization and Landfilling of Toxic
Substances and Wastes21 sets the requirements for storage and disposal of toxic
substances and wastes from industrial enterprises and agriculture farms. It stipulates:
the criteria for site selection; requirements for landfill design and construction;
criteria for selecting the methods of disposal; requirements for landfill
inspection/checks; analytical methods for pollutants determination in soil.

Regulation on Management of Phyto-Sanitary Products and Fertilizers in the
National Economy22 is the basic document setting mandatory sanitary,
environmental and hygienic requirements for all aspects of agriculture chemicals
management. The requirements in the following areas are particularly pertinent to the
Project activities: storage and transportation of phyto-sanitary products;
decontamination of transport units, equipment, packaging materials and premises;
safety measures; and individual protection equipment.

Regulation on Procedures and the Statute for Selection and Information
Exchange in the Protection of Public Areas in Emergency Situations 23 defines
natural and man-caused emergency situations and their sources, including those that
were caused by accidents which lead to emissions and discharges of toxic and
hazardous substances and subsequent pollution of various environmental media and
disrupted routine public life style.

Regulation on Public Involvement in Elaboration and Decision-making in
Environmental Protection Area (RPIEDM) 24 establishes the procedure of public




19
   Government Decision No 477 of 19 May 2000.
20
   Government Decision No 394 of 8 April 1998.
21
   Chief Sanitary Ordinance of 3 November 1995.
22
   Approved by MAFI Ordinance No. 231 of 28 November 2003.
23
   Government Decision No. 347 of 25 March 2003.
24
   Government Decision No. 72 of 25 January 2000.

ECOS
Environmental Impact Assessment Report                                                   Page    45 of 179



involvement and participation in environmental decision making. The regulation
proclaim the main principle of decision making: public involvement should
anticipate any decision on planned activities likely to negatively impact the
environment. The Regulation sets the responsibilities and rights of main actors:
public, developer and local authorities.

National Standards

The following national standards are applicable to the identification, packaging,
transportation and storage processes envisaged by the Project:

Hygienic Norms for the Content of Residues of Phyto-Sanitary Preparations in
the Environment25 stipulate the maximum allowable concentrations/limits of
pesticides residues in the environment as well as the maximum daily intake values;
lists the pesticides determination methods and sets their costs.

General Sanitary-Hygienic Requirements for Air Quality of the Working
Areas26 set maximum allowable concentrations for toxic chemicals in the air of
working areas (e.g. industrial premises, open air, transport units).

Sanitary Rules for Protection of the Atmospheric Air in Residential Areas 27 set
general requirements for all economic entities which are sources of air pollution.

General Requirements for Protection of the Surface and Ground Waters
against Pollution with Pesticides28 stipulate the requirements concerning the
sanitary zones for groundwater intakes and protection zones for rivers. It provides the
classification of pesticides according to their polluting potential for groundwater as
well as to their risks for living organisms.

General Requirements for Categorizing the Soils according to the Impact of
Chemical Pollutants on them29 provide a classification of soils depending on their
tolerance to chemical pollutants.

Safety Requirements for Use of Pesticides for Plant Protection 30 apply to all
activities related to the use of pesticides, including storage; loading; transportation;
decontamination of premises and transport units; and use of individual protection
equipment.




25
   Chief Sanitary Ordinance No. 06.3.3.50 of 21 August 2003.
26
   GOST 12.1.005-88.
27
   Approved by the Ministry of Health Protection of USSR, Decision No. 4946-89 of 16 May 1989.
28
   GOST 17.1.3.04-82.
29
   GOST 17.4.3.06-86.
30
   GOST 12.3.041-86.

ECOS
Environmental Impact Assessment Report                                    Page   46 of 179



Rules for Pesticides Acceptance,                      Sampling,   Packaging,     Labeling,
Transportation and Storage31.

Construction Norms for Dry Fertilizers and Pesticides Storage Facilities 32 set
the requirements to be complied with when designing storage facilities for
agriculture chemicals, including building, operating and environmental safety
requirements.

Guidelines for Designing Landfills for Toxic Industrial Wastes33 stipulate the
requirements concerning siting, capacity, collection of toxic wastes, methods of
disposal, sanitary protection zones and environmental monitoring.

Instruction concerning the Selection, Preparation and Sending of Obsolete
Pesticides and their Package Materials for Disposal34 stipulates the requirements
related to the process of identification/selection of obsolete pesticides; and the
organization of their sending to specialized facilities for disposal.

International Standards

In terms of identification, packaging, transportation and storage the provisions to
follow are put down in the (i) Basel Convention General Technical Guidelines for the
Environmentally Sound Management of Wastes Consisting or, Contaminated with
Persistent Organic Pollutants (POPs)35 as well as in the (ii) Basel Convention
Technical Guidelines for the Environmentally Sound Management of Wastes
Consisting of, Containing or, Contaminated with Polychlorinated Biphenyls (PCBs),
Polychlorinated Tetraphenyls (PCTs) and Polybrominated Biphenyls are applied36.

The guidelines provided in these documents are intended to serve as a stand-alone
general guidance and also as what might be termed an “umbrella” guide to be used in
conjunction with the specific technical guidelines.

3.4    Administration and Enforcement

Apart from POPs implementation the institutions which are relevant to
environmental management system in Moldova are:

The Presidency. The president is responsible in front of international community for
the state of the environment in the Republic of Moldova.




31
   GOST 14189-81.
32
   SNIP II-108-78.
33
   SNIP 2.01.28-85.
34
   Approved by the Ministry of Agriculture of USSR.
35
   UNEP, Basel Convention Series. SBC Nr. 2005 / 1
36
   UNEP, Basel Convention Series. SBC Nr. 2005 / 2

ECOS
Environmental Impact Assessment Report                                  Page   47 of 179



The Parliament is responsible for approving the environmental policy, laws and
programme. There is a Parliamentary Commission on Environment and natural
Resources within the structure of the Parliament.

The Government is responsible to enforce the adopted policy and laws through its
lines ministries and state departments. Besides within the structure of the
Government there is a Department of Agriculture and Environment and several ad
hock and permanent commissions.

Toward the POPs Project implementation the following institutions have direct
implications:

The Ministry of Ecology and Natural Resources (MENR) is the central national
environmental authority designated as the Stockholm Convention competent
authority. MENR is responsible for: state legal monitoring, control and compliance
enforcement particularly for production, storage, transportation, use, neutralization
and burial of toxic and hazardous products and substances and their wastes.

The Ministry of Health and Social Protection (MOHSP) is responsible for
establishing and maintaining the National Register of Potentially Toxic Chemical
Substances and for listing new substances when necessary. It also amends the Statute
on Procedures for the Use and Elimination of Hazardous Products and Substances
and their Wastes; issues conclusion regarding the Statute on Procedures for
Transporting, Storing and Use of Phyto-Sanitary Means and Fertilizers and the List
of Chemical and Biological Means of Plants Protection and their Growth
Stimulation.

The Ministry of Agriculture and Food Industry (MAFI). MAFI includes the State
Service for Plants Protection and the State Center for Phyto-Sanitary Means and
Fertilizers Certification, which has a designated certified laboratory. The State
Register of Phyto-Sanitary Means and Fertilizers, approved by the interdepartmental
Council for phyto-sanitary means and fertilizers approval, is elaborated, maintained
and updated through a joint effort of MAFI, MOH and MENR. In accordance with
the Governmental decision No.1543 The MAFI is responsible to collect the
information regarding the progresses made toward centralization of the POPs
pesticides.

The Ministry of Energy (ME) is concerned about several aspects of environmental
and energy saving issues but the problem of PCBs is not specifically on their agenda.
Increased pressure from the unresolved problem of PCB oils and power equipment
(particularly old capacitors) has driven the energy sector to seek solutions. NIP
stipulates MOE responsibility related to PCB issue within the power enterprises.

The Ministry of Transport and Road Management (MOTRM). In accordance
with the Governmental Decision N 637 от 27.05.2003 - is responsible for toxic
wastes trans-boundary transportation as well as for training of the drivers to carry out
this kind of transportation.

ECOS
Environmental Impact Assessment Report                                 Page   48 of 179



The Ministry of Defense (MD). In November 2003, in accordance with the
Governmental Decision No 1543 MOD and DES started repackaging and
transportation of obsolete pesticides in a few districts.

The Department of Customs (DOC) administers export and imports by ensuring
compliance with restrictions established by MENR, MAFI, MOH, which furnish the
department with lists of prohibited pesticides and chemicals in accordance with
national legislation and international obligations. DOC enforces these restrictions at
the border with MAFI and MENR helping customs officers with specific technical
issues.

The Department of Standardization and Metrology (DSM) possess all the
standards related to storage of toxic wastes, transportation of toxic wastes, is
responsible to supervise all activities which fall into the category of dangerous ones,
relevant to civil protection issue.

The Department for Emergency Situations (DES). In November 2003, in
accordance with the Governmental Decision No 1543 MOD and DES started
repackaging and transportation of obsolete pesticides in a few districts. Also this
department is responsible to undertake precautionary measures in terms of civil
protection issue.

The local authorities have responsibilities for environmental protection and
management in the limits of their territory, ensuring compliance with applicable
legislation and standards. The legislation stipulated a range of obligations for
economic entities (e.g. to operate on the basis of environmental permits, prevent
pollution, manage toxic substances in environmentally safe way, etc). Related to
POPs processes the LA are all mentioned in the Governmental Decision No 1543 as
being responsible to secure selection of the storage sites as well as to assist the MOD
and DES in centralization and repackaging work.

Environmental Enforcement

Moldovan legislation stipulates: a) disciplinary, b) administrative, c) civil, and d)
criminal liability for non-compliance and violation of environmental, health, safety
and social legislation, regulations, standards and norms, permits and licenses. In
addition, market-based instruments of environmental protection, like taxes, fees and
fines for use of natural resources, pollution and over-pollution, are used in the
country. These are being enforced and penalties are being imposed by authorized
governmental ministries and agencies as well as through judicial process.
Environmental prosecution may result in temporary or permanent termination or
closure of relevant facilities and processes, or lead to mandatory retrofitting and
upgrading to meet environmental, health and safety standards and norms. Natural and
legal persons liable for environmental harm and damage must compensate and pay to
required rehabilitation, restoration, etc.



ECOS
Environmental Impact Assessment Report                                    Page   49 of 179



The following executive and specially authorized state bodies are responsible for
enforcement of constitutional principles and legislative acts in environmental
protection field:
●     Ministry of Ecology and Natural Resources (Environmental Inspection as a sub-
      ordinated institution)
●     State Forestry Department
●     Ministry of Health and Social Protection (Sanitary-Epidemiological Service)
●     Ministry of Internal Affairs (Traffic air pollution)
●     Ministry of Agriculture and Food Processing Industry
●     State Geology and Mineral Resources Agency of Moldova.

3.5    National and WB Environmental Assessment requirements

National EIA and other procedural requirements

The national procedures for environmental consideration has been introduced sine
1985, and currently includes the package of mechanisms and tools, as: so called
ecological expertise, environmental impact assessment, environmental audit,
pasportisation of facilities/units/entities, construction expertise, planning and
designing rules and normatives, environmental and health permission and penalty
system, environmental risk assessment of privatized enterprises, etc. Formal EIA
procedures were introduced in Moldova since the year 1996. Current legislation is
treated EIA process as project-level oriented, applicable at the planning phase to
complex and potentially dangerous (to the environment) projects, which could lead
to significant impacts. The strategic, regional or sectoral environmental assessments
are not incorporated yet.

Thirty-two topics are on the list of activities obligatory requiring an EIA. The
Ministry of Environment and Natural Resources (MENR) may require EIA for other
types and scales of projects if significant impacts are foreseen, but the criteria are not
specified. Among listed projects only: (1) installations and polygons for reusing,
dumping and neutralization of industrial wastes, including toxic and (2) electrical
enterprises, which required more than 2,000 m2 of surface area, have been found as
are subjects for EIA. There are no formal EIA requirements for re-packaging and
stocks of pesticides, remediation of contaminated sites, as well as for storage of
electrical equipment.

The EIA should be conducted at an early stage of the project (before designing) if
new construction, upgrading, reconstruction, modernisation, production profile
changes, conservation or liquidation of existing enterprises or new development




ECOS
Environmental Impact Assessment Report                                                     Page   50 of 179



planning is expected to be implemented. The EIA is conducted by national certified
experts following the defined methodology37, report structure and documentation
requirements. The brief Statement on the Environmental Impact Assessment (SEIA)
should be a subject of public and ministerial revisions. Corrected SEIA and other
documentation should be presented to the so called State Ecological Expertise 38 for
adoption. A positive decision on the SEIA provides the official basis to initiate detail
design of the project.

Once the technical and economic evaluation (feasibility study) and detailed design is
prepared it is again subject to review by the State Ecological Expertise. The EIA
findings should be incorporated in the chapter “Protection of Environment”, of the
Engineering Design Report including mitigation measures and the environmental
management plan. The State Ecological Expertise can be conducted either by the
MENR responsible department, or by the Zonal Ecological Agencies, depending on
the scale of the project and its economic importance. In addition to the obligatory
State Ecological Expertise, so called “ministerial” and/or “public” expertise can be
voluntarily applied.

The EIA procedure is a complex one. The steps to be followed for the submission
and approval of the EIA findings are illustrated in Figure 1 next page.

The EIA procedure has several weaknesses, as follows: (i) there are no criteria for
initial environmental examination of projects/activities not included in the formal
list39; (ii) scoping and screening are not included as formal EIA steps; (iii) the
decision-making process based of EIA study is not clearly defined 40; (iv) there are no
criteria established for review of the EIA by the State Ecological Expertise, which
does not become formally involved in the EIA process until late in the procedure; (v)
there is no opportunity for official early public input to the process41.




37
   There is no formal methodology developed yet
38
   Responsible agency for nation wide projects is the Direction of Ecological Impact and Waste Management of
MENR.
39
   JICA EIA study for water supply of the northern part of Moldova, 2002
40
   Prut river basin management project, TACIS, 2000
41
     Sectoral Environmental Review. Market Access and Rural Services Project, 2000

ECOS
     Environmental Impact Assessment Report                                              Page   51 of 179




   INITIATOR
 (DEVELOPER)                                                      EIA study                          EIA
                                EIA TEAM

                                                                                             DOCUMENTATION


     PUBLIC                                                      LOCAL PUBLIC
  ECOLOGICAL                  ANNOUNCEMENT                        AUTHORITY
                                in mass-media                                                    EIA
   EXPERTISE
                                                                                              STATEMENT
    (voluntary)


                                                                  MINISTRIES &
                                                                STATE AGENCIES
     Reviewing                        Reviewing


                                                                   MINISTRY OF
                                                                  ENVIRONMENT
          COMMENTS
                                                                  AND NATURAL
                                  COMMENTS                         RESOURSES




                                                    amendment EIA                 STATE ECOLOGICAL
                    INITIATOR                     DOCUMENTATION                       EXPERTISE
                  (DEVELOPER) +                  and EIA STATEMENT
                     EIA TEAM


                                                    INITIATOR
                  Approving                       (DEVELOPER)
                                                                              +
                                                                                           Expertising
  TERMS OF
REFERENCE for
   designing
                                                                              -
                                          CHAPTER
                                    «ENVIRONMENTAL
   DESIGNER                     PROTECTION» as an integral
                                 part of design documentation                         Correction




     Figure 1. EIA Process in Moldova

     An environmental audit is applied only to existing facilities, enterprises, factories, or
     other economic activities. The purpose of the audit is to evaluate environmental
     impacts at the operational phase42.




     42
        A decision to conduct an environmental audit is made if (among other reasons): (i) enterprise,
     factory or any activity had not received approval from the Department of Ecological Expertise, but
     was built/operated; (ii) enterprise, factory or other activity for which the significant environmental

     ECOS
Environmental Impact Assessment Report                                                       Page   52 of 179



National requirements for public involvement in EIA process

When public participation is the subject of a legal analysis there are 4 human rights
which all together make the sense of the notion and which should be addressed.
They are: (i) the right to know (public information), (ii) the right to participate
(public involvement procedures), (iii) the right to be heard (considering the public
opinion under the decision making process) and, (iv) the right to appeal (attacking
the decision in court).

(i) The access to information is guarantied by Constitution of the Republic of
Moldova which by the articles 34 (“the right to access to information can not be
stopped”) and 37 (“the state guaranties the right to the free access to the
environmental information”) sets the general framework of the issue in question.

Moldovan legislation stipulates a large spectrum of provisions assuring the right to
know of the citizens - for instance, in environmental matter there are more then 10
environmental laws containing provisions on access to information. However, the
only law which comprehensively governs the access to all kind of information is the
organic Law on Access to Information. Unlike the majority of laws this one sets a
very clear procedure of access to public interest information and stipulates all
conditions when the information is exempted from public access due to certain
reasons like e.g. state / commercial secret, documents under preparation and internal
working documents.

(ii) All above mentioned environmental laws did not provide a clear procedure of
public participation - this right is rather declared then instrumental in the laws. The
law where the procedure of public participation is described is the Law on
Environmental Expertise and Environmental Impact Assessment (EE&EIA) as well
as the Regulation on Public Involvement into Environmental Decision-Making
(RPIEDM). At the same time, the provisions toward the right to participate within
the EE and EIA Law are very restrictive43 making the procedure of participation
problematic to the general and even affected public. Besides, there are a number of
procedural confusions and contradictions between the Law and Regulation.

(iii) The EE&EIA Law and the RPIEDM do oblige the responsible public authorities
to make public (publishing in media, radio, TV broadcasts, etc.) the decision made.




impacts are recognised by the environmental authorities or general public, or for which there is
insufficient information for effective environmental management.
43
   The way of public participation within EIA and EE process is so called Public Environmental Expertise. The
right to perform PEE is limited to only “registered” associations which have to have respective record in their
statue; not included people that can be influenced by the project or those who are interested to comment and
acting on people’s behalf on the project. The RPIEDM offers this right to individuals.

ECOS
Environmental Impact Assessment Report                                                         Page   53 of 179



However, nor the Law neither the Regulation obliges the authorities to make
accessible to the public the reasons and considerations on which the decision is
based.

(iv) The provisions of the EE&EIA and RPIEDM do imply the decision-makers to
make the decision accessible to the public (publishing in mass media). Nevertheless,
nor EE&EIA neither RPIEDM obliges the decision makers to provide within the
decision published also the guidelines on appeal procedures.

WB safeguards operational policies

The Bank’s safeguard policies require that potentially adverse environmental impacts
of projects are identified, avoided or minimized where feasible, and mitigated or
monitored. All 10 WB safeguard policies have been analyzed in the context of the
applicability to the project outline. The Environmental Assessment (OP 4.01) is
clearly triggered44. The Pest Management (OP 4.09) policy45 is not applied46. The
Natural Habitats (OP 4.04) and Forestry (OP 4.36) have been identified as not
triggered, but for the several project sites identified during risk assessment, located
nearby sensitive habitats and important forest areas, required safety and
precautionary measures should be incorporated.

A comparative review of WB Operational Policies, relevant Moldovan and EU
legislation is presented in Annex 5.




44
   The Bank requires EA of projects proposed for Bank financing to help ensure that they are environmentally
sound and sustainable, and thus to improve decision making. EA evaluates a project's potential environmental
risks and impacts in its area of influence; examines project alternatives; identifies ways of improving project
selection, siting, planning, design, and implementation by preventing, minimizing, mitigating, or compensating
for adverse environmental impacts and enhancing positive impacts; and includes the process of mitigating and
managing adverse environmental impacts throughout project implementation. EA takes into account the natural
environment (air, water, and land); human health and safety; social aspects (involuntary resettlement, indigenous
peoples, and cultural property); and transboundary and global environmental aspects. EA is initiated as early as
possible in project processing and is integrated closely with the economic, financial, institutional, social, and
technical analyses of a proposed project.
45
   In assisting borrowers to manage pests, the Bank supports a strategy that promotes the use of biological or
environmental control methods and reduces reliance on synthetic chemical pesticides. The Bank assesses the
capacity of the country's regulatory framework and institutions to promote and support safe, effective, and
environmentally sound pest management.
46
   Moldova has never produced pesticides or PCBs. None of the POPs pesticides is presently permitted for use in
agriculture, forestry or households. The project does not finance purchase or production of pesticides but rather is
financing disposal of the existing stockpiles. The project will finance training in integrated pest management and
strengthened pesticide control. The project is co-ordinating with the WB Moldova Rural Investment and Services
Project (RISP) II IDA credit which supports integrated pest management and the strengthening of pesticides
control. The project is working closely with the WB Rural Investment Project which is financing improved pest
management practices.

ECOS
Environmental Impact Assessment Report                                                          Page   54 of 179




4 Description of the Environment (Baseline)
4.1     Biophysical Environment

4.1.1 Location and Topography

Moldova is a landlocked country of 33,800 km2 with a population exceeding 4
million (2004 estimate)47 situated in southeastern Europe and is one of the most
densely populated countries in the region. Chisinau is the largest city with a
population of 700,000 and other large centres include Tiraspol, Balti and Bender.
Moldova is bordered by Romania on the west and by Ukraine on the north, east and
south. Most of its territory is drained by two large rivers, the Dniester and the Prut,
both part of the Black Sea basin. The landscape is dominated by rolling hills, and
void of mountains and plateaus. The country forms a varied mosaic of undulating
open and wooded steppe alternating with plains. The multitude of landscapes and
local topographical features determines the variety of toxic chemicals pathways in
the environment. The picture of chemical contamination and impacts can be very
complex, considering that natural conditions in Moldova are typified by a substantial
variation in soils, landscapes, vegetation buffers and water resources.

4.1.2 Climate48

Moldova has a moderate continental climate, with short mild winters and long hot
summers. The coldest month is January with average temperature ranging from
minus 3ºC to minus 5ºC. Spring weather is unstable and can be characterized by
rapid temperature rises. Summer is long, hot and dry. The warmest month is July,
with average temperature ranging from 19ºC to 22ºC and the maximum daily
temperature frequently exceeding 30oC. The average annual air temperature is 7.5-
10.0ºC and average soil surface temperatures are within the 10-12ºC range. The
warm period lasts 146 to 180 days per year. Temperature and humidity are important
factors which determine the environmental fate and lifetime of organic chemicals.
The ambient conditions in Moldova allow persistent organic chemicals to remain in




47
   The census undertaken in 2004 provided a number of 3,388,000 inhabitants. However, this does not comprise
the population on the left bank of the river Nistru (Transnistria) which is estimated at approximately 700,000.
Transnistria is politically and institutionally separated from the rest of the country and does not participate in
activities initiated by the official authorities of the country.
48
   Atlas of the Republic of Moldova, 1978, 1990.

ECOS
Environmental Impact Assessment Report                                                   Page   55 of 179



soil for long periods of time. It is well known that some organochlorinated
compounds can persist in the soil for 10-20 years and more. This explains why DDT
is still being detected in the Moldovan environment despite the fact that it was
banned in 1970 and it was not used in significant amounts since then49.

Annual precipitation varies from 550 mm in the north of the country to 350 mm in
the south and falls mainly in the summer months as torrent rains, often accompanied
by squalls and hail. Summer precipitation is quite variable, ranging from monthly
averages of 55-85 mm to 200-300 mm. About 18% of total precipitation falls as a
mixture of rain and snow during the winter months. Precipitation water is a carrier of
many pollutants and the precipitation pattern is an important factor determining the
spatial distribution of chemicals in the environment. During the torrent rains the
runoff, carrying all kind of chemicals adsorbed on the soil particles, is a major
contributor to the surface water pollution, while during winter and springtime the
problems of chemical contamination of the groundwater are of bigger concern.
Strong winds are rare but should not be ignored as contributors to the contamination
of the surroundings in the vicinity of chemical pollution sources (chemical stores,
highly contaminated lands). This is particularly relevant for volatile and dust
pesticide formulations.

4.1.3 Geology and Soils

Moldova’s geology is dominated by the Moldovan plate of the Eastern-European
geological platform. Sedimentary materials of sandstone, clay and limestone cover
the crystalline basement. The variety of soil mechanical and composition profiles
determines the accumulation potential of the soil related to persistent organic
compounds as well as the movement of pollutants into the groundwater with leaching
precipitation water.

Moldova is located within the seismic Carpathian region and is subject to
earthquakes, the intensity of which can reach a rating of 6-8 (locally 9) on the
Richter scale. This leads to stricter requirements to be applied to engineering works
and consequently to higher construction costs50. The safety precaution principle is a
very important consideration to be applied to any building intended for long-term
storage of toxic and dangerous chemicals as any damages occurred in basement,
floor surface and roof of the building can result in unexpected contamination of the
neighbouring environment.




49
  National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004.
50
  Regional Study: Managing Natural Disasters in Europe and Central Asia, World Bank perspective, Country
Risk Template (Republic of Moldova), WB, 2003.

ECOS
Environmental Impact Assessment Report                                                        Page   56 of 179



Moldova is blessed with excellent soils for agricultural production; the black soils
comprise 75% of all agricultural land. One of the most serious environmental issues
in the country is the progressive loss of topsoil: approximately 2 million hectares of
land are affected by erosion and soil losses are estimated at 26 million tons of soil
annually. During the last 35 years the area of eroded land increased by 265,000 ha
(7,500 ha per year, on average)51. Soil erosion also leads to the silting of water
bodies, transporting adsorbed chemical substances to surface waters, causing
pollution and other losses in terms of services to the population both for drinking and
irrigation purposes.

Huge amounts of pesticides were used in the agricultural sector in the past decades in
order to protect the large-scale monoculture fields easily invaded by pests, weeds and
fungi. In the 1950-1990s, an estimated amount of 560,000 tons of pesticides were
used, including 22,000 tons of persistent organochlorine compounds52. This resulted
in heavy contamination of the soils. The application of pesticides was so high that
locally the residual levels of organohlorine compounds exceeded maximum
allowable levels by up to 50 times53. Since the middle 1980s, the application of
pesticides has diminished significantly and currently the background monitoring
conducted by the Hydrometeorological Service (HMS) does not report significant
contamination of soils by persistent pesticides at the selected sites 54.

It has to be stressed, however, that data on the soil pollution by pesticides near the
pesticide stores and former stations for preparation of chemicals solutions are
worrying. Several surveys of such areas showed a significant level of soil pollution
with persistent organic pollutants, including DDT, in the radius of up to 200 м from
the storage facilities55. In most of such locations the national standards for DDT and
its metabolites in soil were significantly exceeded (up to 15-20 times), even at a
depth of 1 m.

4.1.4 Water Resources

The surface water resources of Moldova are mainly (90%) formed by the transit flow
of the Danube, Dniester and Prut rivers. The internal rivers network consists of
nearly 3,300 water courses with a total length of 16,000 km. Most rivers are small
and only nine have a length exceeding 100 km. About 3,500 reservoirs have been
created on the rivers, designated to trap sediments, provide irrigation,
domestic/industrial water, and support fisheries.




51
   State of the Environment Report, 2003.
52
   National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004.
53
   Market Access and Rural Services Project, Sectoral Environmental Review, draft, 2000.
54
   It has to be pointed out that the HMS monitoring program is very limited, both in terms of spatial coverage and
parameters analyzed.
55
   National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004

ECOS
Environmental Impact Assessment Report                                                     Page   57 of 179



The water quality of the Dniester and Prut rivers is generally considered as suitable
for irrigation, recreation and drinking purposes. Currently, the main source of
pollution of surface waters is improperly treated sewage. Most wastewater treatment
plants are ill-maintained, consequently surface waters are still receiving significant
loads of organic pollution and are subject to strong bacteriological contamination56.
A general improvement of the river water quality in terms of chemical pollution was
observed over the last decade due to the significant decline of the industrial and
agricultural production. Most of the internal rivers are canalized, with regulating
dams and flood protection dykes, and most are moderately or heavily polluted57,58,59.
The reported level of pollution with synthetic organic compounds and pesticides is
low60.

There are few small natural lakes in Moldova. Most of the water bodies are
reservoirs created on the small rivers which are regulated by weirs, build in cascade.
The reservoirs are subject to siltation due to soil erosion, eutrophication and pollution
from land-based sources. Nevertheless, they are an important local resource for
livestock watering, fishing, commercial fish farming, maintaining domestic
waterfowl, and recreation. The high value of local water resources for the rural
population requires special attention if any actions involving pesticide stores
management are to be taken. The water reservoirs are currently often used for
commercial fish-farming which is an important economic activity in the rural areas.
This makes the water streams and associated reservoirs particularly sensitive to
pollution by toxic, persistent and cumulative chemical compounds.

The floodplains of many of the small internal rivers are highly exposed to flooding,
due to climate and landscapes characteristics, poor technical status of weirs and
inadequate safety management61. Several cases of severe floods on small rivers have
been reported over the last decade. The pesticide stores, located closely to the
floodplain, have been washed out thus contributing to the pollution of water
resources62,63.

90% of Moldova’s groundwater resources are related to the deep aquifers. Deep
groundwater, especially from the Lower Baden Sarmat aquifer, underlying the entire
country, is an important source of domestic and industrial water. Deep groundwater
resources are characterized by high levels of salt content that are often close to, or




56
   Water Cadastre of the Republic of Moldova, 1998
57
   Prut River Tributaries: Environmental Protection Review. Protection Strategy and Options, TACIS, 2001
58
   State of the Environment Report, 2003
59
   Water Cadastre of the Republic of Moldova, 1998
60
   Prut River Basin Water Management Project, Tacis, 2000.
61
   Regional Study: Managing Natural Disasters in Europe and Central Asia, WB perspective, Country Risk
Template (Republic of Moldova), WB, 2003
62
     Flood Risk in Moldova, Acvaproiect, 2002.

ECOS
Environmental Impact Assessment Report                                                  Page   58 of 179



exceeding the drinking standards for fluoride, sulphate and TDS. Shallow
groundwater is present throughout the country in recent Quaternary sediments, which
are composed mostly of sand, sandstone, and occasionally, gravel. This shallow
acquifer is fed from the infiltration of precipitation and is therefore vulnerable for
pollution from the earth surface. In the same time, this is a major drinking water
source for rural population: about 50% of the country population relies on shallow
wells for drinking and domestic purposes.

A study implemented in 1997 in two pilot regions64 indicated pollution of shallow
wells by atrasine, prometrine and organophosphorus insecticides at trace
concentrations. Most of the contaminated wells were located near orchards, tractor
brigades, pesticide warehouses and within arable fields, but also in the limits of
villages. DDE and HCH have been reported in some wells at a level varying from
0.00014 to 0.00028 mg/l.

4.1.5 Natural Systems, Habitats, Biodiversity and Protection

Natural landscapes and biodiversity in Moldova are limited due to the long lasting
and intense agriculture use of this area. At present, natural ecosystems cover no more
than 20% of the country’s territory; they are fragmented and notably degraded65. The
forest cover index is 9.6% and virgin forests are rare (86% of the woods are planted).
The steppe ecosystems are in a continuous process of degradation, since the specific
habitats have been almost totally converted into arable land. Natural meadows were
completely destroyed on the area of about 200,000 ha and have been preserved only
as small isolated spots. Aquatic ecosystems, wetland and marches cover
approximately 2.8% of the national territory66. Moldova’s biodiversity is represented
by more than 5,500 species of plants, 1,200 species of mycophyta and about 15,000
species of fauna, including 461 vertebrates and 14,400 invertebrates. The greatest
biodiversity value is associated with forest, aquatic and wetland ecosystems67, which
are among the most vulnerable natural habitats in the country.

The number of wildlife species requiring protection is constantly growing68,69. The
current edition of the Red Book includes an extremely high share of animal species
from certain classes (e.g. 57% of reptile species, 43% of mammals, 20% and 24% of
fish and birds, respectively). Because of the degraded status, fragmentation and
sensitivity of nature to human impacts, the biodiversity and habitat conservation is an




63
   Problems of Flooding, European Associated Center on Flood Problems in Moldova, Acvaproiect, 2001.
64
   Study of the Quality of Rural Drinking Water, World Bank, 1997.
65
   Biological Diversity Conservation. National Strategy and Action Plan, 2002.
66
   State of the Environment Report, 2003.
67
   Biological Diversity Conservation. National Strategy and Action Plan, 2002.
68
   Red Book of Moldova, 2001.
69
   Biological Diversity Conservation. National Strategy and Action Plan, 2002.

ECOS
  Environmental Impact Assessment Report                                  Page   59 of 179



  important theme in any assessment of the factors, which may lead to further
  degradation of the national ecological potential and affect sustainability of country
  development.

  The state has developed a system for the protection of important and threatened
  habitats and landscapes and between 1962 and 1998 the total area of protected areas
  has increased from 3,700 ha to 66,500 ha or 1,96% of the national territory, which is
  still very low in comparison to the majority of European countries 70. The categories
  and areas of natural protection are indicated below.

  Table X. Habitats and Landscapes Protected in Moldova
Categories of natural objects and complexes                         Number       Area (ha)
Scientific reserves                                                 5            19,378
Nature monuments, including:                                        130          2,907
Geological and paleontological                                      86           2,682
Hydrological                                                        31           100
Botanical                                                           13           125
Natural reserves, including:                                        63           8,009
Forests                                                             51           5,001
Medicinal herbs                                                     9            2,796
Complexes                                                           3            212
Landscape reserves                                                  41           34,200
Resource reserves                                                   13           523
Multi-purpose management areas, including:                          34           1,030
Typical areas of steppe vegetation                                  5            148
Typical areas of meadow vegetation                                  25           675
Protective forest belts                                             2            208
Botanical gardens                                                   1            105
Dendrological gardens                                               2            104
Garden architecture monuments                                       20           191
Zoological gardens                                                  1            20
TOTAL                                                               310          66,487

  The management of the majority of protected territories is deficient. Enforcement of
  legal requirements is poor. In some cases the protected areas are left in the custody of
  economic agents, mayors’ offices, educational institutions, which do not have
  capacity or even interest for adequate management of these areas.

  Pasture grassland is limited for most villages and local authorities usually designate
  the less productive lands for community pasture purposes. Due to lack of pasture
  lands, areas like forests, wetlands, river floodplains and roadside plantings are used
  for grazing. This often involves areas located nearby or even inside the territory of
  the pesticide storage facilities, which increases the risks of acute toxic effects for
  cattle or sheep and chronic intoxication for humans, as well as the potential for
  environmental dissipation of POPs.




  70
       Ibidem.

  ECOS
Environmental Impact Assessment Report                                                  Page   60 of 179



There are no data available on the level of contamination of the natural and protected
areas with pesticides. A study undertaken in two pilot areas in the late 1990s71 did
not reveal any pesticide contamination of shallow groundwater wells located in
forests and semi-natural areas (ravines, etc). Description of the environment at the
rayon level is presented in the Technical Appendix.

4.2       Socio-Economic Environment

4.2.1 Economic Evolution of Moldova and Poverty Issues72

With independence, the Republic of Moldova began facing a set of political,
economic, environmental and social problems, which it had to resolve alone, relying
on its own potential and resources. The process of state building and self-
determination was going in a context of social and economic crisis, and radical
transformation of the economic system. Lack of experience in resisting external
“shocks”, crises in the economy and social sector, as well as insufficient experience
in implementing system and sectoral reforms, unstable internal political situation,
territorial disintegration of the country – all these predetermined the considerable
mistakes and costs of the transition period.

Until independence, the Moldovan economy was highly integrated into the Soviet
economy through the mechanism of the inter-republican division of labour and
economic ties with the other union republics. The high degree of integration was
reinforced by an almost complete lack of domestic energy resources, of non-
agricultural raw materials, machinery, equipment and components for production,
and of subsidies for the country’s agrarian sector from the Union budget. The
Transnistria conflict has broken economic ties within the country. As a result of the
territorial disintegration, Moldova lost control on its eastern border of a considerable
part of its energy, irrigation and industrial sectors.

The period of adaptation to the collapse of the Soviet Union and internal
disintegration coincided with the beginning of the reform and restructuring of the
economic system. A switch from the centrally planned economy to the market
economy was executed energetically in all main areas, including price liberalization,
foreign trade and investment, opening up the internal market, mass privatisation, land
reform and formation of a new banking system. However the consequences of the
reforms, and their effect on social development and environment were not accurately
predicted; no account was taken of the low level of preparedness of the people and of
economic agents to live and act in the changing circumstances. Thus the practical




71
     Study on the Quality of the Rural Drinking Water, World Bank, 1997.
72
     Economic Growth and Poverty Reduction Strategy Paper (2004-2006), Government of Moldova, 2004.

ECOS
Environmental Impact Assessment Report                                  Page   61 of 179



results of the reform to a large extent failed to meet expectations of society and
government.

The transformation of ownership relations was the key and radical reform. The mass
privatization of the state property did not justify the aspiration in the emergence of a
new class of owners interested in the development of production by increasing
competitiveness; renovating and modernizing fixed assets, comply with the
environmental obligation, attracting investment and quality management. The main
agrarian reform, the transfer of land and assets (including part of the pesticides
warehouses) into private ownership, was carried out without providing adequate
enough to render informational, technological, commercial, financial, consulting,
environmentally oriented and other services to peasants. As a result the problems of
ecological degradation and uncontrolled pollution intensified. Most of pesticides
warehouses, shared between farmers, has been dismantled and part of obsolete
pesticides has disappeared. At many locations the farmers used the bricks, blocks and
other construction elements for building facilities for livestock and other household
needs. Lack of control, low level of information and awareness of the rural society
concerning the negative impacts of improper pesticide management practices, and
poverty of rural population, altogether leaded to this situation. Larger and
environmentally well-designed regional pesticides warehouses had a better fate but
without proper operation and maintenance and clear perspectives of future use, these
assets are in the process of advanced physical degradation.

In 2000, the Moldovan economy moved onto a growth trajectory. From 2000 to
2003, GDP rose by 24,1%, industrial output by 54,1%, and investments in fixed
capital by 21,5%. The economy entered the period of upturn with a new structure. As
a result of implementation of reforms, the non-state sector became dominant. In
2002, its share in GDP was 75%, with a share of over 80% in industrial
manufacturing, over 95% in retail trade, almost 100% in the agrarian sector, and 54%
in the sector of paid services. The correlation between major economic sectors
remains unfavourable – agriculture in 2002 accounted for 21,0% of GDP and nearly
half of all employed in the economy (49,6%), industry accounted for 17,3% of GDP
and a bit more than one tenth of the employed (11,4%). The economic stabilisation
and growth was not reflected in improving the environmental management. Low
capacity of the public, health and environmental authorities to control and manage
pesticides warehouses status leaded to further deepening of environmental pollution
problems.

In a domestic regional context, the economy of Moldova is evolving in an
unbalanced way. In the course of the crisis years, a gap between the social and
economic development of capital city Chisinau and the rest of the country increased.
Differentiation of the economic potentials of the capital and regions is caused by the
degradation of industry and infrastructure of smaller cities during the 1990 crisis, and
by the low efficiency of the agrarian sector in regional economies, resulting in an
absence of necessary conditions and resources for development, including
environmental consideration. The rural communities are very significant poverty

ECOS
            Environmental Impact Assessment Report                                                   Page     62 of 179



            epicenters, which generates environmental concerns, with impacts on the
            population’s health and well-being, which results in increasing the level of rural
            poverty driven by the environmental cycle. Moldova is among the poorest countries
            in Europe, with a per capita income of US$543 and over half the population living on
            less than one US dollar equivalent per day.

            The social crisis was deeper and more dramatic than the economic one. With large-
            scale release of labour from the economy, high inflation and falling real state
            expenditures for social needs, the losses of the population were limited not only to
            narrowing income resources and declining purchasing power, but also to a
            diminished ability to enjoy social assistance from the state, in the form of benefits
            and free social services. The main indicators of social development are presented in
            the table below73:


Years
                                                      1997         1998        1999         2000     2001         2002
DEMOGRAPHY
Number of permanent residents as of 1 January,
                                                      3663.7       3655.6      3649.9       3644.1   3635.1       3627.8
thousands of people
Population aging rate (individuals of 60 and
                                                      13.3         13.5        13.6         13.6     13.6         13.9
over per 100 people)
Average life expectancy, years:
- male                                                62.9         64.0        63.7         63.9     64.5         64.4
- female                                              70.3         71.4        71.0         71.2     71.7         71.7
Births per 1, 000 people                              12.5         11.3        10.6         10.2     10.0         9.9
Deaths per 1,000 people                               11.8         10.9        11.3         11.3     11.0         11.6
Rate of natural increase                              0.7          0.4         -0.7         -1.1     -1.0         -1.7
INCOME OF POPULATION
GDP per capita, USD                                   527.1        464.8       321.3        353.7    408          459
Share of population with income below USD
                                                      -            52.7        70.8         64.5     52.4         39.8
2,15 per day (by purchasing power parity), % *
Share of poorest population (I quintile group)
                                                      5.8          5.9         6.2          6.7      6.6          6.8
in national consumption, %
Average monthly nominal wage, USD                     47.6         46.5        29.0         32.8     42.2         51.0
EMPLOYMENT AND LABOR MARKET
Number of employed in the economy,
                                                      1646         1642        1495         1515     1499         1505
thousands of people
Number of employed in agrarian sector,
                                                      684          750         731          766      764          747
thousands people
Unemployment rate according to ILO
                                                      …            9.2         11.1         8.5      7.3          6.8
methodology, %

            In spite of the facts of emerging and targeting efforts to mitigate social crisis the
            perceptions of many national and international experts are that social and economic
            improvements are slow and sometimes negligible. The critical issues now are not




            73
                 Department of Statistics and Sociology and (*) Policy and Poverty Monitoring Unit

            ECOS
Environmental Impact Assessment Report                                    Page   63 of 179



only to make improvements, but also to ensure that improvements are visible and
understood by stakeholders.

Poverty in the 1990s grew in association with reductions in national output,
investment, employment, and degradation of physical and biological environment,
damaging of infrastructures, neglecting of environmental obligations and decreasing
of real income of the population. As with many countries in transition, poverty is a
multidimensional phenomenon, but because of its geographical and geo-economic
and geo-political location, Moldova has specific features, which have amplified its
vulnerability to poverty. These include regional economic crises, sensitivity to
natural disasters, political and social instability, territorial separation, combined with
fear for the future arising from experience of its recent history. Poverty in Moldova
affects not only traditionally vulnerable categories of the population such as the less
educated, unskilled, unemployed, it also affects those who are able to work, and who
are qualified and healthy. Children, who account for one third of Moldova’s poor, are
severely affected by the worsening economic conditions. There has been an increase
in infant and child mortality and the spread of infectious diseases among poor
children. The vulnerability of pregnant women and mothers has also increased.
Current severity of poverty in the country does not suppose the environmental issues
being high on the agenda of both the authorities and the population. Such an attitude
is also generated by low awareness, non-transparent decision-making and poor
environmental education.

4.2.2 Current Features of the Agricultural Sector 74

Since Independence in August 1991, Moldovan agriculture and food industries have
faced a series of shocks, including a large unfavourable adjustment in terms of trade,
civil unrest, and severe droughts. A drastic reduction in input of capital into
agriculture has gone hand in hand with a significant decline in production and the
economic disruption associated with the break-up of the Soviet Union. Agriculture
and food processing make up more than half of the Moldovan economy and most of
the labour force is engaged directly or indirectly in agriculture.

Moldova has no production capacity for inorganic fertilizers, pesticides, mineral or
vitamin nutrition additives, veterinary medicines or fuels, and consequently the
country relies on imports of these commodities. The relatively faster rise in prices of
imported commodities relative to the rise of prices for exported commodities has led
to the need for very large adjustments in the sector. The decline is mainly the result
of decreased productivity, as total agricultural area has not changed significantly.




74
  Economic Growth and Poverty Reduction Strategy Paper (2004-2006), Government of Moldova,
2004.


ECOS
Environmental Impact Assessment Report                                  Page   64 of 179



Yields of the crop are 20-60% lower, than the 1989-1991 levels. One of the reasons
is decreasing of the land fertilization efforts and loose of the pest control. Labour
productivity has also declined. The agricultural production structure also changed.
During past years the areas under low resource crops with assured markets (wheat,
corn, sunflower) have increased and areas under intensive crops (tobacco,
vegetables), requiring stricter pests control have been reduced. The food processing
industry has adjusted better to the changes. About one third of all these economic
units have been successfully restructured being able to modernize their equipment,
management, as well as their raw material supply.

The privatization and restructuring of large-scale state and collective farms is now
practically complete. The contrasting picture with about half the land being
cultivated by various medium to large enterprises, consolidating the land through
various leasing agreements and the second half is owned mainly by small
independent farmers has resulted in a very fragmented structure of land ownership
and misbalance between agricultural technologies applied, including pesticides and
fertilizers. The transition toward market economy resulted in a loss of jobs in
agriculture. As estimated in some villages about 40% of active, skilled and
experienced population is presumed to have gone abroad or to the urban areas.

Food and agricultural products traditionally dominated Moldovan exports. Moldova
still remains a net exporter of agriculture and food products mostly to CIS countries,
but their contribution in the volume of exports is slightly declining. The major part of
the loans/credits provided by national banks goes to food processors and input
suppliers. Credits provided to the individual sector in Moldova come mostly from
non-bank financial institutions supported by the New Lending Initiatives under the
World Bank Rural Investment Support Project (RISP, 2000). Foreign donor agencies
play a very important role in the national economy. A large number of international
financing and donor organizations such as USAID, TACIS, SIDA, DFID, Soros
Foundation, from Japan, Poland and the Netherlands have recently become more
active in providing support to the agricultural sector, including investment, grants,
soft loans and guarantees to banks, and technical assistance. Moldova under its
membership agreement with the WTO has made commitments limiting subsidies.
Moldova has signed Free Trade Agreements with 17 countries.

A more active involvement of the country in international trade stressed the issue of
agricultural products safety. Heavy use of pesticides in the past has resulted in soil
and groundwater contamination, further exacerbated through poor enforcement of
regulations concerning pesticides management. In the 1980s, the frequency of
detection of pesticide residuals (including DDT and HCH) in Moldovan foodstuffs
was pretty high ranging from 5.6% (1984) to 19.8% (1990). The most contaminated
were fruits, canned goods, dairy products and meat. In 1993 21.6% of all agricultural
produce contained pesticide residues, although less than 1% exceeded the allowable
limit. Poor warehouses management also contributed to the pesticides entering the
environment and circulating in the food chains. The contamination frequency



ECOS
Environmental Impact Assessment Report                                                   Page   65 of 179



decreased during the last decade, but still data from 2000 indicated that pesticide
residuals were present in 3.1% out of about 12,000 analyzed samples of food crops75.

4.2.3 Energy sector76

The current situation in the energy sector reflects the difficulties associated with the
process of reform and the application of market principles. The country’s energy
sector is developing in a context of an almost complete absence of primary energy
resources (98% of consumed energy resources are imported) and sizeable foreign
debts to suppliers. The major problems in the development of the energy sector are
associated with the inappropriate technical and financial structures of many energy
sector enterprises, as well as with insufficiently effective organization of energy
supply and energy consumption. These problems in electrical sector manifest
themselves in:

i) high depreciation levels of energy equipment and power lines (up to 70%)
ii) low utilization coefficient of technical-industrial equipment and high voltage
electricity network with a trend of falling consumption of power, heat energy and
natural gas;
iii) high level of energy losses in electricity lines (up to 53%);
iv) large debts of the population, economic agents and budgetary institutions for
consumed energy due to their low paying capacity;

Until 1998, electricity was supplied by only one public enterprise, the Moldenergo
State Company. Since then, the electrical sector has been diverted to decentralisation.
Three categories of enterprises with investment capitals are existing nowadays: (i)
power generation companies; (ii) electricity transport company Moldelectrica; and
(iii) electricity distribution companies: three out of five privatized by Union Fenosa,
Spain; and two state owned companies.

The national objectives of the medium-term energy policy are to enhance energy
security of the country and to create an environment for efficient and stable
development of the sector77.

The energy sector is estimated as priority for PCBs safety management in the
country78 as it is the largest source of environmental pollution with PCBs. Currently
the PCBs continue to be used in power installations and other types of equipment.
The main pathways of environmental pollution are the PCB oil leaks from electric




75
   National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004.
76
   Economic Growth and Poverty Reduction Strategy Paper (2004-2006), Government of Moldova, 2004.
77
   Economic Growth and Poverty Reduction Strategy Paper (2004-2006), Government of Moldova, 2004.
78
   National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004.

ECOS
Environmental Impact Assessment Report                                 Page   66 of 179



equipment, heat exchangers and hydraulic systems, evaporation from different
technical installations, and discharges of industrial liquid waste.

A preliminary inventory identified that about 24,000 tons of dielectric oils are used
in electrical installations, including approximately 18,000 tons in high voltage
transformers, 380 tons in capacitors and 5,400 tons in circuit breakers, inductors and
other electrical equipment. From the total amount, 95-97 % is in the equipment that
belongs to power producers, transporters, and distributors and 3-5% in the
installations of power consumers.

The power units keep no records about the type of oil currently or previously filled in
transformers. Thus, no direct evidence exists at this moment on whether the
transformer oil is or is not PCB-contaminated. A few selected analyses executed by
Fichtner (Germany) in 1999, in transformers from the transport division of the power
system, and by Union Fenosa (Spain) in 2003, in 25 transformers from power
distribution companies, did not provide proof of any PCB presence.

In contrast to transformer oil, the capacitors used in Moldova contain PCB
(trichlorobyphenil). According to the inventory undertaken as part of the NIP
preparation, almost 20,000 capacitors are located in 20 electrical substations
throughout the country. The whole stock of PCBs contaminated capacitors is state-
owned. Most of the capacitors (12,000) are kept in one assembly consisting of 18
capacitor batteries at the Vulcanesti substation in the south of Moldova. About 300
discarded capacitors are kept in closed containers at the station. Also, two dumps
with approximately 1,000 broken capacitors each are located at this substation giving
a total of 14,000 spent capacitors in Vulcanesti. The total PCB content in 20,000
capacitors is estimated at 380 tons while the total weight of the capacitors is
approximately 1,080 tons.

The capacitors represent a significant hazard to the environment and a real threat for
the health of people working at or living in the vicinity of the substations. Most of
them have been in operation for more than 30 years. The capacitors are situated
outdoors and PCBs leak from corroded capacitors to the soil below the capacitor
batteries. Due to past incidents of capacitor explosions and leakage by corrosion the
ground below capacitor batteries is highly contaminated. The analysis of soil samples
taken by the HMS in 2003 and 2005 below the capacitors as well as on the territory
of several substations showed a worrying degree of environmental contamination
with PCBs (12 congeners), particularly high at the Vulcanesti (culminating with
concentrations of 5300 ppm and 7100 ppm) and Donduseni (95 ppm) substations.
Even out of the direct reach of PCB leaks from capacitors, their concentrations in the
topsoil on the territory of the substations exceeded the national standard (0.06 ppm)
in almost every sample.

4.2.4 Health and Education

Life expectancy is 71.7 years for a female and 64.4 years for a male, one of the
lowest in Europe. The mortality rate is slightly increasing (11.6 per 1000) while the

ECOS
Environmental Impact Assessment Report                                                        Page   67 of 179



birth rate showed a steady decreasing trend. During the last 6-7 years, the natural
growth rate is negative. Cardiovascular diseases are the single major cause of death
and the rate is higher for men. Children’s health in general has deteriorated and
malnutrition has become a serious problem among children. Infant mortality is three
times higher than the average EU level.

The pesticide use and public health has been considered to be closely related and
studied. Among the pesticides that have been used in Moldova in the past, the
organochlorinated pesticides, which include all the pesticides listed in the POPs
Convention are thought to pose the biggest health and environmental risks due to
their toxicity, persistence and bioaccumulation potential. In the 1990s, their use in
Moldova almost ceased. However, their intensive use in the past, persistence in the
environment and the related health risks still make of them a health and
environmental issue.

Poor enforcement of specific rules and working instructions related to pesticides
storage, transportation, preparation, use, etc. as well as insufficient awareness of the
population on the health risks associated with pesticides leaded to multiple violations
of the regulations on handling toxic substances, including uncontrolled pesticide use
on the individual plots of farmers. This leaded to occupational health problems for
many people directly involved in pesticides handling.

Investigations undertaken in Moldova by the health authorities in the peak period of
pesticide application denoted a significant exposure of humans by organochlorinated
pesticides were identified in the breast milk of women living in villages where
significant amounts of these pesticides were applied79. The vast majority of breast
milk samples (between 87% and 96% in different villages) have been proved to be
contaminated. The concentrations of pesticides in body fluids showed a clear
correlation with the level of pesticide application in the fields. The toxic effects of
organochlorinated pesticides on exposed people included reproductive dysfunctions
and other functional disturbances in women as well as increased frequency of
masculine sterility, the incidence of both related to the level of pesticides use.

Epidemiological studies also revealed a correlation between the level of persistent
pesticides use in previous years and the morbidity through chronic hepatitis and liver
cirrhosis in investigated areas of Moldova. Research findings identified a strong
positive correlation between the general level of pesticides use and infant mortality.
The demonstrated chronic effects on children and teenagers related to pesticides
application included immune system disruptions as well as physical and mental




79
  Volneanschi A., Romanciuc P. Hygienic evaluation of the content of organochlorinated pesticides in breast
milk (Rom.) Proceedings of the III Congress of hygienists, microbiologists, epidemiologists and parazitologists of
the Republic of Moldova, Chisinau, 1992. P. 68-70.

ECOS
Environmental Impact Assessment Report                                    Page   68 of 179



retardation. The comprehensive estimation of health status revealed an evident
general worsening of children’s and teenagers’ health indices in areas with high level
of pesticides application.

Starting with the land reform in the mid 1990s, the number of large pesticide users
(agriculture farms) was in a continuous decline. Consequently, the number of people
professionally exposed to pesticides at the work place also dropped from 34,700
persons in 1993 to 8,800 in 2002. This does not mean, however, that the total number
of exposed people decreased in the same proportion since many peasants continue to
apply pesticides on their individual plots in smaller amounts and under less
controlled conditions as well as contaminated building materials from demolished
pesticides warehouses has been used for construction within the limits of villages.
This might in fact have increased the risks of pesticide use instead of decreasing
them. The lack of adequate information, control and peoples education is one of the
reasons.

In 1989 the literacy level of the adult population was 96.4%. Those with secondary
and/or higher education represented about 70% of the adult population. In 1998, 80%
of the 4,700 children not at school, but who were of eligible age for schooling at the
mandatory level, were from the rural areas.

In the transition period pre-school education has been affected the most with the
elimination of kindergarten and this has affected the rural areas. In the school
preparatory groups only 64% of the respective age children are enrolled as the
parents can not maintain the costs. Again, the rural areas, due to higher poverty
levels, are the most affected. In general, in the rural areas the education infrastructure
is deteriorating. There is a chronic shortage of textbooks and supplies and teaching
staff is generally unsatisfactory, probably as a result of low wages and unacceptable
living conditions.


4.3    Current pesticides and PCBs related information

4.3.1 Obsolete pesticides concern: history and state of centralization

In the 1970-1980s, large amounts of obsolete pesticides have been accumulated in
Moldova, due to poor pesticide management practices and the imposition of bans in
the use of particular chemicals. In order to find a solution for the ever-increasing
amount of obsolete pesticides accumulated in the country, a pesticide dump was built
in 1978 at Cismichioi, in the South of Moldova. In 1978-1988, 3,940 tons of obsolete
pesticides were buried there. Another part was stored at several hundreds of pesticide
warehouses allover the country, owned by state and collective farms. During the land
reform in early 1990s, those farms ceased to exist and most of the pesticide stores
were destroyed or dismantled. The obsolete pesticides stockpiles remained in unfitted
facilities, lacking guards and sometimes even in the open air.



ECOS
Environmental Impact Assessment Report                                                     Page   69 of 179



Storing of POPs obsolete pesticides under inappropriate conditions led to the
contamination of adjacent lands and resulted in increase of environmental and health
impacts.

According to official data, by the moment of commencement of activities on
repackaging and transportation of pesticides to centralized storehouses, 1,712 tons of
obsolete pesticides were stored in 344 poorly equipped or unfitted facilities with lack
of proper monitoring and security80. According to the same source, since 1995 the
amount of pesticides declined by about 600 tons, supposedly due to theft and
uncontrolled use in agriculture, illegal disposal and dissipation in the environment by
evaporation, leaching into groundwater, surface runoff, etc.

Since 1997, three Governmental Decisions have been taken towards pesticides
collection and centralized storage.

In 1997, the Government of Moldova adopted the Decision Nr. 474 “On Actions
toward Collection and Centralized Storage of Out-of-Use and Banned Pesticides”
asking for collection and centralized storage of pesticides at the existing pesticide
storage facility in Calarasi.

In 2001, the Government adopted another Decision81 stipulating the measures to be
undertaken, timeframe and responsibilities of involved ministries, departments and
local public authorities with regard to centralized storage and disposal of obsolete
pesticides. In particular, it asked the Ministry of Agriculture, the Ministry of Ecology
and the local authorities to select 3-4 storehouses in each judet (former
administrative unit in Moldova) to be used for centralized storage; the Ministry of
Agriculture, the Ministry of Healthcare, the Institute of Chemistry of the Academy of
Sciences and the Department for Standardization and Metrology to participate in
laboratory investigation of pesticides to determine their chemical composition and
amount of active substance; the Ministry of Agriculture and the local authorities to
rehabilitate the storehouses; the Institute of Chemistry to investigate the possibilities
of further incineration of pesticides; the Ministry of Agriculture, the Ministry of
Healthcare and the Department for Standardization and Metrology to make
provisions for transportation of pesticides to cement factory for further elimination
while the Ministry of Agriculture was given the task to apply to the Council of
Europe for a grant to support the elimination of pesticides.

In 2002 the Government adopted the Decision No. 1543 “On Additional Actions
toward Centralized Storage and Disposal of Out-of-Use and Banned Pesticides”




80
  National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004.
81
  Decision No. 30 of 15-01-2001 on actions toward centralized storage and disposal of out-of-use and banned
pesticides.

ECOS
Environmental Impact Assessment Report                                    Page   70 of 179



which stated that the Ministry of Defense and the Department of Emergency
Situations is to ensure the transportation of pesticides as well as other relevant
technical actions. This Decision also asked the National Ecological Fund to co-
finance the implementation of measures towards centralized storage of pesticides. It
designated the former depot for flammable and explosive substances situated in
Papauti (rayon Rezina) to be used for obsolete pesticides storage. MAFI, MENR and
MOD were assigned to implement this work.

Both decisions had not been implemented due to some objective and subjective
reasons including in particular, proactive confrontation and remonstrance from local
communities and authorities against disposal of obsolete and non-used pesticides.

In 2003 the Government adopted the Decision No. 1389 “On approval of
modifications and agenda in the Governmental Decision 1543 as of 29 November,
2002”. The latest Decision stated that heads of rayons, and mayors of settlements
must select one storehouse on the administrated territory, and in coordination with
the Ministry of Defense and Department of Emergency Situations should make
provisions for the repackaging, transportation and guarding of pesticides until a
destruction option is found. The implementation of this Decision is under way.

The State Ecological Inspectorate outlined a number of criteria to be used while
selecting the sites for centralized storage, which should comply with existing sanitary
and ecological requirements. In particular, the following criteria were suggested:

    (i)      the distance to closest water bodies should not be less than 2000 meters;

    (ii)     the minimum distance to water bodies used for non-fishery purposes has
             to established in relation to warehouses’ capacity as follows: up to 20 t -
             200 m; 20-50 t - 300 m; 50-100 t - 400 m; 100–300 t - 500 m; 300–500
             t - 700 m and more than 500 t – 1000 m;

    (iii)    distance from houses, poultry and livestock farms, water sources, sites of
             livestock and poultry concentration (e.g., grazing areas) should be not less
             than 200 meters.

Besides, while selecting the sites for centralized pesticides storage at the rayon level
the following criteria have been taken into consideration: appropriate technical
condition of potential storage facilities requiring minimum costs for their
rehabilitation; amount of pesticides already stored in those facilities to avoid extra re-
packaging and transportation of pesticides, etc.

To ensure the implementation of the Governmental Decisions, 3,233,500 MDL were
disbursed in 2003-2004 from the National Ecological Fund to cover the costs of
repackaging, transportation and storage of pesticides to/at the assigned warehouses.

The ECOS team investigated all designated rayon storage facilities (description of
investigated warehouses is presented in Technical Appendix) and the following facts
were noticed, pertinent to the activities currently undertaken by the Government:
ECOS
Environmental Impact Assessment Report                                                       Page   71 of 179



 ●      there is an obvious lack of plastic barrels for packing solid pesticides and metal
        drums for liquid pesticides;
 ●      MOD and DES lack fuel for transportation purposes;
 ●      activities were not sufficiently well planned;
 ●      selected sites not always complied with environmental and health requirements;
 ●      there were violations of the technical and sanitary rules, and environmental
        requirements during repackaging, transportation and storage works;
 ●      the involved personnel is not sufficiently trained;
 ●      labeling of barrels (and bags) with indication of weight and pesticides name was
        not done properly or at all;
 ●      many storehouses were over-packed with barrels;
 ●      covers were absent on many plastic barrels;
 ●      at many storehouses, e.g. in Floresti, Cimislia, Ratus and others the liquid
        pesticides were not repackaged and are stored in old rusty barrels;
 ●      in some centralized storehouses there were old used and new spoiled barrels;
 ●      there was no appropriate guarding of the storehouses territory,
 ●      the storehouses territory is often used for passage or grazing of livestock.

The MOD and DES report on repackaging and collection of obsolete pesticides,
dated February 15, 2005, indicated 1,670,287 kg of solid pesticides repackaged in
bags, including 958,049 kg placed in plastic barrels. 92,469 liters of liquid pesticides
have reportedly been transferred to new drums. The remaining amount of pesticides
to be repackaged, collected and transported is 684,325 kg (Annex 6).

4.3.2 Environmental Contamination with POPs

Existing data on the contamination of the environment with POPs pesticides and
particularly PCBs are scarce. There is no systematic information on the level of
contamination of lands adjacent to the pesticide stores and/or on the pathways of
POPs dissipation in the environment. This was one of the major impediments to a
comprehensive assessment of the risks associated with POPs stockpiles and
contaminated sites in Moldova. A few surveys undertaken by the State Ecological
Inspectorate in 2002 and 2003 revealed a significant level of soil contamination with
POPs pesticides (including DDT) around most checked facilities82. These surveys,
however, were limited in scope and extent and were rather fragmentary in temporal
and spatial terms.




82
     National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004.

ECOS
Environmental Impact Assessment Report                                 Page   72 of 179



The EA team, supported by PIU, designed a sampling and analysis program to bring
more light on the issue of environmental pollution with POPs. Several components of
this program were implemented during the spring of 2005 and their results are briefly
presented and discussed below.

Pilot investigation of contamination with POPs pesticides (Orhei rayon)

A pilot investigation of soil contamination near 24 former as well as currently
operating pesticide storage facilities in the Orhei rayon was undertaken. The program
was designed by the EA team and implemented by the SEI central laboratory. One
indicative sample was taken from each location, usually at 50 meters from the
storage facility, in the point where the movement of pesticides would be most likely.
In selecting the sampling point, consideration was given to the landscape features,
adjacent land-use, and proximity to the residential areas. The study revealed that at
most sites the 50-cm surface/top soil layer is significantly polluted with POPs. The
national standard for (DDT+DDE+DDD) in soil is exceeded at some locations as
much as 10-20 times, even at 50 meters from the facility or the remains of the former
facility. Some of those facilities are situated close to health and environmentally
sensitive/vulnerable areas like residential areas or water bodies or water courses. The
results of this survey demonstrate (and confirm) the large extent of the problem of
soil contamination in areas close to former and currently operating pesticide stores.
This represents a direct threat to human and environmental health and urges for
measures being taken to eliminate/limit this risk. The factual results of the
investigation are presented in the Technical Appendix.

Investigation of environmental pathways of POPs pesticides (Pascani)

A thorough integrated investigation of environmental pathways of POPs was
performed in the vicinity of an old pesticide store in village Pascani, Hincesti rayon.
The Pascani facility was used for pesticide storage for about 30 years and presently
contains several tons of obsolete pesticides including 1,300 kg of toxaphen83. The
visual investigation of the facility revealed significant potential health and
environmental risks associated with this store. The building, in poor condition, is
situated in the river Lapusna floodplain, at the outskirts of the residential area and
close to agriculture lands and pastures. The groundwater table is close to the earth
surface and the area is exposed to flooding.

The study was designed by the EA team and implemented by the SEI central
laboratory. Soil, surface and ground water, vegetation and bottom sediments were
investigated for POPs. The results (see the Technical Appendix for details) showed a
high level of soil contamination with (DDT+DDE+DDD) in the area adjacent to




ECOS
Environmental Impact Assessment Report                                          Page   73 of 179



the storage facility (16.6 times exceedance of the national standard). Areas situated at
200-500 m uphill and downhill of the store were not significantly contaminated.
Bottom sediments and vegetation also did not accumulate high amounts of POPs
pesticides while water showed to be the least suitable propagation way for POPs
(insignificant concentrations). The results show that the soil is the main migration
pathway of POPs in the environment. One of the conclusions could be that further
priority remediation measures should focus on cleaning up the soils in areas adjacent
to pesticide stores and an environmental monitoring program is to be tailored for
studying the soils as capture media for POPs and source of long-term residual
impacts.

Vegetation and bottom sediments are other notable pathways of POPs, despite the
content of POPs pesticides in investigated samples did not exceed the national
standards.

Investigation of soil contamination with PCBs

Data on environmental contamination with PCBs are scarce. Most PCBs and PCB-
contaminated equipment in Moldova are concentrated in the energy sector,
particularly in power capacitors. The capacitors represent a significant hazard to the
environment and a real threat for the health of people working at or living in the
vicinity of the substations. Most of them have been in operation for more than 30
years. The capacitors are situated outdoors and PCBs leak from corroded capacitors
to the soil below the capacitor batteries. Due to past incidents of capacitor explosions
and leakage by corrosion the ground below capacitor batteries could be highly
contaminated.

The analysis of soil samples taken by the HMS in 2005 below the capacitors as well
as on the territory of several substations showed a worrying degree of environmental
contamination with PCBs (12 congeners). This was particularly high at the
Vulcanesti (culminating with concentrations of 5300 ppm and 7100 ppm) and
Donduseni (95 ppm) substations. This correlates with the reported facts about
explosions of capacitors that occurred at these stations in the past. In the same time,
even out of the direct reach of PCB leaks from capacitors, their concentrations in the
topsoil on the territory of the substations exceeded the national standard (0.06 ppm)
in almost every sample. This poses very seriously the problem of occupational health
for electrical substations staff.

The factual results of the investigation are presented in the Technical Appendix.




83
     Toxaphene is one of the 12 POPs referred to in the Stockholm Convention.

ECOS
Environmental Impact Assessment Report                                   Page   74 of 179



4.4       Risk assessment

Central Warehouses Risk Assessment

The EA team visited all rayons and evaluated the process of selection of central
warehouses, after discussions with relevant rayonal authorities. The status identified
is as follows:
 ●      Out of the total 37 sites, only in 4 rayons (Straseni, Ialoveni, Drochia and
        Glodeni) central warehouses have not been designated yet.
 ●      In Floresti, Taraclia and Stefan Voda rayons, two central warehouses per rayon
        have been selected.
 ●      In the Criuleni rayon, the central warehouse selected is also used for storing
        obsolete pesticides from the Dubasari raion and the Chisinau municipality.
 ●      The Singerei rayon and Balti municipality are using one central warehouse.

Forced by the current situation (unaccomplished selection process), the EA team has
evaluated the risks associated with selected central warehouses at 41 sites. All sites
have been visited and investigated (repots of field teams’ are annexed in the
Technical Appendix). The spectrum of warehouses has been categorized using
different risk criteria and the most concerned sites have been identified. Finally, an
integrated risk evaluation has been done, allowing ranking warehouses according to
various risk criteria.

Risks induced by the large amount of pesticides stored and the technical
condition of buildings

Seven of the considered warehouses are intended to store relatively large amounts of
pesticides exceeding 100 tons per facility (Ratus, Alexandreni, Tudora, Cimislia,
Grimancauti, Gradinita and Oniscani). Larger amounts of stored pesticides require
longer time and more operations to be undertaken for repackaging, loading and
inventory and this may pose higher risks of spills, operational failures and accidents.
The technical status of warehouses in Alexandreni84 and Tudora is quite good,
ensuring safe conditions for long-term storage. More or less satisfactory is the
technical status of selected warehouses in Ratus (one section has been renovated, 305
tons are already stored) and Gradinita (142 tons are stored). The designated storage
facilities in Cimislia (150 tons stored, but not all stock repackaged) and Oniscani are
in poor condition. At the latter store, one section is in technically satisfactory
conditions but considering the expected large amount of obsolete pesticides to be
stored (124 tons) the other sections require significant rehabilitation. The facility in




84
     Privately owned and operational warehouse

ECOS
Environmental Impact Assessment Report                                                         Page   75 of 179



Grimancauti (132 tons of obsolete pesticides expected) must not be used as a storage
place as the building is seriously damaged.

In 13 warehouses, the amount of stored pesticides is expected to be within the range
50–100 tons per facility. The technical status of buildings and sections designated for
obsolete pesticides storage in Bugeac, Hitresti, Taraclia, Albota de Sus and probably
in Bardar and Milestii Mici85 is satisfactory. In Temeleuti, Gaidar, and Carpineni86
the status of warehouses is less satisfactory and additional rehabilitation may be
required. The condition of Tirnova (61 tons) and Cismichioi (61 tons) stores as well
as the two sites located at the military training fields in Cahul (54 tons) and Ungheni
(78 tons) is poor. In Tirnova, an automobile garage, located on the territory of the
bone meal factory (not in operation), was designated and is already used as a central
warehouse. In Cahul, an old pig farm is used for storing obsolete pesticides. In
Ungheni, a former military depot for toxic chemicals is used, but additional
rehabilitation is required.

The rest of warehouses (21 in total) are intended to store less than 50 tons per
facility. The stores in Ghindesti87, Papauti88, Ciobalaccia89, Sadaclia, Zgurita,
Sturzovca, Porumbeni, Pelivan and Cuhnesti, are in relatively good technical
condition but additional rehabilitation may be required for some of them. At the
Olanesti, Nisporeni, Straseni, and Vorniceni designated sites, the technical condition
of buildings is suitable for short and medium term storage, but there is no adequate
protection against unauthorized access to the storage area. The stores in Clocusna (22
tons), Edinet (3 tons), Recea (23 tons), Cosauti (26 tons), Iargara (25 tons), Bulboaca
(20 tons), Suri (15 tons), and Chipesca (36 tons) are in the worst condition. The
warehouse in Suri was not originally designed for pesticide storage: it is a store for
agriculture products located in an agro-industrial area, which includes currently used
depots for apples and vegetables. At the Bulboaca military training polygon, a
seriously damaged improper building is used for storing obsolete pesticides.

Risks induced by proximity to residential areas

12 designated warehouses90 (29 % from total investigated number) are located at
relatively close distance (not exceeding 500 m) to residential areas. Five stores are




85
   Both warehouses are privately owned and no permission from owners to visit the sites has been obtained
86
   Privately owned
87
   Privately owned and operating warehouse
88
   Former depot for flammable and explosive chemicals
89
   Privately owned and operating warehouse
90
   Ratus (Telenesti rayon), Alexandreni (Singerei rayon and Balti municipality), Bugeac (Gagauz Eri, Comrat
section), Olanesti (Stefan Voda rayon), Clocusna (Ocnita rayon), Cahul SDES training field (Cahul rayon),
Ciobalaccia (Cantemir rayon), Recea (Riscani rayon), Straseni (Straseni rayon), Hitresti (Falesti rayon), Albota
de Sus (Taraclia rayon), Chipesca (Soldanesti rayon)

ECOS
Environmental Impact Assessment Report                                 Page   76 of 179



placed within or at the outskirts of populated areas, in some places close to schools
(Cahul). The most concerned warehouses are:
●    Bugeac (Gagauz Eri, Comrat sector), situated at 300 m from the residential area
     and within active industrial area, with several depots, shops, artesian water
     sources and other relevant facilities. The nearest areas are also used for
     agricultural production, grazing of livestock and apiary.
●    Olanesti (Stefan Voda rayon), situated at 100-150 m from the nearest
     households. The village is located downhill from warehouse and is exposed to
     runoff from that direction. A ravine directed to the village is situated at 20 m
     from warehouse. An artesian water source is also located downhill. The area is
     visited by peasants and livestock and adjacent land is used for agriculture and
     grazing. The warehouse is not fenced.
●    Straseni, situated within the industrial zone of town, with several depots and
     stock buildings. The residential area is situated close to the warehouse as well.
     Shallow drinking wells, artesian boreholes and a watering place for livestock are
     located close to the territory of the store.
●    Albota de Sus (Taraclia rayon), located within the village limits (distance to
     residential buildings and households about 100-150 m). The warehouse is
     located uphill of the village and is likely to contribute to the contamination of
     drinking wells, arable lands and pastures joining the warehouse perimeter.
●    Chipesca (Soldanesti rayon), placed at the outskirts of the village and within its
     industrial area. The warehouse is located on the hill and runoff is directed
     towards households and drinking wells. Arable lands and the nearest drinking
     well are distanced at 10 m and 40 m respectively from the facility. Livestock
     grazing places are present as well.

Risks induced by proximity to agriculture fields and plantations

37 warehouses (or 90 % from total considered sites) are situated close to crop fields,
orchards and vineyards. The distances from warehouses to the sensitive agriculture
zones, vulnerable by contamination of agriculture products and productive lands, are
usually between 10 and 200 m. The list of most concerned warehouses includes 31
sites, where the distance to agricultural fields is only 10-50 m from the perimeter of
warehouse territory.

Risks for livestock

In total, 23 warehouses (56%) have been identified to pose risks for livestock due to
use of lands, situated at 500 m from warehouse or closer, for grazing of cattle and
sheep. The lands around warehouses are not productive pastures, but peasants are
forced to use all available green areas, as they have no alternative lands for feeding
their livestock.

Risks for forest ecosystems



ECOS
Environmental Impact Assessment Report                                                       Page   77 of 179



Twelve warehouses91 (29%) are situated closer than 500 m to forest areas, different
by size, value and vulnerability. The forests located in the vicinity of warehouses are
mostly planted on slopes for mitigation of soil erosion and prevention of ravine
formation. It should be stressed that five warehouses (Tudora, Cimislia, Gradinita,
Papauti and Stuzovca) are located at the forest edge and the distance to the trees is
only 10–60 m. The unknown pesticides stock from these warehouses may contain
herbicides, defoliants, desiccants, which in case of air dispersion may seriously affect
the vegetation and trees, as well as toxic insecticides which can damage the wild
fauna and contaminate the mushrooms, springflowers and berries, which are
collected by local people.

Special attention should be given to the following sites of biggest concern:
 ●   Tudora (Stefan Voda rayon), natural and valuable forest located on the Nistru
     river terrace. The site is included in the list of priority regions for biodiversity
     conservation (future Lower Nistru and Nistru Delta reserves). The distance from
     warehouse is about 40-50 m. The forest is located downhill of warehouse and
     can be polluted by runoff.
 ●   Cimislia, a relatively large forest on slope, with Robinia trees. The distance from
     warehouse is about 50 m. The forest is located uphill of the warehouse, but air
     pollution may affect the associated flora and fauna.
 ●   Gradinita (Causeni rayon), a large valuable natural forest, dominated by Robinia
     and oak trees, included in the list of priority regions for biodiversity
     conservation. The distance from warehouse does not exceed 50 m. The forest is
     located downhill, the runoff and air contamination may affect the forest
     ecosystem. The protected forest reserve Leuntea is located close to the site.
 ●   Papauti (Resina rayon), a large valuable natural oak forest. Located downhill of
     the warehouse. The distance to the forest is about 100 m.

Risks for surface and ground waters

Eight warehouses92 (20%) are situated in areas with relatively high groundwater
table, thus shallow groundwater aquifer contamination is concerned. The most
evident high groundwater level has been observed at the following sites:
 ●   Recea (Riscani rayon). Discharging springs are visible close to the warehouse.
     The groundwater table has been estimated at the depth about 2 m.




91
   Gaidar and Bugeac (Gagauz Eri, Ciadir-Lunga and Comrat sections), Tudora (Stefan Voda rayon), Cimislia
(Cimislia rayon), Gradinita (Causeni rayon), Papauti (Rezina rayon), Chipesca (Soldanesti rayon), Carpineni
(Hincesti rayon), Pelivan (Orhei rayon), Cosauti (Soroca rayon), Sadaclia (Basarabeasca rayon), Sturzovca
(Glodeni rayon).
92
   Ratus (Telenesti rayon), Temeleuti (Floresti rayon),Grimancauti (Briceni rayon), Nisporeni (Nisporeni rayon),
Recea (Riscani rayon), Straseni (Straseni rayon), Sturzovca (Glodeni rayon), Hitresti (Falesti rayon)

ECOS
Environmental Impact Assessment Report                                                      Page   78 of 179



 ●   Temeleuti (Floresti rayon). A spring, wetland vegetation and a drinking shallow
     well have been identified downhill of the warehouse. The distance to the shallow
     groundwater table may be estimated at 3-4 m.
 ●   Straseni. The warehouse is located in the floodplain of the Bic river. The
     adjoining territory is covered by permanent wetland vegetation (reed). The depth
     to the groundwater is estimated at about 2-4 m.
 ●   Sturzovca (Glodeni rayon). Wetland-associated vegetation and small discharging
     springs are present in the proximity of the store. The depth to the water in the
     dug well located on the territory of the facility is about 2 m.

Part of the designated warehouses is placed near water courses and water bodies. At
least 18 warehouses (44%) are situated at less than 500 m from surface waters. Most
of them are small rivulets and small - but important for local population - water
reservoirs. Eight warehouses93 (20%) are located relatively close to the rivers’
floodplains and predominantly on the first terraces of the rivers. The location of
warehouses close to the floodplains can generate additional environmental risks for
sensitive meadow and river ecosystems. The most concerned warehouses are:
 ●   Ratus (Telenesti rayon). The warehouse is situated on the first terrace of the
     floodplain of the river Ciulucul Mare, at about 200-250 m from the floodplain
     itself. The landscape makes possible the contamination of meadow vegetation,
     pasture zones and drainage/irrigation channel directly discharging to the
     Ciulucul Mare river.
 ●   Bugeac (Gagauz Eri, Comrat sector). The warehouse is placed in a dry valley,
     but close to the large floodplain of river Ialpug.
 ●   Nisporeni. The warehouse is situated on the first terrace of river Nirnova and
     uphill of drainage/irrigation canals, which drain the floodplain and further
     discharge to the river. Currently, the floodplain area is used by local population
     for pasture. The distance to the drainage channels does not exceed 150-200 m.
 ●   Carpineni (Hincesti rayon). The warehouse is placed on the first terrace of the
     river Lapusnita and may contribute to pollution of the extensive floodplain area
     downhill. The distance to the river is about 400 m, but existing ravines and
     abrupt hillsides may easily accelerate the movement of washed out contaminants
     to the main stream. The designated obsolete pesticides store is situated at the
     edge of the river sanitary and protection area.
 ●   Recea (Riscani rayon). The warehouse is located close and uphill of the
     Copacheanca river floodplain. The distance to the river and large water reservoir
     used for fish-farming is about 400 m. Local fish-farmers expressed their great




93
  Ratus (Telenesti rayon), Bugeac (Gagauz Eri, Comrat sector), Nisporeni (Nisporeni rayon), Carpineni (Hincesti
rayon), Recea (Riscani rayon), Straseni (Straseni rayon), Sadaclia (Basarabeasca rayon), Bardar (Ialoveni rayon)


ECOS
Environmental Impact Assessment Report                                  Page   79 of 179



     concern since they consider the warehouse being a dangerous pollution source
     for the water body. The selected obsolete pesticides store is situated at the edge
     of the river sanitary and protection area.
●    Straseni. This is the only designated central warehouse which is located directly
     in a river floodplain: the Bic river is flowing at about 400 m away. The selected
     obsolete pesticides depot is situated within the sanitary and protection zone of
     the river Bic.
●    Sadaclia (Basarabeasca rayon). The warehouse is situated on the first terrace of a
     large floodplain area associated with the Cogilnic river. The distance to the river
     is about 1 km.

In other settlements, namely Tirnova (Donduseni rayon), Sturzovca (Glodeni rayon),
Temeleuti (Floresti rayon), Cimislia (Cimislia rayon), Albota de Sus (Taraclia rayon)
the nearest water sources are presented by small springs, rivulets or ponds, located
within 50-200 m downhill of the central warehouse.

Risks associated with transportation

19 warehouses (46%) have been tentatively identified to be concerned with the safety
of obsolete pesticides transportation. The most concerned sites are:
  Gaidar (Gagauz Eri, Ciadir-Lunga sector). The available road is crossing the
    residential zone of village Gaidar and has damaged unpaved sections (1-1.5 km)
    near the village. Transportation during wet conditions is hardly possible.
  Iargara (Leova rayon). About 200 m of unpaved road from the warehouse
    facility are hardly passable under wet conditions. One bridge on the road
    Iargara-Sarata Noua is in poor condition.
  Gradinita (Causeni rayon). The road is passing in the vicinity of several villages
    (Gradinita, Plopi-Stiubeni and Cirnateni) and natural protected areas (Leuntea).
    A few damaged road sections have been identified.
  Olanesti (Stefan-Voda rayon). The main road is passing the village Olanesti.
    Hardly trafficable during wet conditions.
  Oniscani (Calarasi rayon). The road is passing along the river floodplain.
  Nisporeni. The road is passing along the river floodplain.
  Carpineni (Hincesti rayon). The road is passing along the river floodplain and is
    crossing several villages (Negrea, Sofia).
  Ratus (Telenesti rayon). The road is passing village Ratus and along the river
    floodplain.
  Chipesca (Soldanesti rayon). The road is damaged on some sections; one bridge
    could be problematic during poor weather conditions. The road is passing village
    Dobrusa.
  Temeleuti (Floresti rayon). The road is damaged near the warehouse (150-200
    m) and crossing village Solonet.
  Clocusna (Ocnita rayon). The road from warehouse is damaged and sloping. One
    bridge is seriously damaged. The site is hardly reachable during wet conditions.
    The road is passing village Clocusna.
  Cimislia (Cimislia rayon). The road from warehouse is seriously damaged on the
    slope. It is hardly passable even in dry period.


ECOS
Environmental Impact Assessment Report                                     Page   80 of 179



    Porumbeni (Criuleni rayon). The road is deteriorated by heavy cars from the
     closely located mine. The road is hardly passable even in dry period.
    Milestii Mici (Ialoveni rayon). About 1 km of slope and unpaved road in the
     village Milestii Mici could be hardly accessible under wet conditions.
    Vorniceni (Straseni rayon). The 2 km unpaved road from warehouse could be
     hardly accessible during wet conditions.
    Pelivan (Orhei rayon). There is about 1 km of unpaved village road with difficult
     access to the warehouse during wet conditions. The road is passing village
     Pelivan.

Integrated risk assessment

Simplified integrated risk assessment and ranking system has been applied in order
to cluster the central warehouses by the risk factors identified during the study (refer
to Annex 7 for more details). The integration involved the following risk criteria:
●    Amount of pesticides stored or expected to be stored after centralization
●    Technical status of buildings
●    Distance to the nearest populated area, agriculture lands, water courses, forests,
     and pastures.
●    Location of warehouse against vulnerable floodplain zones.
●    Estimated depth to the first groundwater aquifer.
●    Need for repackaging of pesticides in the open space (out of warehouse if
     internal space is limited).

According to the estimation of integrated risk and classification of warehouses
associated risks by 4 categories (higher, considerable, moderate, low) the following
conclusion may be drafted:
●    Higher risks have been identified for Ratus, Bugeac, Cimislia, Grimancauti,
     Chipesca, Recea and Straseni sites.
●    Considerable risks are associated with Temeleuti, Gaidar, Tudora, Clocusna,
     Nisporeni, Oniscani, Edinet, Carpineni, Pelivan, Sadaclia, Sturzovca, Albota de
     Sus and Gradinita sites.

Within this integrated classification, one can distinguish between the risk factors
focused on population (distance to settlements, agriculture lands, livestock grazing
fields) and the risks mostly associated with the environment (distance to water
bodies, forested areas, pastures, wetlands, river floodplains, and depth of
groundwater table). These risk criteria were substantiated with factors as the amount
of pesticides stored and the technical condition of the facilities.

Considering the risks for the population the situation looks as follows:
●    Higher risks have been identified for Cimislia (agriculture, pastures),
     Grimancauti (agriculture, pastures), and Chipesca (village, agriculture, pastures)
     sites.



ECOS
Environmental Impact Assessment Report                                  Page   81 of 179



●    Considerable risks are associated with Ratus (residential area), Gaidar
     (agriculture, pastures, residential area), Cismichioi (agriculture, pastures),
     Olanesti (residential area, agriculture), Tirnova (agro-industrial zone), Cahul
     (residential area, pastures), Oniscani (agriculture, pastures), Edinet (residential
     area, agriculture, pastures), Gradinita (amount stored), Clocusna (agriculture,
     pastures, village), Recea (residential area, agriculture, fish-farming), Straseni
     (residential area), Vorniceni (vineyards), and Albota de Sus (residential area)
     sites.

Considering the risks to the environment the situation is as follows:
●    Higher risks have been identified for Ratus (floodplain), Temeleuti
     (groundwater, springs), Cimislia (forest, surface water), Grimancauti
     (groundwater), Carpineni (floodplain), Recea (water reservoir and river) and
     Straseni (floodplain, groundwater, wetland) sites.
●    Considerable risks are associated with Bugeac (forest, floodplain), Gaidar
     (water stream), Tudora (forest, spring), Nisporeni (floodplain, river), Chipesca
     (forest), Oniscani (water stream), Gradinita (forest, protected area), Pelivan
     (water stream, forest), Sadaclia (forest, floodplain) and Sturzovca (water stream,
     forest, groundwater) sites.




ECOS
Environmental Impact Assessment Report                                                                                                                                                                                                                                Page           82 of 179



Table 1. Integrated risk assessment and ranking of central warehouses




                   Amount of pesticides storing


                                                  Warehouse technical status




                                                                                                                                                                                                                                Location at the river flood
                                                                                                                                                        Distance to water courses
 Warehouse                                                                                                                                                                                                                                                                           TOTAL         RISC    HUMAN      RISK    ENVIRON-     RISK




                                                                                                                             Distance to agricultural
  (rayon)                                                                                                                                                                                                                                                                             RISK       RANKING   HEALTH   RANKING    MENTAL    RANKING




                                                                                                                                                                                                                                                              Depth to groundwater
                                                                                                     Distance to populated




                                                                                                                                                                                                         Distance to pastures
                                                                               Available space for
                                                                                                                                                                                                                                                                                     INDEX                   RISK                RISK




                                                                                                                                                                                    Distance to forest
                                                                                                                                                                                                                                                                                                            INDEX               INDEX




                                                                               repackaging

                                                                                                     locality




                                                                                                                                                                                                                                                              aquifer
                                                                                                                             zones




                                                                                                                                                                                                                                plain
Ratus             ***                             **                             **                     **                   *** ***                                                  -                  ***                        **                           **                     22         H         15       C          17        H
Telenesti

Temeleuti          **                             **                           ***                         *                        *                   ***                         **                   ***                             -                    ***                       20         C         12       M          18        H
Floresti

Ghindesti           *                             *                                 *                      *                    **                       *                            -                  ***                             -                         *                    11          L        9         L         8          L
Floresti

Alexandreni       ***                             *                                 *                *** ***                                            **                            -                   *                              -                         *                    15         M         12       M          9          L
Singerei+ Balti

Porumbeni           *                             **                             **                        *                 ***                        **                            -                   *                              -                         *                    13         M         10       M          9          L
Criuleni+
Dubasari +
Chisinau

Bugeac             **                             *                                 *                *** ***                                            **                          ***                  **                         **                           **                     21         H         12       M          15        C
Comrat

Gaigar             **                             **                                *                   **                   *** *** *** ***                                                                                             -                         *                    20         C         13       C          15        C
Gagauzia,
Ceadir Lunga



ECOS
Environmental Impact Assessment Report                                                                                                                                                                                                                                Page           83 of 179




                   Amount of pesticides storing


                                                  Warehouse technical status




                                                                                                                                                                                                                                Location at the river flood
                                                                                                                                                        Distance to water courses
 Warehouse                                                                                                                                                                                                                                                                           TOTAL         RISC    HUMAN      RISK    ENVIRON-     RISK




                                                                                                                             Distance to agricultural
  (rayon)                                                                                                                                                                                                                                                                             RISK       RANKING   HEALTH   RANKING    MENTAL    RANKING




                                                                                                                                                                                                                                                              Depth to groundwater
                                                                                                     Distance to populated




                                                                                                                                                                                                         Distance to pastures
                                                                               Available space for
                                                                                                                                                                                                                                                                                     INDEX                   RISK                RISK




                                                                                                                                                                                    Distance to forest
                                                                                                                                                                                                                                                                                                            INDEX               INDEX




                                                                               repackaging

                                                                                                     locality




                                                                                                                                                                                                                                                              aquifer
                                                                                                                             zones




                                                                                                                                                                                                                                plain
Cismichioi         **                             ***                               *                      *                 ***                        *                             -                  ***                             -                         *                    15           M       13       C          11        M
Vulcanesti

Tudora            ***                              *                             **                        *                 ***                        **                          ***                   *                              -                         *                    17           C       11       M          13        C
Stefan Voda

Olanesti            *                             **                                *                *** ***                                            *                             -                  ***                             -                         *                    15           M       13       C          9          L
Stefan Voda

Cimislia          ***                             *** ***                                                  *                 *** *** *** ***                                                                                             -                         *                    23           H       16       H          19        H
Cimislia

Tîrnova            **                             **                                *                   **                   ***                        *                             -                  ***                             -                         *                    15           M       13       C          10        M
Donduseni

Grimancauti       ***                             *** ***                                               **                   ***                        **                            -                  ***                             -                       **                     21           H       17       H          16        H
Briceni

Gradinita         ***                             **                             **                     **                   ***                        *                           ***                   *                              -                         *                    18           C       13       C          13        C
Causeni

Clocusna            *                             *** ***                                               **                   ***                        *                             -                  ***                             -                         *                    17           C       15       C          12        M
Ocnita

Papauti             *                              *                                *                      *                 ***                        *                           ***                   *                              -                         *                    13       M           8         L         9          L
Rezina


ECOS
Environmental Impact Assessment Report                                                                                                                                                                                                                                Page           84 of 179




                   Amount of pesticides storing


                                                  Warehouse technical status




                                                                                                                                                                                                                                Location at the river flood
                                                                                                                                                        Distance to water courses
 Warehouse                                                                                                                                                                                                                                                                           TOTAL         RISC    HUMAN      RISK    ENVIRON-     RISK




                                                                                                                             Distance to agricultural
  (rayon)                                                                                                                                                                                                                                                                             RISK       RANKING   HEALTH   RANKING    MENTAL    RANKING




                                                                                                                                                                                                                                                              Depth to groundwater
                                                                                                     Distance to populated




                                                                                                                                                                                                         Distance to pastures
                                                                               Available space for
                                                                                                                                                                                                                                                                                     INDEX                   RISK                RISK




                                                                                                                                                                                    Distance to forest
                                                                                                                                                                                                                                                                                                            INDEX               INDEX




                                                                               repackaging

                                                                                                     locality




                                                                                                                                                                                                                                                              aquifer
                                                                                                                             zones




                                                                                                                                                                                                                                plain
Nisporeni           *                             **                                *                      *                 ***                        **                            -                  ***                        **                           **                     17         C         11       M          13        C
Nisporeni

Chipesca            *                             *** *** *** ***                                                                                       *                           *** ***                                              -                         *                    21         H         16       H          15        C
Soldanesti

DES training       **                             **                                *                *** ***                                            *                             -                  **                              -                         *                    15         M         13       C          9          L
field Cahul

Ciobalaccia         *                              *                                *                   **                   ***                        **                            -                  ***                             -                         *                    14         M         11       M          9          L
Cantemir

Oniscani          ***                             ***                               *                      *                 *** ***                                                  -                  ***                             -                         *                    18         C         14       C          14        C
Calaras

Edinet              *                             ***                               *                   **                   *** ***                                                  -                  ***                             -                         *                    17         C         13       C          12        M
Edinet

Carpineni          **                             **                                *                      *                 *** *** ***                                                                 **                         **                             *                    20         C         11       M          16        H
Hincesti

Pelivan             *                             **                                *                   **                   *** *** *** ***                                                                                             -                         *                    19         C         12       M          14        C
Orhei

Recea               *                             ***                               *                   **                   *** ***                                                  -                  ***                        **                        ***                       21         H         13       C          16        H
Riscani


ECOS
Environmental Impact Assessment Report                                                                                                                                                                                                                                   Page           85 of 179




                   Amount of pesticides storing


                                                   Warehouse technical status




                                                                                                                                                                                                                                   Location at the river flood
                                                                                                                                                         Distance to water courses
 Warehouse                                                                                                                                                                                                                                                                              TOTAL         RISC    HUMAN      RISK    ENVIRON-     RISK




                                                                                                                              Distance to agricultural
  (rayon)                                                                                                                                                                                                                                                                                RISK       RANKING   HEALTH   RANKING    MENTAL    RANKING




                                                                                                                                                                                                                                                                 Depth to groundwater
                                                                                                      Distance to populated




                                                                                                                                                                                                            Distance to pastures
                                                                                Available space for
                                                                                                                                                                                                                                                                                        INDEX                   RISK                RISK




                                                                                                                                                                                      Distance to forest
                                                                                                                                                                                                                                                                                                               INDEX               INDEX




                                                                                repackaging

                                                                                                      locality




                                                                                                                                                                                                                                                                 aquifer
                                                                                                                              zones




                                                                                                                                                                                                                                   plain
Straseni
(candidat)          *                             **                                 *                *** *** ***                                                                       -                  *** *** ***                                                                     22         H         13       C          16        H

Vorniceni          *                              ** ***                                                   *                  ***                        *                             -                   ***                             -                          *                    15         M         13       C          11        M
(candidat)
Straseni

Cosauti            *                              ***                               *                      *                  ***                        *                           ***                    *                              -                          *                    15         M         10       M          11        M
Soroca

Sadaclia           *                               *                                *                   ** *** ** *** **                                                                                                             **                               *                    18         C         10       M          13        C
Basarabeasca

Zgurita (cand.)    *                               *                                *                      *                  *** **                                                   -                   **                              -                          *                    12          L        9         L         8          L
Drochia

Suri (cand.)       *                              ***                               *                      *                    **                       **                            -                   **                              -                          *                    13         M         10       M          10        M
Drochia

Bardar (cand.)    **                              **                                *                      *                  *** **                                                   -                   ***                             -                          *                    15         M         12       M          11        M
Ialoveni

Milistii Mici     **                              **                                *                   ** *** **                                                                      -                   ***                             -                          *                    16         M         13       C          11        M
(candidat)
Ialoveni

Sturzovca          *                               *                                *                      *                  *** *** *** ***                                                                                              -                     ***                       19         C         10       M          15        C


ECOS
Environmental Impact Assessment Report                                                                                                                                                                                                                                  Page           86 of 179




                   Amount of pesticides storing


                                                   Warehouse technical status




                                                                                                                                                                                                                                  Location at the river flood
                                                                                                                                                         Distance to water courses
 Warehouse                                                                                                                                                                                                                                                                             TOTAL         RISC    HUMAN      RISK    ENVIRON-     RISK




                                                                                                                              Distance to agricultural
  (rayon)                                                                                                                                                                                                                                                                               RISK       RANKING   HEALTH   RANKING    MENTAL    RANKING




                                                                                                                                                                                                                                                                Depth to groundwater
                                                                                                      Distance to populated




                                                                                                                                                                                                           Distance to pastures
                                                                                Available space for
                                                                                                                                                                                                                                                                                       INDEX                   RISK                RISK




                                                                                                                                                                                     Distance to forest
                                                                                                                                                                                                                                                                                                              INDEX               INDEX




                                                                                repackaging

                                                                                                      locality




                                                                                                                                                                                                                                                                aquifer
                                                                                                                              zones




                                                                                                                                                                                                                                  plain
(candidat)
Glodeni

Cuhnesti           *                               *                                *                   ** ***                                             -                          -                    *                              -                          *                    10          L        9         L         5          L
(cand.)
Glodeni

Hitresti          **                               *                                *                 *** ***                                            *                                                **                              -                       **                      15         M         12       M          9          L
Falesti

Iargara            *                              ***                               *                   ** ***                                           *                            -                    *                              -                          *                    13         M         11       M          8          L
Leova

Taraclia          **                               *                                *                      *                  ***                        *                            -                    *                              -                          *                    11          L        9         L         7          L
Taraclia

Albota de Sus     **                               *                                *                 *** *** ***                                                                     -                   ***                             -                          *                    17         C         13       C          11        M
Taraclia

MOD training       *                              *** ***                                                  *                  ***                        *                            -                    *                              -                          *                    14         M         12       M          10        M
field Bulboaca
Anenii Noi
MOD training
field Ungheni     **                              **                                *                        -                      *                    *                           *                     *                              -                          *                    10          L        7         L         9          L
Note:
* - low risk; ** - middle risk; *** - high risk
H – higher risk, C – considerable risk, M – moderate risk, L – low risk


ECOS
Environmental Impact Assessment Report                                  Page   87 of 179




5 Project Alternatives
This section assesses the project alternatives for dealing with the current POPs
pesticides and PCBs stockpiles in Moldova. These alternatives have been extensively
discussed along the last years in the country, particularly during the development of
the Stockholm Convention National Implementation Plan (NIP) and during the
project preparation. The two major alternatives, which have been proposed during
this study and have been discussed with the stakeholders during the public
consultation workshop in February 2005, are: "without project" and "with project".
Both alternatives are discussed below in more detail. The GEF project alternative
will support on-the-ground investments for environmentally safe disposal of POPs
pesticides and PCBs; building institutional capacity for sound management of POPs;
and raising public awareness on POPs risks. The study considered various
configurations for the project design including various disposal options; siting of
facilities; methods of collection, packaging and storage; institutional & socio-
political risks. It must be stated that the alternative disposal options for POPs
pesticides and PCBs stockpiles are largely the same, however, all notable differences
are highlighted below.

5.1    Without Project Alternative

The "without project" alternative represents the current (or moderately enhanced)
efforts of the Government to solve the problem. This alternative is to be rejected
because it does not offer a long-term solution to the problem. Nevertheless the
"without project" scenario is described below to provide a baseline for further
stockpiles management activities, planned by the current project.

Under "without project" scenario, Moldova would apply its existing policies,
regulations and management approach to the problem of obsolete pesticides and
PCBs. These include:
●     the Government Decision No. 1389 of 24-11-2003 on measures for centralized
      storing and neutralization of obsolete pesticides.
●     the Stockholm Convention NIP describing Moldova's POPs situation, priorities
      and management activities, approved by the Government in October 2004 (its
      implementation is likely to face difficulties, since the NIP is largely relying on
      international sources).
●     obligations under the Stockholm, Basel and Rotterdam Conventions and the
      Aarhus protocol on POPs to the Convention on Long-Range Transboundary Air
      Pollution (chronic lack of institutional and financial capacity).



ECOS
Environmental Impact Assessment Report                                                    Page   88 of 179



      Under "without project" scenario, two sub-scenarios were considered:
       "business as usual" and "no action".

So far, Government efforts were focused on centralizing all obsolete (including
POPs) pesticides in a few locations in the idea of limiting the dissipation of
chemicals in the environment and, implicitly, decreasing the health and
environmental risks. Under the "business as usual" sub-scenario, Moldova is likely to
continue this management practice, no more. In the absence of project, the country
would continue to respond to only emergency situations with POPs pesticides or
accidental releases of PCBs, on a case-by-case basis. It looks unlikely that the
Government would develop soon an adequate policy framework and management for
ensuring the environmentally sound management and eventual elimination of all
POPs pesticides and PCBs.

Along the 1990s, the Government made several attempts to solve the problem of
obsolete pesticides stockpiles, trying to implement different options including
centralization of all obsolete pesticides stocks at one storage facility or their
incineration in cement kilns in Moldova. These attempts have all failed due to the
inadequate preparedness, lack of resources, poor compliance, low awareness, non-
transparency of decisions taken, and protests from local population. According to the
latest Government Decision94 obsolete pesticides are to be centralized at the rayon
level. The responsibility for repackaging and transportation to storage sites was
assigned to the Ministry of Defense and the Department for Emergency Situations
while selection and preparation of storage facilities as well as ensuring safe storage
was assigned to the local authorities.

The implementation of this Decision is under way. Centralization has been
completed in several rayons, but has been discontinued due to financial limitations.
Besides, poor management led to the situation when by April 2005, 9 rayons out of
32 have not even selected and designated the facilities to store obsolete pesticides.
The centralization, implemented by MOD and DES so far, was done with many
violations of environmental safety requirements. Some of them are listed below:
 ●    Not all selected central storages are located in areas which can be considered
      safe enough from the health and environmental perspective (close to villages,
      near forests, rivers and water bodies or within flooding risk areas).
 ●    In some cases, selected warehouses have not adequately been prepared for safe
      storage (e.g. no fence, no guards, free access of people and livestock).




94
  Government Decision No. 1389 of 24-11-2003 on modifications and amendments to the Government Decision
No. 1543 of 29-11-2002 concerning additional measures for centralized storage and neutralization of obsolete
pesticides.

ECOS
Environmental Impact Assessment Report                                  Page   89 of 179



●    In some rayons the selection of warehouses has resulted in conflict situations
     between the public and the local authorities (e.g. at Straseni, Donduseni,
     Drochia, and Briceni sites).
●    No identification of unknown pesticides was done before repackaging.
●    Repackaging process itself was not always in line with safety rules (e.g. no
     labeling, use of damaged bags, absence of barrels' caps, etc).
●    Some of the central facilities, where repackaging and storing of pesticides has
     been completed, are overloaded. Storage of barrels with obsolete pesticide has
     been done without considering the need to have enough empty space, and
     transport and emergency corridors inside the building (e.g. Grimancauti, Tudora,
     Cimislia, Chipesca, Bulboaca, and Temeleuti).
●    In some warehouses the repackaging has not been completed properly (only
     plastic bags, no barrels), e.g. at Chipesca, Grimancauti, and Nisporeni sites.
●    There are no safety perceptional labels placed on facility walls, doors and fences.
●    A few cases of fire accidents inside of central warehouses after completed
     centralization have been registered (e.g. Gradinita, Cimislia, and Ratus).
●    Sometimes liquid pesticides have been pored into (only available) old corroded
     metal drums.
●    Emptied old drums have partly been abandoned at the old storage sites, or just
     thrown around in the central warehouses sections.
●    Several emptied warehouses have not been cleaned-up properly: old package
     materials or even residuals of chemical substances are left there (e.g. Taul,
     Iurceni, and Gratiesti).
●    No measures have been taken to reduce the risks from the abandoned old
     warehouses: many of them are being dismantled and used by local population for
     construction needs.
●    There are a few cases of discontent of the local authorities and the population
     with the way the centralization was done, e.g. in Grimancauti and Albota de Sus.
●    Several cases of theft of plastic barrels from central warehouses were reported,
     e.g. at Ratus, Bugeac, Tirnova, Gradinita, and Chipesca sites.

According to the "business as usual" sub-scenario centralization of obsolete
(including POPs) pesticides would probably be completed within several years (the
expectations of the ministries in charge to finalize the centralization process by the
end of 2005 look overly ambitious and unlikely to be done if safety rules are to be
complied with). The crucial element is financing from the National Ecological Fund
providing about one million lei (some US$ 80,000) per year for purchase of plastic
barrels and metal drums for pesticides packing. If this financial source will
eventually dry out the "business as usual" scenario can quickly become the "no
action" scenario, resulting in incomplete centralization of POPs pesticides.

In the case of PCBs, the “business as usual” scenario tends to be almost equal to the
“no action” situation due to the fact that, so far, very little was done in Moldova in
this field. Information on PCBs and PCB-containing equipment has been very scarce

ECOS
Environmental Impact Assessment Report                                  Page   90 of 179



until recently and the problem basically remained with the energy companies’
management. The World Bank “Enabling activities for the implementation of the
Stockholm Convention on POPs in Moldova” project and developed National
Implementation Plan have brought this issue to the attention of the central
authorities. However, the government currently has neither proper understanding of
the magnitude of the problem, nor the tools to handle it. There is lack of data on
PCBs in transformers, switches and other power equipment (except for capacitors) in
energy as well as other sectors. The development of a hazardous waste management
system in Moldova is still in a preliminary phase. Current national legislation does
not require the holders of PCB-containing power equipment to identify and label it
accordingly and this hampers any further management and disposal of it. Finally, the
country (including the government and the energy companies) does not have the
technical and human capacity and financial resources to solve the problem of PCBs.

The consequences of both sub-scenarios under "without project" alternative (and the
associated risks stemming from these) will be the following:
●    The Government will proceed slowly with centralization of POPs pesticide
     stocks while the problem of PCBs will probably not go further than a limited
     inventory of PCB-oils and PCB-contaminated power equipment (at best).
●    Financing for disposal of obsolete pesticide stocks and PCBs issues will be very
     limited.
●    Institutional capacity to manage POPs stockpiles will remain deficient.
●    Poor monitoring and enforcement are likely to undermine the intentions to better
     manage the risks of POPs dissipation.
●    Leaving the PCBs at sites undisturbed and (partly) keeping POPs pesticides at
     rayon facilities is entailing threats to human health and the environment posed
     by site leaks, release by accidents, fires or other human failures. The continuous
     dissipation of POPs in the environment can harm biodiversity, undermine the
     groundwater drinking supplies in rural areas and create the potential for
     agriculture products contamination.
●    General awareness of POPs (and especially PCBs) and their environmental and
     heath impact will remain very limited. This may lead to POPs issues going lower
     in the government’s priorities due to the limited appreciation of the fact that
     timely addressing POPs will contribute to agricultural sustainability and access
     to Western markets, poverty alleviation, and development agenda.
●    Local concerns at rayon obsolete pesticide storage sites will be growing (as they
     do already) since public awareness on these matters is low while national
     authorities prefer simple administrative approaches rather than comprehensive
     awareness campaigns and stakeholder involvement in the decision-making
     process.
●    Lack of resources for operation costs, e.g. maintenance of proper condition of
     storage facilities or keeping the obsolete pesticide stocks safe will become
     chronic. It is worth noting that this money is to be spent to store materials which
     finally will have to be destructed anyway. Local administrations already

ECOS
Environmental Impact Assessment Report                                   Page   91 of 179



      experience difficulties with paying salaries to the guards and financial pressure
      will increase. Besides, the level of salaries is extremely low and does not provide
      incentives for guards to do their job properly.
●     Consequently, theft may increase, associated with fires, as occurred already
      several times at some storage facilities. This is going to contribute to spreading
      POPs pesticides out in the environment, which will increase health and
      environmental risks.
●     Risks of leaking/spreading are likely to increase in time, also due to (currently
      non UN-approved) package deterioration.
●     No remediation activities will be undertaken mainly due to: (i) lack of finance;
      and (ii) very limited knowledge and capacity.

In conclusion, lack of national capacity for solving the problem of POPs pesticides is
obvious (equally, there is no capacity to recover, collect, store and dispose PCBs
safely). Starting with the 1990s, the Government made several attempts to get the
situation under control by repackaging the obsolete pesticides spread out in hundreds
of dilapidated locations allover the country, and by centralizing them in a limited
number of better controlled facilities. So far, this did not bring significant results in
terms of risk diminution. The willingness of international community to provide
grant resources to Moldova is an indication of "willingness to pay" for a risk
perceived to be substantial.

5.2    GEF Project Alternatives

The project will support on-the-ground investments for environmentally safe disposal
of obsolete POPs, including co-financing for repackaging and centralized safe
storage of obsolete pesticides, and PCBs in the energy sector, as well as their final
destruction. The project will support a detailed inventory and risk assessment of the
POPs pesticides storage sites and PCBs as well as a feasibility study of remediation
measures at one electric station in Vulcanesti. GEF will provide incremental funding
for strengthening national POPs institutional capacity; enhancing monitoring and
enforcement activities; and training and capacity building for POPs handling.

The project will be a major contribution to:
●     Eliminating/minimizing the risks of further releases of POPs pesticides and
      PCBs from leaking storage sites by ensuring their safe recovery, transportation,
      storage and disposal;
●     Building institutional capacity to manage POPs in an environmentally sound
      manner;
●     Raising public awareness of POPs' risks to the environment and human health;
      and
●     Moldova's general capacity to comply with the requirements of the Stockholm
      Convention.




ECOS
Environmental Impact Assessment Report                                     Page   92 of 179



The EA study considered various configurations for the project design. Several
parameters were identified as critical to the overall environmental impacts, namely
(i) disposal options; (ii) siting of facilities; (iii) methods of collection, packaging and
storage; and (iv) ways of transportation. The options considered and conclusions
reached are summarized below.

5.2.1 Disposal options

As part of the project, POPs stocks will be collected, inventoried, repacked and
stored. POPs pesticides will be stored in 37 warehouses until the start of disposal
process. PCB-containing capacitors will basically remain at their place at electric
stations before disposal begins (except for leaking capacitors which are to be
dismantled from their batteries and stored in hermetic containers at the stations).
Several final disposal options have been carefully evaluated by project design team
and consulted with major stakeholders.

The following disposal options have been considered under the GEF project:
●    Medium to long-term storage in a limited number of storage facilities (generally,
     one facility per rayon – for pesticides, and at each electric substation – for
     PCBs). For pesticides, this option will (probably) require a new repackaging in
     UN-approved package materials since present packaging (plastic bags and
     plastic barrels) is not dedicated to long-term storage and, basically, it was
     selected by the Government as the currently cheapest solution.
●    In-country disposal (using facilities available within Moldova), including
     thermal neutralization (e.g. in cement kilns or in a mobile incinerator), chemical
     treatment or landfill. It must be noted that only the first mentioned technique can
     be envisaged for PCBs.
●    Out-of-country disposal (export to a disposal facility in a third country).

5.2.1.1 Local long-term storage

As regards POPs pesticides, long-term storage can be implemented in the current
configuration (37 centralized facilities), in one facility or in a number of facilities.

If the current configuration (37 centralized facilities) is to be implemented it must be
taken into account that, in the public perception, this option is not significantly
different from the “business as usual” situation under the “no project” alternative and
most of the risks associated with that alternative will also be applicable to this one. In
short, the storages will remain vulnerable to renewed releases of POPs by natural
disaster, accidents, fires and other human failure). Besides, as already mentioned, the
selection of district warehouses often resulted in conflicts between the public and the
local authorities and the latter accepted to host the pesticide stockpiles in exchange
for the promise that this is going to be a provisory measure and the stocks are to be
evacuated as soon as possible. If the current situation will last beyond reasonable
terms the recrudescence of local population protests is highly probable. Thus, in the
medium to long term this situation looks unsustainable.

ECOS
Environmental Impact Assessment Report                                                      Page   93 of 179



The idea of storing the pesticides in one single (existing) place was tested by the
Government95,96 but now it seems irremediably spoiled by two previous failures. The
option of a new store construction is expensive. Besides, Moldova is a densely
populated country, with predominantly rural population and intensive agriculture
land-use. Therefore, selecting a site responding to all health and environmental
criteria and resolving associated tenure problems might turn to be a difficult issue.

Irrespective of the configuration chosen, prior to storage the waste material will
require expert repackaging, sampling and analysis (only identified wastes should be
stored in any repository) while storage facilities themselves will have to be upgraded.
This option requires regular inspection of stores, immediate containment of leakages
and spillage's and proper stacking of available stock. It requires significant operating
and maintenance costs while not providing a final solution to the problem. Since
stored POPs will have to be disposed of anyway, this method increases the cost of
final disposal therefore it is not preferred.

Leaving the PCB-containing equipment in a storage vulnerable to renewed releases
of POPs by natural disaster, accidents, fires and other human failure is going to raise
the risks for the environment, and has to be rejected. In any case, this equipment will
have to be finally destructed and there is no reason to anticipate that cheaper disposal
would be available in the future. The total costs will be higher by establishing a
temporary storage facility and storing the capacitors for some time.

5.2.1.2 Local Landfill

Landfilling of pesticides residuals is an option known in Moldova. Over the period
1978-1988, 3,940 tons of obsolete pesticides (including 654 tons of DDT) have been
buried near the Cismichioi village, in the South of Moldova. Limited monitoring data
available indicated the contamination of topsoil cover of the landfill. The deposit is
full and there is no place left for eventual stockpiling of new amounts of toxic waste.
Such an idea would be extremely unpopular since the Cismichioi landfill has been
for years a major concern for local inhabitants and environmental NGOs.

To summarize, this method is not acceptable nowadays on the following grounds:
 ●   POPs pesticides are very stable and will not breakdown under landfill
     conditions.
 ●   There may be problems of lateral and downward migration of contaminants
     outside the landfill site due to leaching.




95
   Government Decision No. 474 of 21.05.1997 on measures for collection and centralized storage of obsolete
pesticides.
96
   Government Decision No. 30 of 15.01.2001 on measures for centralized storage and neutralization of obsolete
pesticides.

ECOS
Environmental Impact Assessment Report                                                         Page   94 of 179



 ●   There is a lack of empty specifically engineered landfill site with leachate
     capture and treatment in Moldova.
 ●   The cost for construction of new big landfill is high, construction of several
     small landfills are also costly and limited by high population density in the
     country.
 ●   In general, landfilling is not an acceptable option for the disposal of pesticides in
     the opinion of the specialized international agencies97.
 ●   Landfilling is not an option for the disposal of PCBs either.

5.2.1.3 Local incineration

Currently there are no purpose-built large-scale fixed hazardous waste incinerators in
Moldova and there are no considerations for establishing such installations. Large
incinerators are expensive in terms of initial investment (ranging from
US$10,000,000 to 200,000,000 depending on the capacity, stack gas cleaning and
water treatment performance) and operating costs. In addition, these incinerators
require permanent expert supervision, maintenance and repair, (expatriate) highly
trained technicians, continuous supply of fresh water, reliable supply of electricity,
large quantities of chemicals for gas and liquid effluent treatment and safe disposal
of ashes and scrubber liquor. All these factors are essential if they are to be operated
safely and comply with emission requirements.

These facilities currently only operate effectively in the US and Europe and are cost-
effective only if a continuous and substantial stream of chemical waste is offered for
incineration. This is clearly not the case in Moldova and this option will not be
considered further in this study.

Similarly, smaller or even mobile hazardous waste incinerator units have many of the
limitation outlined above. In addition they are also unable to take large packages of
waste or, for example, PCB capacitors. A mobile incinerator costs at least US$ 5-7
million. Using a mobile incinerator for capacitors destruction would also imply
installation of a shredder at a price of approximately US$ 1 million. Considering the
relatively small amount of POPs waste in Moldova using a mobile unit most
probably would be more costly than disposal abroad. The costs of establishing a
mobile facility might be acceptable if this would be the first step in creating a full
hazardous waste treatment system with a facility for final destruction. However, at
this moment Moldova is not ready to create such a system where legislation and
enforcement secure a stable flow of hazardous waste to the plant. The international
experience shows that after starting this process it takes 7 to 15 years to have such a




97
 Disposal of bulk quantities of obsolete pesticides in developing countries. Provisional technical guidelines.
UNEP, WHO, FAO. 1996.

ECOS
Environmental Impact Assessment Report                                                         Page   95 of 179



facility running. Such a time span would delay too much the destruction of POPs in
Moldova, with all associated risks.

Incineration in the cement kilns can theoretically be an option for POPs pesticides
but experience with their use in developing countries is still very limited. Besides,
there are several environmental and technological limitations with this method98. The
Government of Moldova considered the option of incinerating obsolete pesticides at
the cement plant in Rezina. This idea was abandoned after the preliminary study
showed that only 10-15% of the pesticide stockpiles could be destructed in this way
and the costs of adapting the plant to this operation, requested by the owner (Lafarge
company), amount to US$ 10 million. It must be also stated that this method is
inapplicable to PCB-containing and PCB-contaminated equipment.

All variants of the local incineration option are likely to provoke a wave of public
opposition, at both local and national level. The option is not considered further in
this study.

5.2.1.4 Local chemical treatment

No suitable facilities exist in Moldova. Chemical treatment of large quantities of
material requires: (i) special reactor tanks; (ii) process control devices; (iii) analytical
facilities; (iv) continuous expert supervision; (v) a disposal facility for residues; and
(vi) a range of chemicals suitable for reaction with all types of obsolete pesticides.

The wide variety of pesticide types, coupled with the requirements above make the
use of this technology locally unsuitable.

5.2.1.5 Transshipment to a third country for final destruction

The most widely used method in the treatment of obsolete pesticides from
developing countries is high temperature incineration in dedicated hazardous waste
incinerators in Europe. This is also the method proposed in this project. Only
disposal at a fully licensed, monitored disposal facility will be considered.

A further aspect to the disposal of the pesticides wastes is safe repackaging of the
obsolete stocks into a form which is suitable for transportation to the final disposal
site. Shipment of obsolete stocks to a developed country for incineration at a licensed
facility has, to-date, been the favored disposal option promoted by FAO in its
guidelines.




98
 Disposal of bulk quantities of obsolete pesticides in developing countries. Provisional technical guidelines.
UNEP, WHO, FAO. 1996.

ECOS
Environmental Impact Assessment Report                                                       Page   96 of 179



A number of similar projects have been completed in other countries, where there is
lack of cost effective local options for pesticide disposal that are environmentally
sound.

Competition between incinerator operators has resulted in a general lowering of unit
rates for incineration. This has been coupled with an increased number of companies
now offering field teams to complete operations in-country. Both of these factors
make this option increasingly attractive in terms of value for money and highest
environmental standards.

The proposed project approach also gives an immediate and final destruction of the
identified PCB-containing equipment. Most probably the major part of the problems
related to the PCB-containing power equipment in Moldova will be solved by this
operation.

If carried out correctly, the primary environmental impact of this project will be
overwhelmingly positive. The operation will remove large and widely dispersed
stockpiles of highly toxic chemicals. These chemicals currently contaminate human
and natural environments, food sources, soil, water and air. Their removal, with due
consideration for the prevention of additional contamination caused by the activities
of the operation, will eliminate many major sources of environmental contamination.
The operation will send a clear message to the authorities and the public in Moldova
that the problems related to POPs can be solved and should be solved.

5.2.1.6 Final disposal of POPs pesticides combined with local long-term
        storage of other obsolete pesticides

This option is in fact a combination of previously described alternatives and it is
based on the fact that the composition of only 777 tons out of the total amount of
obsolete pesticides is known and of this there is only a small portion of POPs
pesticides, 80 kg of heptachlor and 1600 kg of toxaphene. There is also no
acknowledgement of the amount of POP pesticides that may be among the rest of
935 tons of unidentified obsolete pesticides stored in facilities. Tentative expert
estimates suggest that Stockholm POPs may represent less than 20% of existing
stock of obsolete pesticides99. Whereas obsolete pesticides are a big concern they
may not pose the same level of concern as the POPs.

The considered alternative first presumes that a thorough identification of all
obsolete pesticides is to be undertaken. Afterwards, identified POPs could be
disposed of (e.g. by incineration) while other disposal options (e.g. long-term
storage) could be considered for the rest of the preparations.




99
     National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004.

ECOS
                Environmental Impact Assessment Report                                              Page   97 of 179



                Such a solution does not look acceptable to the EA team, due to the following
                reasons.

                The costs of better quantifying the POPs component of the pesticides, which are the
                more dangerous, might outweigh the mitigation costs. The chemical identification of
                obsolete pesticides might turn to be very costly and time-consuming. It has to be
                mentioned that part of them is still stored at the old sites while another part has been
                repackaged, transported and stored at the rayon facilities. Dealing with the latter may
                be a particularly difficult task. Reportedly, the obsolete pesticides repackaged by the
                MOD and DES are not properly separated by categories and labeled. It means that
                samples will have to be taken from every barrel and every pack inside the barrels.
                This will implicitly require opening every recipient. Besides, some of the rayon
                stores are overloaded: there is not enough space for handling the barrels inside the
                building, so they will have to be handled in the open air. This will greatly increase
                the risks of environmental dissipation and occupational risks.

                In the opinion of the EA team, the whole operation of pesticides identification will
                require several years. This will leave the pesticide stores exposed for longer time to
                natural accidents and human incidents, as mentioned above under the item 5.2.1.1. It
                means that at least for several more years the current health and environmental threat
                will persist. This is likely to stimulate the irritability of local population which at this
                moment has expectations about the evacuation of obsolete pesticides (all of them, not
                only POPs!) within a reasonable period of time. These feelings will increase if the
                identification phase will – very likely - demonstrate that most of the obsolete
                pesticides are not POPs and they, eventually, are to further be stored at the same
                premises.

                The analysis of alternatives is presented in the table below.


          Criteria             Alternative 1:    Alternative 2:   Alternative 3:   Alternative 4:    Alternative 5:
                                 Long term         Landfill in     Incineration      Chemical         Incineration
                                 storage in         Moldova         in Moldova       Treatment          Abroad
                                  Moldova
Relative Financial Costs       Low               High             High             Medium            Medium
Technical Capacity for         Sufficient        Sufficient       Insufficient     Insufficient      Sufficient
implementation in Moldova
Human Capacities               Sufficient        Insufficient     Insufficient     Insufficient      Sufficient
Time needed                    Medium            Medium           Long             Medium            Medium
Social Risks                   High              High             High             Low               Low
Environmental Risks            High              High             Medium           Medium            Low
Probability of Success         Medium            Low              Low              Low               High
Does the alternative provide   No                No               Yes              Yes               Yes
a final solution to the POPs
problem?
CONCLUSION                     Rejected          Rejected         Rejected         Rejected          Accepted


                ECOS
               Environmental Impact Assessment Report                                                       Page   98 of 179



         Criteria              Alternative 1:      Alternative 2:      Alternative 3:      Alternative 4:     Alternative 5:
                                 Long term           Landfill in        Incineration        Chemical           Incineration
                                 storage in           Moldova            in Moldova         Treatment            Abroad
                                  Moldova
The reason                     The alternative     The alternative    Lacking local       Lacking local       The method
                               does not            does not           technological       technological       provides a
                               provide a final     provide a final    capacities.         and human           final solution
                               solution to the     solution to the    Investments         capacities.         to the POPs
                               POPs problem.       POPs problem.      needed are          Investments         problem at
                               Very high           Very high          comparable          needed are          reasonable
                               social and high     social and high    with alterna-       comparable          cost, with low-
                               environmental       environmental      tives of lower      with alterna-       to-medium
                               risks               risks              environmental       tives of lower      environmental
                                                                      and social          environmental       and low social
                                                                      risks               and social          risks.
                                                                                          risks




               5.2.2 Siting of facilities

               Siting of warehouses for storage of obsolete pesticides is important safeguard
               principle, which may minimize health and environmental impacts at the great extent.
               For the project implementation is crucial to know exact locations, warehouses
               technical conditions, amount of pesticides stored, storing conditions and probability
               of impacts to the sensitive environment and end-points.

               The selection of central raional warehouses has been triggered by the Government
               and partly implemented, resulting in obsolete pesticides centralization in 23 rayons.
               In 4 rayons there is no formal decision taken, but it should be done soon100.

               5.2.3 Transportation routes within Moldova

               At the time being there is no specific information on transportation pathways of
               POPs pesticides from the rayon warehouses to the border of the country. It will
               mainly depend on the final project design or, later, on proposals from international
               contractors. Whatever way will be selected, applicable Moldovan legislation as well
               as international standards, procedures and regulations, and Occupational Health,
               Safety and Environment (OHSE) standards, due diligence and best practices, with
               technology transfer from international contractors will have to be applied. All
               contracts will include OHSE stipulations in accordance with Moldovan, international
               and host country laws.




               100
                  It is to be mentioned that the EA team had no formal mandate to influence the siting of warehouses. The input
               of EA team was to contribute to the risk assessment and identifying of the most risky/critical warehouses and to
               brief the PIU on the results of field assessment.

               ECOS
Environmental Impact Assessment Report                                  Page   99 of 179



There are two transportation options within Moldova (up to the national border): by
road or railway, and, further, by the same transport (or by navy cargo, loaded in
neighbor country, if it is a case) to the destination place. The EA study looked into
the road and rail-road routes to Western Europe and assessed technical capabilities to
transport POPs. The most safe and direct routes will be selected after host country
will be identified.

The EA study proposes to consider two major project configurations related to the
transportation of POPs pesticides: (i) to evacuate pesticide stocks from each rayon
warehouse separately, directly to the final destination (can be implemented by road
transport), or (ii) to concentrate (phased-up) pesticides stocks at one appropriate site
for relatively short time and afterwards to transport them out of the country (by
railway or road transport).

The EA proposes the following approach, which is considered more environmentally
safe:

    1. To select one site meeting the technical and environmental criteria for
       implementation of pesticides identification, re-packaging, short-term storage
       of pesticides and containers, transport maneuvering spaces and loading
       facilities.

    2. To renovate and improve this intermediate platform according to the
       safeguard requirements.

    3. To transport to this platform the stocks of POPs pesticides already packed in
       plastic barrels, starting from the rayon storage facilities posing the greatest
       risks for human health and environmental contamination.

    4. To take on-site samples for identification of unknown pesticides and to
       repack them if necessary.

    5. Finally, to load the principal transport units (vehicle or railway) for
       transportation outside the country.

This approach may reduce the impacts generated by moving and disturbing the
barrels for inventory and re-packaging at each of the 37 central storage facilities in
Moldova, considering that some of them are not environmentally safely sited.

Railway transportation should also consider the needs for train wheels changing at
the border station, as Moldovan railways have different distance between lines as in
other European countries.




ECOS
Environmental Impact Assessment Report                                                    Page   100 of 179



On the other side, a total amount of 1,100 tons PCB-containing capacitors and highly
polluted soil will be exported for destruction outside Moldova. The transport of
capacitors should be in accordance with the stipulations of:
 ●    Moldovan regulations covering the transport of dangerous goods by rail or
      road101,102;
 ●    International transport rules: The European Agreements on the International
      Carriage of Dangerous Goods by Road (ADR) and Rail (RID) and the
      International Maritime Dangerous Goods Code (IMDG);
 ●    The EU waste shipment rules set out in EU Waste Shipment Regulation (Council
      Regulation (EEC) No 259/93).

The requirements relating to transboundary shipments of PCB and PCB-containing
equipment shall be followed.

Talking about the choice to be made between road or rail options for transportation
of POPs wastes some arguments to ease the decision making are pointed out below:

The principle the team applied is to the maximum extent avoid to expose new sites
(e.g. railway station) to pollution risks. At the same time we estimate that more then
760 transportations by car should be undertaken to export all the POPs. It is obvious
that statistically trucks transportation (vs. railway transportation) is more risky for
environment. This concern, however, will burden mainly all the European transit
countries the carriers will have to pass through on their way to destruction facility
since within Moldova the trucks will have to undertake the same 760 transportations
in both cases (no matter toward railway station or directly to the national border
pass).

Thus, we are weighting the two options’ environmental risks as being similar which
needs the same mitigation measures described further in the EMP chapter.

In conclusion: the team recommend that the decision is taken by project management
and the contracted company based on the managerial criteria (cost-efficient solutions,
the level of customs clearance burden, etc.).

5.2.4 Methods of collection, packaging and storage

The activities related to identification, repackaging, temporary storage, and
transportation, and clean-up of POPs pesticides and PCBs will be conducted in




101
    Government Decision No. 672 of 28.05.2002 on the transport of dangerous goods on the territory of the
Republic of Moldova.
102
    Government Decision No. 637 of 27.05.2003 on the control of transboundary movements of wastes and their
disposal.

ECOS
Environmental Impact Assessment Report                               Page   101 of 179



accordance with Moldovan legislation and standards, international requirements and
best practice, as well as Occupational Health, Safety and Environment standards and
due diligence.

The EA study proposes the following approach to be considered, as most
appropriated from the environmental point of view:

    1. To finalize centralization of obsolete pesticides at the rayon warehouses but
       under improved process management, better pesticide handling and in
       accordance with safeguard principles.

    2. To start phased evacuation of obsolete pesticides from the most risky rayon
       warehouses.

    3. To make sampling, repackaging and inventory at the designated intermediate
       platform (as described above).

    4. To improve guarding of all rayon warehouses.




ECOS
Environmental Impact Assessment Report                                 Page   102 of 179




6 Environmental Impacts
6.1    The Current Threat (Without project alternative)

It is well known that pesticides are able, by virtue of their various physical and
chemical properties to enter all environmental compartments and affect human,
animal and plant organisms through various pathways. At present the health of local
people and the quality of their environment is severely compromised by the presence
of obsolete pesticides, including POPs and unidentified stocks, and by conditions of
their storage in about 340 deposits over the country. It is also important to note that
over 1000 pesticide warehouses and a similar number of grounds for preparation of
pesticide solutions had been in use in Moldova in the past. It can be estimated that a
few thousand areas, which are potentially polluted and pose health and
environmental risks, may be found in Moldova. The level of their contamination
needs a thorough detailed investigation coupled with pertinent analysis, for which the
country has no financial capabilities.

Currently, an estimated 2500 tons of obsolete pesticides, from which about 60% non-
identified are distributed in 340 storage sites around the country. These stocks have
been accumulated over the past years for a combination of reasons including lack of
co-ordination in procurement, poor storage conditions and stock management, and
oversupply of products. Neglecting of safety rules and mismanagement during last
decade leaded to non-appropriate storage conditions. Significant amount of obsolete
pesticides is stored in the open, deposit facilities are deteriorated and physically
damaged, contain leaking drums and burst sacks. Many of the pesticides have leaked
or are leaking from their containers. Liquid and dissolved by penetrated rainfalls
pesticides have soaked into unprotected soil at many sites. Elsewhere liquids have
seeped through store foundations. Paper and plastic packs containing powder
formulations have burst to release their contents. These have been dispersed by air
movements, exposure to flowing water or precipitation and by the movement of
people and animals through contaminated sites. Some stores are sited in areas with
high water table and others in river floodplains. Pesticides released are therefore
constantly entering the aquatic environment and sources of drinking and irrigation
water.

The problem of obsolete stocks in Moldova is particularly serious as a significant
number from the remaining warehouses are located closely to residential areas
(mainly rural ones) or/and nearby pastures, arable land and orchards/vineyards. Some
of the stores are located within areas, which are regularly passed or visited by
unprotected people. The result is that children, women, men and livestock are


ECOS
Environmental Impact Assessment Report                                 Page   103 of 179



exposed to pesticide vapors, dust and contaminated soil, water and other materials on
a virtually constant basis.

It is also important to recognize that contamination of agro-products has potential
impacts on the urban population’s health, as many products are sold in local markets
which have no rigorous pesticides residuals control. The economic losses, driven by
contamination of agriculture and food products, can significantly limit Moldova
opportunities on the external markets.

It should also be stressed that no reliable risk assessment, mapping and inventory of
potentially contaminated sites and pesticides stores have been conducted in Moldova.

Since 1995, the total amount of recorded pesticides decreased by 600 tons. There is
no clear reason available for this situation. It was assumed that some of stored
pesticides were washed out with the runoff or infiltrated into the groundwater,
leading to soil and water contamination, or were stolen. On the other side, the
centralisation of obsolete pesticides at the rayon warehouses implemented by the
MOD/DES showed that the amount of evacuated waste is significantly higher than it
was reported before (sometimes twice as much as reported). It can be partly
explained that floor dust, packaging remaining, empty drums are currently registered
as pesticide wastes and are transported to the central rayon stores together with the
obsolete pesticides per se.

Among selected rayon warehouses for temporary storage of obsolete pesticides only
few are located in relatively safeguarded surroundings. 29% of the storage facilities
are situated close to residential areas, 90% nearby agriculture fields and/or pastures,
and 44% not far from natural water streams and their floodplains. The conditions of
storage are not totally adequate, violations of storage rules and safety standards are
visible, guarding is insufficient, perimeter fences and precaution/safety/alarming
labels are missing at many locations, their territory is crossed by livestock and
people.

Few stores have undamaged solid floors and only a very small number have any
spillage containment measures build in, which are significantly deteriorated in many
places. Most stores were not equipped with water and power. The soil under and
around many of the stores, as well as the walls, are contaminated to varying degrees
and strong chemical smells emanate from most stores indicating high levels of
contamination.

In general, the packaging materials for obsolete pesticides were found to be in poor
condition and hardly suitable for transportation. Already implemented repackaging in
a few rayons was done for solid pesticides by use of non-UN approved plastic drums,
which are new and relatively safe, but sensitive to physical crack damage and fragile
if frozen. The liquid wastes have been filled into non-UN approved used metal and
slightly corroded drums, but not at all deposits yet. At a few central warehouses the
solid pesticide waste has been transported without proper packaging in drums (only
placed in ordinary plastic bags, which is prohibited by national requirements). The

ECOS
Environmental Impact Assessment Report                                 Page   104 of 179



old and empty metal drums, which are heavily corroded and contain pesticide
remains, have been transported to the central rayon deposits occasionally. Some of
them were left at the original places or were dumped in ravines, earth holes, or just
on the territory. The labels are generally missing. The composition of unidentified
formulations has not been studied. The issue of ownership of obsolete stocks and
responsibility for their storage still needs to be clarified.

The picture would not be complete without description of the fate of emptied
deposits. In many places the local population demolished the old warehouses. The
disassembled construction materials were used for building livestock stables or for
other household needs. Contaminated bricks, limestone blocks, wood, gravel and
other construction residuals are now moved into village limits and stored near living
houses, livestock and drinking wells. The continuation of this process in more than
300 sites all over Moldova, left after the completion of centralisation of obsolete
pesticides stocks, is likely to generate significant health and environmental risks by
spreading out contaminated materials.

In conclusion, it may be stated again, that if no or limited action is taken for
improving the obsolete pesticides management, the severity of impacts, originated
from improper storing and mismanagement of obsolete pesticides stock to the
national environment and human health, would increase, even considering self-
degradation and life-time of obsolete pesticides formulations. It is obviously not the
case for POPs pesticides, as they are persistent, bio-accumulative and remaining in
the environment and in organisms for a long time. It would not be an exaggeration to
affirm that poverty alleviation, the human right to leave in a healthy environment,
economic development and sustainability, country external market options and
country international image would be affected by failure to dispose of obsolete/POPs
pesticides in an environmentally safe manner.

A number of broad environmental, social and economic issues as well as their cause
and effects have been identified during the study and the stakeholder/public
consultations. The diagram below (Figure 2) indicates the identified important
environmental components, their causes and effects as well as assessment of severity
of impacts.




ECOS
POLLUTION SOURCE AFFECTED ENVIRONMENT PROCESS AND FACTORS   CONTAMINATION/POLLUTION PATTERN   BIOPHYSICAL, SOCIAL AND ECONOMIC IMPACTS    IMPACT EVALUATION



                                                                     Working space



                    Atmosphere         Vaporization &                Living, residential          Losses of value      Economic
                                       wind dispersion               areas                        (wood, herbs,        losses
                                                                                                  mushrooms)

                                                                     Forests and
                                                                     terrestrial habitats

                                       Run-off and top
                                       soil erosion                  Productive, fertile
                                                                     soils                        Accumulation /
                    Soil                                                                          toxicity wild        Biological
                                                                                                  fauna, flora         diversity losses
                                       Infiltration                                                                                          SIGNIFICANT
                                                                     Agricultural crops
                                                                                                                                             LONG-TERM
                                                                                                                                             COUNTRY WIDE
POOR POPs                                                                                                                                    SEVERE
STOCKS
                                                                                                                                             HARDLY
MANAGEMEN                                                            Pastures                                                                 REVERSIBLE
T
                    Surface
                    water
                                                                     Natural streams and          Losses of value
                                                                     wetlands                     (crops, milk,        Human health
                                                                                                  meat, fish           losses
                                       Leakage                                                    products)
                                                                     Reservoirs for
                                                                     irrigation
                                                                     pisciculture
                                                                     recreation
                                       Base flow
                    Ground

                    water                                            Water supply
                                                                     sources
Environmental Impact Assessment Report                                  Page 106   of 179
Draft Version – Do not quote




Concerning the PCB issue, Moldova has accumulated a large number of PCB-
containing capacitors, especially in the power sector. According to the NIP, almost
20,000 power capacitors are located in 20 electrical substations throughout the
country. Of these, 12,000 capacitors are kept in one assembly at the Vulcanesti
substation. Additionally, two dumps with approximately 1000 broken capacitors each
are located at the same substation. The total PCB-content in all capacitors (excluding
the pits at Vulcanesti) is estimated at 380 tons.

In most of the substations the capacitors have not been in operation since the collapse
of the Soviet Union around 1990. The PCB-containing capacitors in the electrical
substations are in a condition where leakages due to corrosion take place and the
leakages are deemed to increase in the coming years. As most of them are not in use,
leakages may continue for long time before they are discovered. In Vulcanesti, for
example, the ground below the capacitor assembly has been highly contaminated by
the explosions of capacitors in the 1970s and releases from corroded capacitors
during the last 33 years. Further the soil and groundwater around the two pits with
about 1000 broken exploded capacitors each may be highly contaminated.

The PCB-containing capacitors are a major environmental threat to the groundwater
resources and human health in the region, in particular the occupational health. At
most substations, the personnel are complaining about health problems which are
associated with the presence of capacitors. Either real or mostly imaginary, these
concerns indicate a perceptional pressure for something to be done. Besides, in some
places rural households are located within 10 m from the capacitor batteries
(culminating with the playing ground for children at 3-4 m from capacitors at the
Orhei substation), which creates a real menace for people’s health.

If no or limited action is taken and, consequently, the PCBs are left at the sites
undisturbed the threat to human health and the environment - both in Moldova and
globally - posed by site leaking, is going to increase. If left unaddressed, the situation
could only be worsening. In addition, under such circumstances it looks hardly
possible that the obligations taken by Moldova under the Stockholm Convention, i.e.
identifying and ensuring environmentally sound management of both spent PCB
equipment and PCB still in use, can be met.

6.2    Project Benefits

At present the health of local people and the quality of their environment is severely
compromised by the presence of these chemicals and the conditions of their storage.
Environmental improvement is the primary concern of this project but additional
benefits will be yielded including:
●     National capacity building in handling and management of hazardous waste
      including legal and institutional arrangements, raising laboratory analysis and
      information management capacity, providing know-how, and training



ECOS
          Environmental Impact Assessment Report                                         Page 107   of 179
          Draft Version – Do not quote



           ●   Poverty reduction and economic growth, especially in rural areas, through
               creating more opportunities for producing clean/organic agriculture products

          Providing that the project is successful, with project objectives being met, the local,
          regional, national and international benefits can be substantial. The expected benefits
          are described in table below for each of the project components.

          Table 2: Project Benefits
                                                   Project Benefits
Project Component
                                                   (environmental, health, socio-economic)
                                                   -   Overall reduction of the environmental,
I. Environmentally sound disposal of POPs              health, and socio-economic risks associated
stockpiles                                             with POPs dissipation in the environment (at
                                                       both global and regional/local level);
                                                   -   Assisting Moldova in meeting its obligations
                                                       under the Stockholm Convention;


                                                   -   Eliminating the health and environmental
A. POPs obsolete pesticides                            risks of further releases of POPs from
subcomponent:                                          temporary unsafe storage sites;
- Immediate repackaging and                        -   Raising opportunities for organic agriculture
   centralization;                                     thus increasing the income levels of small
- Inventory and risk assessment;                       farmers and the rural poor;
- Repackaging for transportation and               -   Improving the export potential of agriculture
   final disposal;                                     products;
- Pilot remediation activities.                    -   Increasing the land value in the proximity of
                                                       emptied warehouses;
                                                   -   Reduction of poverty in rural areas;

                                                   -   Environmentally sound and immediate
B. PCBs subcomponent:                                  destruction of the bulk of identified PCB-
- PCBs detailed inventory;                             containing equipment in Moldova, under
- PCBs disposal;                                       controlled conditions;
- Feasibility study of remediation                 -   Demonstration project for the management
    measures at the Vulcanesti electric                of PCB-containing equipment identified
    substation.                                        during the detailed inventory;
                                                   -   Gaining exact data on the extent of the PCBs
                                                       problem in Moldova (including non-energy
                                                       sector) providing for development of a future
                                                       management plan;
                                                   -   Reduction of occupational health risks
                                                       through inventory and labelling of all PCB-
                                                       containing equipment;
                                                   -   Knowledge transfer on POPs-contaminated
                                                       sites remediation and using the Vulcanesti
                                                       cleanup program for remediation of sites
                                                       heavily polluted with other hazardous
                                                       substances.



          ECOS
          Environmental Impact Assessment Report                                         Page 108   of 179
          Draft Version – Do not quote



                                                   Project Benefits
Project Component
                                                   (environmental, health, socio-economic)



                                                   -   Enhanced institutional capacity to manage
II. Sustainable POPs management:                       POPs in an environmentally sound manner,
- Strengthening POPs institutional                     including: (i) new policy and regulations of
     capacity;                                         PCBs management; (ii) improved capacity to
- Inventory, monitoring and enforcement                monitor POPs; (iii) better enforcement of
     activities;                                       POPs-related environmental regulations; (iv)
- Training and capacity building for                   development of human capital through
     POPs handling.                                    training and experience.
                                                   -   Raising public awareness on POPs risks for
III. POPs public awareness and replication             human health and the environment;
activities                                         -   Potential benefits in terms of avoiding
                                                       exposure and prevention of future use and
                                                       accumulation of POPs (esp. in households)
                                                   -   This can provide indirect benefits by
IV. Project management                                 coordinating/managing all the project
                                                       activities

          6.3       Project Impacts

          6.3.1 Generic nature of impacts

          The project consists of 4 distinct components which could have either direct or
          indirect impacts on various aspects of environment. In following, each
          component/sub-component is addressed in terms why and how the environment can
          be affected.

          POPs obsolete pesticides sub-component

          This sub-component will finance quantification, identification and packaging of the
          pesticides in UN approved containers which will then render the materials safe for
          transportation and destruction. The following activities will be conducted:

          (i) Immediate repackaging and centralization of obsolete pesticides.

          This activity will have a variety of direct environmental impacts if no adequate
          preparation and mitigation measures are applied.

          Implementation is normally required of carefully designed and enforced preliminary
          actions such as: (i) preparation of evacuation and emergency plans as the first step in
          repackaging and transportation of obsolete pesticides and associated wastes,
          including identification of priority sites at the rayon level, setting up the time-table,
          defining of labeling and storing systems and registers, nomination of responsible
          agencies and supervisors, selection of transportation routes, and familiarization of
          involved partners and general public; (ii) repair of selected rayon warehouses in
          order to prevent pesticide movement out of the facilities by means of dust,

          ECOS
         Environmental Impact Assessment Report                                                 Page 109   of 179
         Draft Version – Do not quote



         infiltration, washing-out; (iii) establishing of warehouses protection system against
         non-authorized access, warning labeling, guarding. This preparation stage should be
         urgently improved using the experience of the demonstration activities supported by
         Milieukontakt, a Dutch NGO, which initiated a project aiming to implement the best
         practices for obsolete pesticides handling in one rayon.

         The physical actions include the following: (i) circulation of military trucks around
         pesticides storage facilities; (ii) hosting 10-15 solders and officers for 2-5 days at
         each storage facility, in field camps or in the village; (iii) using available space at the
         facilities for temporary storage of empty drums and packages. All these activities are
         not generating significant negative impacts to the environment and rural livelihoods
         as they are compatible with the normal activities in rural areas.

         Practical implementation of repackaging procedures, collection of pesticide-
         associated wastes and floor dust, keeping of packed pesticides and contaminated
         wastes on the territory of evacuated stores for a while, loading the trucks and
         transportation to the central warehouse as well as re-loading and placing of pesticide
         barrels/packs at the central warehouse are more concerning issues.

         Disturbance of existing chemical stores and the movement of chemicals may expose
         those working at the sites to severe hazards and may cause additional environmental
         dispersion of hazardous products. This could result in exposure of people working
         nearby and other local inhabitants, and the environment at large. Many Moldovan
         pesticide stores are located closely to the residential, agriculture and water
         environments.

         The following table lists the environmental hazards posed by the current situation
         and indicates which of these factors could be compounded as a result of the activities
         of this project:

         Table 3. Potential for compounding environmental impact from the movement of
         stored pesticides103

Current environmental hazard                           Potential compounding effects of the project

Leakage of pesticides to soil and dispersal Movement and transfer of pesticides from one
in soil through capillary action and soil container to another could generate additional
microfauna                                  leakage and increase the area contaminated.

Leaching of pesticides to groundwater                  Disturbance of pesticides and their movement




         103
           Prevention and Disposal of Obsolete Pesticides Stocks in Ethiopia, Programmatic Environmental Assessment,
         2004.


         ECOS
          Environmental Impact Assessment Report                                    Page 110   of 179
          Draft Version – Do not quote




Current environmental hazard                       Potential compounding effects of the project
through contaminated soil                          could increase the area contaminated and cause
                                                   additional leaching to groundwater sources
                                                   beneath the contaminated area. Exposure of
                                                   pesticides during periods of rainfall could
                                                   increase groundwater contamination.

Surface water contamination by surface             Disturbance of pesticides could cause additional
runoff, wind dispersal or animal transport.        pesticides to enter surface water through surface
In several cases stores sit on floodplains         runoff or air movement. Exposure of pesticides
which periodically cause additional surface        during periods of rainfall could increase surface
water contamination.                               water contamination.

Dispersal of pesticides by air through             Additional exposure of pesticides to air during
volatilisation and wind dispersal.                 repackaging processes could lead to increases in
                                                   volatilisation and wind dispersal. Exposure of
                                                   pesticides during periods of intense solar
                                                   radiation, high temperatures or high winds
                                                   could increase contamination.

Contamination of vegetation through uptake         Increased release of pesticides to air, water and
of pesticides in soil and surface                  soil during its movement could result in
contamination of plants. Contaminated              additional exposure of vegetation to pesticides
vegetation may be crop plants, food sources        and hence additional contamination.
for people, livestock or wildlife, or other
vegetation forming part of the natural
environment.

Direct or indirect toxic effects on the human      Additional releases of pesticides to the
population, livestock and wildlife resulting       environment could result from their disturbance
from exposure to pesticides which have             and movement thereby increasing the potential
been released into the environment.                for organisms to be exposed to pesticides.
Pesticides can also enter the food chain and
contaminate several organisms. The toxic
effects of exposure could be short term and
acute, or long term and chronic.

          These possible releases may have negative impacts, which are local, provisory and
          relatively comparable to the current pollution of areas around existing warehouses.

          Transportation losses, accidents and failures during centralization phase may
          potentially release a relatively large amount of toxic, dangerous and persistent
          chemicals at new places and for new environmental components. Mismanagement or
          weak control and enforcement may significantly contribute to the pollution of natural
          or economic environments and humans beings, associated with settlements, located
          around selected central stores. Improper placing of drums within facilities and

          ECOS
Environmental Impact Assessment Report                                Page 111   of 179
Draft Version – Do not quote



overloading may lead to further project operational troubles, as it may be required to
move the stored drums for planned inventory, sampling and classification.

(ii) Inventory and risk assessment.

Generally, such activities as inventories and risk assessments have no direct negative
impacts; conversely, they can indirectly benefit the environment and human being by
means of better knowledge and planning. However, the inventory required under
current conditions of packaging and centralization, may have direct impacts on the
environment and human health at about 37 sites where centralization will take place.

A significant portion (up to 60%) of obsolete pesticides that have already been / are
to be repackaged and stored at the centralized rayon warehouses, are still
unidentified. Careful determination of unknown chemicals and pesticide stock
labeling will be necessary, which is crucial for international transportation. The
inventory of category and quantity of pesticide stocks to be further placed in UN-
approved package material as well as identification of unknown compounds will
require: (i) resorting, reloading and moving of barrels inside the warehouse, (ii) for
overloaded stores - even moving to the open space, (iii) opening of a significant
portion of barrels/drums with unidentified pesticides, evacuation of bags out of
barrels and opening the bags for sampling, (iv) placing labeled barrels again within
warehouse, but in better order suitable for further loading on trucks. All these
movements may generate additional unwanted releases of pesticides to the air,
spilling or dispersion on the soil, similar to those presented in the table above. The
impacts may be local, but significant for working personal if spillage would involve
POPs or toxic chemicals.

The risk assessment and creation of national register of storage sites selected or
already used for centralization, as well as for other old stores over the country, have
no direct negative impacts, but can be positive by means of storage sites ranking,
identification of priority sites and formulation of site-specific mitigation measures
and evacuation plans. The developed and tested methodology, scoring system and
results of EA study may serve as a starting point in developing a toxic risk
assessment approach that can be further upgraded using the international experience.
The EA team has already trained staff, which may undertake further risk assessments
over the country.

(iii)   Repackaging for transportation and final disposal.

Potential impacts of this activity on the environment are direct. Repackaging of all
liquid and solid obsolete pesticides, as well as associated wastes, including empty
corroded metal drums, and heavily contaminated soils in UN-approved bags or tanks
may lead to additional pollution of sites.

Potential impacts from handling and repackaging of solid obsolete pesticides will be
local and less significant in comparison with inventory impacts, as all obsolete
pesticides would already be placed in protection barrels, labeled, placed in good

ECOS
Environmental Impact Assessment Report                                 Page 112   of 179
Draft Version – Do not quote



order and would not require any more opening. Only loading failure should be a
matter of concern.

Negative impacts related to the liquid pesticides pumping into UN-approved
containers may be more significant, as the operation could lead to leaks,
volatilisation and wind dispersal. The same negative aspects are related to packaging
of contaminated soils, floor dust, and other associated wastes at 37 central
warehouses after evacuation of pesticide stock out of deposit. The air pollution with
contaminated dust can be significant and can affect relatively large areas around.

Metal drums that will be emptied during repackaging and old heavily corroded
drums, collected at the central deposits, will contain pesticide residuals and will have
to be crushed by means of a drum crusher. This operation may affect local
surroundings, livestock and population by vibration and noise. These kinds of
impacts are local and minor in comparison with possible leakage of pesticides liquid
fractions remaining in old and recently emptied drums. If no mitigation measures
will be applied this operation could induce heavy contamination of soils at the place
where a drum crusher machine would be installed.

The transportation of pesticides by railway or road is a potential generator of
negative impacts by accident. The road carriage is statistically more dangerous in this
sense. The roads in Moldova are generally not in a good repair since their
maintenance is poor. Correlated with the specific Moldovan relief (many climbs and
slopes), this increases the risks of obsolete pesticides transportation by road,
especially in winter time. On the other side, the road traffic in Moldova is not very
intense, which is decreasing the risk of accidents. The main road to the Western
border of the country is crossing only a few settlements and thus the risk of a direct
impact on the population is small. In the same time, this transport way is crossing, on
a distance of 10-15 km, a state protected scientific reserve and a transport failure
could affect a naturally valuable virgin forest area. The contamination of this area
could result in important losses of natural values.

PCBs sub-component

This sub-component will support the following activities:

(i)     PCBs detailed inventory.

Only local and insignificant direct impacts are foreseen during inventory, which
require identification of oil contamination by PCBs in all transformers and other
electrical equipment at the electrical sub-stations. Unintentionally released small
amounts of oils at the sampling points may contaminate the ground, but can easily be
mitigated. Direct moderate impacts may appear if sampling and other inventory
actions will require stops in the normal operation of transformers and other electrical
equipment. This may affect a wide range of consumers if prevention/mitigation plan
will not be developed and carefully implemented.


ECOS
Environmental Impact Assessment Report                                 Page 113   of 179
Draft Version – Do not quote



The project may also involve testing of PCBs content in electrical equipment in use
by large electricity consumers (water supply, transport, industrial enterprises), which
are unknown for the time being. The equipment to be tested may be situated in
sensitive areas (close to food and drinking water production sites, etc.) that would
require careful prevention/mitigation both for leakage and possible operational
disturbance of enterprises.

But in general, this sub-component will have significant beneficial impacts as it will
provide for the first time a clear picture of PCBs contamination of oils and
equipment over the country, in particular, in priority areas linked with the
stipulations of the Stockholm Convention. All anticipated activities, such as
development of related regulations, labeling system, involving of equipment holders
in the process and increasing their environmental responsibility, know-how transfer
and management guides, training and awareness raising, establishing of safety
requirements and their enforcement, reporting and register would increase overall
country chemical safety.

(ii)    PCBs disposal.

The sub-component may have direct environmental impacts as handling of about
17,300 contaminated capacitors is required. Besides, it includes the excavation of
some 2,000 broken capacitors placed in earth pits on the station territory and an
estimated amount of 50 tons of highly contaminated soils, temporary storage of
polluted soils and keeping of UN-approved packaging containers stock, as well as
their transportation. It is important to note that all works, excluding shipment, are to
be implemented on industrial sites (electrical substations) which reduce the
significance of possible negative impacts, but some of them (minor ones) will
involve more sensitive locations and end-points (e.g. population, food industry and
agriculture) and thus require more attention.

The activities planned may affect the operation of some substations as a small part of
the capacitors is periodically used by the state owned company Moldelectrica. The
agreed replacing plan would help Moldelectrica to switch from PCB-contaminated
capacitors to PCB-free ones and would show the commitment of the country to
comply with Stockholm Convention requirements.

Dismantling of capacitors may affect the occupational safety of workers as they may
have direct contact with leaking equipment and lead to further pollution of soil
around the work places, but precaution measures can be easily applied to minimise
effects.

Heavy machinery and trucks, forklift, scaffolding, lowering mechanisms and
excavation equipment may generate some minor impacts (emissions, noise and
vibration), comparable to the normal situation.

Possible establishment of buffer storage at the Vulcanesti site where the IBC
containers can be temporarily placed will require paving of about 200 m2 and

ECOS
Environmental Impact Assessment Report                                Page 114    of 179
Draft Version – Do not quote



providing a bund wall and a sump. The impact is comparable with similar
construction works and can not be significant.

Excavation of PCB capacitors in Vulcanesti and associated works with contaminated
soil, handling of damaged capacitors, construction of temporary storage facilities,
decontamination of excavation mechanisms will require special attention, as they
may lead to negative effects on environment and health of workers. Excavation may
be required for two pits at a depth up to 5-7 m and on the area of approximately 5 x 5
m and 25 x 15 m in order to remove at least 2 000 burned capacitors. The volume of
contaminated soils may be higher as estimated. The building of lined site of 10 x 20
m with a 1.2 m high cofferdam by each pit and probably balustrades for temporary
storage of polluted soils will be required. The most polluted soils layers can be found
at the bottom of the pit, but after removing it may be placed at the top. The soil
dispersion by winds and leaking of drained soil porosity water may contribute to the
pollution of vicinity areas. The polluted leaking or rainfall water from pits bottom
may further contaminate groundwater locally. It should be stressed that area of
Vulcanesti power station is not regularly visited by people, but agriculture and
sheep/cow grazing has been reported. The impacts can be local, but significant
considering wider spreading of PCBs at high concentration.

Transportation itself is not expected to generate significant environmental impacts as
it is comparable with normal traffic around the Vulcanesti sites and other sub-
stations.

(iii)   Feasibility study of remediation measures at the Vulcanesti substation.

Impacts of this component are indirect and positive. All anticipated activities will
contribute to identification of environmentally safer and cost-effective measures to
prevent further dissipation of PCBs from the contaminated site to the surroundings
and may serve as a model for other substations and other contaminated sites.

Sustainable POPs Management component

Three groups of activities as (i) strengthening POPs institutional capacity, (ii)
inventory, monitoring and enforcement activities and (iii) training and capacity
building for POPs handling would not have direct impacts, but indirectly they would
benefits overall country capacity to handle toxic and dangerous chemicals in an
environmentally safe manner and in accordance with country’s international
obligations.

POPs public awareness and replication activities component

This component is indirectly beneficial to the environment and to the human
perception on POPs over the country and would provide substantial basis for
participation, maintaining of database of comprehensive, accurate and regularly
updated aggregated information quantifying POPs, as well as replication of project
results across the region.

ECOS
            Environmental Impact Assessment Report                                           Page 115   of 179
            Draft Version – Do not quote



            Project Management component

            This component would not have direct impacts as it will deal with financing,
            operating, audit services, project monitoring and evaluation.

            6.3.2 Specific project direct negative impacts per components

            (A1) Immediate repackaging and centralization of obsolete pesticides.



      Impacts                Causes            Effects/Consequen        Evaluation of           Mitigation
                                                       ces             potential severity
Disturbance of         ● Reparation works;    ● Disturbance of        Non significant and   Not specially
nearest environment    ● Engineering          wild fauna during       comparable with       required, follows
during central         machinery              reproduction and
                                                                      impacts after usual   normal operation
warehouse              operation;             other sensitive
                                                                      activities            procedures
reparation and         ● Traffic of heavy     periods;
heavy machines         military machines in   ● Noise, vibration;     Local (37 places)
traffic during         wet conditions         ● Slight disturbance    Short-term
transportation                                of local population
                                              usual activities in     Easy reversible
                                              areas adjacent to
                                              pesticide stores
                                              (land cultivation,
                                              harvesting, grazing);
                                              ● Damaging the
                                              local roads and
                                              increased costs for
                                              road maintenance
Pollution of nearest   ● Spillage of fuels    ● Soil and water        Moderate              Required for
environment during     and lubricants from    quality                                       prevention of
                       construction           deterioration;          Local (37 places)
central warehouses                                                                          contaminated dust
                       machinery;             ● Crops and             Short-term
reparation                                                                                  movement,
                       ● Contaminated         livestock               Medium reversible
                       dusts dispersion       contamination                                 occupational safety,
                                                                                            and limitation of
                                                                                            human and livestock
                                                                                            access
Pollution of           ● Leakage and          ● Increased             Significant           Required for
surroundings during    spills during re-      contaminated area;                            minimisation of
                       packaging;             ● Occupational          Countrywide (340
evacuation,                                                           places)               pollutants
                       ● Volatilisation and   exposure;
loading/reloading,                                                                          dispersion
                       wind dispersion;       ● Health losses of      Long-term
transportation         ● Failures during      local population;
                                                                      Hardly reversible
                       loading/reloading      ● Loss of
                       operations;            biodiversity;
                       ● Traffic of           ● Soil and water
                       contaminated           quality
                       vehicles               deterioration;
                                              ● Health impacts
                                              following handling
                                              and consumption of
                                              contaminated
                                              agriculture products




            ECOS
            Environmental Impact Assessment Report                                               Page 116   of 179
            Draft Version – Do not quote



            (A2) Inventory and risk assessment.



      Impacts                 Causes             Effects/Consequen          Evaluation              Mitigation
                                                         ces
Pollution of            ● Small leakage and     ● Increased             Moderate, but at        Required for
surroundings during     spills during           contaminated area       some sites where        reduction of
resorting, reloading,   operation               ● Occupational
                                                                        space inside            contamination
opening, sampling       ● Volatilisation and    exposure
                                                                        warehouse is limited    during operation
                        wind dispersion         ● Health losses of
                        ● Failures during       local population        and all procedures      and occupational
                        resorting/loading/rel   ● Loss of               should be               safety
                        oading operations       biodiversity            implemented
                                                ● Soil and Water        outside of the
                                                quality deterioration   storage facility, can
                                                ● Health impacts        be significant
                                                following handling
                                                                        Local (37 places)
                                                and consumption of
                                                contaminated            Long-term
                                                agriculture products    Hardly reversible

            (A3). Repackaging for transportation and final disposal.



      Impacts                 Causes             Effects/Consequen          Evaluation              Mitigation
                                                         ces
Pollution of            ● Insignificant         ● Increased             Moderate                Required for
surroundings during     leakages and spills     contaminated area;                              reduction of
                        during re-packaging     ● Occupational          Local (37 places)
re-packaging,                                                                                   contamination
                        to UN-approved          exposure;               Long-term
loading/reloading,                                                                              during operation
                        containers;             ● Health losses of      Hardly reversible
transportation          ● Volatilisation and    local population;                               and occupational
                        wind dispersion;        ● Loss of                                       safety
                        ● Spreading of          biodiversity;
                        contaminated dusts;     ● Soil and water
                        ● Failures during       quality
                        loading/reloading       deterioration;
                        operations;             ● Health impacts
                        ● Traffic of            following handling
                        contaminated            and consumption of
                        vehicles;               contaminated
                        ● Leakage during        agriculture products
                        drums crushing
Disturbance of          ● Drums’ crusher        ● Disturbance for                               Not required,
environment during      operation;              wild fauna;             Moderate                follows normal
                        ● Lifting equipment     ● Noise, vibration;
operation                                                                                       operation
                        operation;              ● Disturbance of        Local (37 places)       procedures
                        ● Traffic of heavy      local population
                        vehicles;               normal activities;      Short-term
                        ● Spillage of fuels     ● Increased costs
                        and lubricants          for road
                                                                        Easy reversible
                                                maintenance;
                                                ● Pollution of soil




            ECOS
            Environmental Impact Assessment Report                                           Page 117    of 179
            Draft Version – Do not quote



            (B1) PCBs detailed inventory.



      Impacts                 Causes           Effects/Consequen         Evaluation             Mitigation
                                                       ces
Soil pollution by       ● Failure during       ● PCBs                Insignificant at       Required for
unintentional           sampling               contamination of      electrical sub-        prevention of
                                               grounds and
releases during                                                      stations, but may be   pollution
                                               working places;
sampling                                                             significant at other
                                               ● Occupational
                                               exposures             owners of power
                                                                     equipment
                                                                     Local
                                                                     Short term
                                                                     Medium reversible
Disturbance of          ● Operational stops;   ● Shortage of         Moderate to            Required for
electric companies      ● Sampling             electricity to        significant            shortening of
                                               consumers;
and large electricity                                                Local                  sampling and other
                                               ● Breaks of large
consumers                                                                                   inventory
                                               electricity           Short term
operation                                      consumers normal                             operations, related
                                                                     Easily reversible      to the access to the
                                               operation
                                                                                            equipment

            (B2) PCBs disposal.



      Impacts                 Causes           Effects/Consequen         Evaluation             Mitigation
                                                         ces
Disturbance of          ● Operational stops;   ● Shortage of         Insignificant          Required for limited
electric company        ● Replacing of         electricity to        Local                  number of sites
operation               equipment              consumers             Short term
                                                                     Easily reversible
Disturbance of          ● - Civil works;       ● Noise, vibration;   Insignificant          Not required,
environment during      ● Lifting equipment    ● Disturbance of      Local                  follows normal
operation and           operation;             local population      Short-term             operation
transportation          ● Spillage of fuels    normal activities;    Easy reversible        procedures
                        and lubricants         ● Pollution of soil
                        ● Dismantling of       ● Increased health    Moderate Local         Required
Occupational health     capacitors;            costs;                Medium term
                        ● Leakage from         ● Lost work days      Hardly reversible
                        capacitors;            and lost of income;
                        ● Work with            ● Loss of life
                        contaminated soils
                        and damaged metal
                        parts;
                        ● Improper
                        handling of
                        equipment
                        ● Leakage from         ● Health effects to   Moderate               Required for
Pollution of            capacitors;            the Vulcanesti        Local                  prevention of
environment by          ● Temporary            power station         Medium term            further
PCBs at the             storage of             workers;              Hardly reversible      contamination of
Vulcanesti power        contaminated soils;    ● Wind dispersion                            surrounding
                        ● Drainage water in    of contaminated                              territories
station

            ECOS
            Environmental Impact Assessment Report                                       Page 118   of 179
            Draft Version – Do not quote




      Impacts                  Causes           Effects/Consequen       Evaluation          Mitigation
                                                        ces
                         the pits;             soils;
                         ● Seepage from the    ● Contamination of
                         storage of            groundwater
                         contaminated soil     aquifers
Temporary land           ● Establishment of    ● Limitation for     Insignificant       Generally not
acquisition near the     buffer storage;       Vulcanesti power     Local               required
Vulcanesti power         ● Building of lined   station available    Medium term
station                  sites                 lands                Easily reversible

            6.4     Effects of Environment on the Project

            The natural environment can have important effects on the project, particularly to the
            operational schedule of expected activities and may increase negative impacts as
            well. That is why environment features themselves should be taken into
            consideration at the planning and operational stage for project components stipulated
            under paragraph 2.3
                ●      Wet conditions may increase percolation of pesticides and PCBs from
                       contaminated soils, spills and leakage into groundwater aquifer
                ●      Torrent/heavy rainfall may wash out contaminated soils and residuals of
                       pesticides and PCBs at the ground surface to the surface water streams
                ●      Exposure of pesticides to intense solar radiation, high temperature, and strong
                       winds may increase widening of contamination through the air
                ●      High temperature may increase exposure rate of workers dealing with pre-
                       packaging of pesticides, dismantling and handling of capacitors, civil works at
                       the contaminated sites and excavation of contaminated soils.
                ●      Movement of heavy trucks by non-paved village roads under wet conditions
                       may provoke damages to the roads and increase the accident risks
                ●      Transportation during unfavourable weather conditions (rain, snow, ice, fog)
                       may increase road accidents and risk of wider contamination of environment
                ●      Extremely low temperatures may affect the integrity of plastic drums with
                       pesticides
                ●      Repackaging of pesticides under strong wind conditions may affect closest
                       sensitive environmental components, living areas, agriculture lands, and
                       livestock.

            6.5     Cumulative effects

            Important cumulative effects will be related to project activities (A1) Immediate
            repackaging and centralization of obsolete pesticides and (A2) Inventory and risk
            assessment, and only partly to (A3) Repackaging for transportation and final
            disposal, resulting in widening of soil and water pollution. All three project
            components are involving pesticides which are persistent and have a strong
            cumulative and migratory potential.


            ECOS
Environmental Impact Assessment Report                               Page 119   of 179
Draft Version – Do not quote



Any operation related to immediate repackaging and centralization (activity under
project component A1), taken at a certain site, may have significant local impacts (if
mitigation measures are not applied to the required extent) to the nearest and
sensitive environment. Assuming that about 340 places over the country will be
triggered, the combination of these impacts, can be significant country-wide.
Activities planned under project components A2 (inventory) and A3 (repackaging for
transportation and final disposal) may contribute to the same environmental concern
as widening of environmental pollution from another 37 places, involving higher
volume of chemicals and longer operation at the site. Again, mitigation measures
proposed should minimize negative impacts to a great extent.

Cumulation of releases, spills, and leakages which can happen at a single place
during operations or as a result of operation failures/accidents, may lead to wider
contamination of arable lands, natural ecosystems, livestock, living and occupational
areas, resulting in higher health risk, losses of agricultural products international
marketing opportunities and affecting wider wild biodiversity. It is particularly true
for potential pollution of water streams and floodplains as it may quickly affect the
whole watersheds and include international water courses as Prut and Dniester rivers,
which are important water supply sources not only for Moldova, but also for Ukraine
and Romania. Both rivers and their floodplains are important areas for protection of
wild flora and fauna nationally and internationally, as important European migratory
pathways for many endangered and protected species.

The cumulative impacts of PCBs potential releases during implementation of project
components (B1) PCBs detailed inventory, and (B2) PCBs disposal are not
concerned to the same extent as pesticide ones as PCBs are fixed at the oil drivers
and respectively less migratory. Minor and local impacts can only be expected in
industrialised areas where population’s access and effects to the natural environment
are minimal.

6.6    Residual effects

Assuming that all mitigation is carried out for all potential impacts identified,
residual effects after project activities should be minimal as compared to the actual
status of environmental problems related to the POPs obsolete pesticides and PCBs.

Nevertheless the residual effects will remain. They are mainly related to the
pesticides sub-component as described below:
●     About 340 warehouses will be emptied from POPs obsolete pesticides, ensuring
      urgent and priority measures for elimination of health and environmentally
      dangerous chemicals. The project does not foresee any substantial remediation
      measures for these 340 sites. Emptied warehouse will remain as significant
      pollution sources because their walls, floors, and adjacent territories are
      contaminated. The impacts will be greatly minimised by the project, but if no
      remediation measures are applied the concerns may last for many years.
      Development of after-project alternatives for evacuated warehouses will be


ECOS
Environmental Impact Assessment Report                                 Page 120   of 179
Draft Version – Do not quote



     necessary country-wide and experience gained after Milieukontakt pilot and
     demonstration actions in one rayon may provide better understanding of
     available and affordable safeguarding options.
●    Many other warehouses has been already demolished, ruined and non-
     inventoried. In total, the country has thousands of contaminated sites which
     require inventory, risk assessment and further remediation measures. The project
     would contribute to a country-wide risk assessment and creation of national
     register of storage and old warehouses and contaminated sites.
●    37 central warehouses will finally be emptied, but remediation measures will be
     again limited. If no reliable options for further safe use of buildings or their
     remediation are developed the emptied warehouses will contribute to the residual
     effects, as they will remain as pollution sources for a long time.
●    Mitigation of residual effects by developing and promoting affordable and
     acceptable after-project options for a significant number of evacuated
     warehouses is an important aspect, since the old warehouses are generally not
     considered by the local authorities and the population as very dangerous places,
     finally resulting in using of free construction materials for household needs. This
     may drastically increase the residual impacts and may generate more severe
     impacts on human health.

Residual effects are also detected in the frame of PCBs project components.
●    After the project a number of newly identified PCB-contaminated equipment
     will remain (in energy sector and in other industry as well), further generating
     relative human and environmental risks.
●    Contamination of working territory and constructions on electrical substations is
     likely to have been produced already and next phase of investments will be
     necessary for decontamination of soils and support constructions where leaking
     capacitors are presently placed.




ECOS
Environmental Impact Assessment Report                                                                           Page   121 of 179
Draft Version – Do not quote




7 Environmental Management Plan
7.1     Mitigation Plan

POPs obsolete pesticides sub-component

(A1) Immediate repackaging and centralization of obsolete pesticides.



            Phase                     Issue/Targets                              Mitigating Measure                               Cost         Institutional responsibility

 Preparatory
 ● Correcting decision of          1. Minimize existing         1.1. Revise decision and select new warehouse(s) in                          1.1-1.2. GOM and RLA under
 central warehouses                country overall and site     rayons Briceni104, Donduseni105, Cahul106, Ocnita107,            GOM/        consultation with MAFI, MENR,
 selection in some rayons;         specific environmental       Edinet108, Riscani109, and Soldanesti110.                                    MHSP, SDES.




104
    Seriously damaged warehouse in Grimancauti, high overall risks associated, close to the Ukrainian border. The repackaged pesticide stock in rayon is stored in bags, without
barrels.
105
    Selected storage place in a former garage should be reconsidered and all pesticides should be evacuated accordingly. The current site presents considerable health risks. The
repackaged pesticide stock in rayon is stored in bags, without barrels.
106
    Selected storage place in a former pig farm should be reconsidered and all pesticides should be evacuated accordingly. The current site presents considerable health risk.
Repackaging in rayon has not started yet.
107
    Seriously damaged warehouse in Clocusna, considerable overall risks associated, including high health risks. The repackaged pesticide stock in rayon is stored in bags, without
barrels.

ECOS
Environmental Impact Assessment Report                                                                            Page   122 of 179
Draft Version – Do not quote



            Phase                      Issue/Targets                              Mitigating Measure                               Cost         Institutional responsibility
                                                                                                                           111
 ● Rehabilitation of               and health risks              1.2. Designate central warehouses in rayons Drochia ,            RLA/M       1.3. GOM and RLA under
 warehouses in some                2. Ensure better/ safety      Straseni112, Ialoveni113 and Glodeni114.                         AFI         supervision of MAFI, MENR,
 raions;                           planning and                  1.3. Make additional adequate reparation of                                  MHSP, and DC
 ● Preparing an evacuation         emergency response            warehouses if needed in some rayons, with particular                         2.1-2.2. MAFI and/or contracted
 and emergency plan for            preparedness                  focus on and specific protection measures in                                 national company
 each rayon                                                      Cimislia115, Calaras116, Telenesti117, Floresti118,                          2.3. MAFI in collaboration with
                                                                 Comrat119, Ciadir-Lunga120, Hincesti121, Orhei122,                           MENR, MHSP and MD
                                                                 Stefan Voda (Olanesti)123, Vulcanesti124, and                                2.4. SDES in collaboration with
                                                                 Nisporeni125.                                                                MAFI, MENR, MHSP and MD
                                                                 2.1. Conduct detailed inventory and risk assessment of
                                                                 all warehouses per raion designated for re-packaging
                                                                 2.2. Make inventory of places where facts of illegal




108
    Seriously damaged warehouse in Edinet, considerable overall risks associated, including health risks. Repackaging in rayon has not started yet.
109
    Seriously damaged warehouse in Recea, considerable health risks and high environmental risks. Repackaging in rayon has not started yet.
110
    Seriously damaged warehouse in Chipesca, high health risks and considerable environmental risks, The repackaged pesticide stock in rayon is stored in bags, without barrels.
111
    Zgurita is a more preferable site as compared to Suri, which was proposed by the rayon authorities. Zgurita site presents lower health and environmental risks. Repackaging in
rayon has not started yet.
112
    Vorniceni is a more preferable option, as compared to Straseni. The Straseni site presents high environmental and considerable human risks. Reparation and mitigation
measures in Vorniceni will be necessary to mitigate the considerable health risks. Repackaging in rayon has not started yet.
113
    Bardar and Milestii Mici are both privately owned and the EA team was not allowed to visit and inspect the sites. Repackaging in rayon has not started yet.
114
    Cuhnesti site is more preferable as compared to Sturzovca. Repackaging in rayon has not started yet.
115
    High health and environmental risks associated.
116
    Considerable health and environmental risks associated; large rehabilitation of additional sections will be required in order to accumulate the total amount of pesticides from
the rayon.
117
    High environmental risks and considerable health risk associated.
118
    High environmental risks associated
119
    Considerable environmental risks associated
120
    Considerable health and environmental risks associated
121
    High environmental risks associated
122
    Considerable health and environmental risks associated
123
    Considerable health risk associated
124
    Considerable health risk associated
125
    Considerable environmental risks associated

ECOS
Environmental Impact Assessment Report                                                                       Page   123 of 179
Draft Version – Do not quote



               Phase                    Issue/Targets                            Mitigating Measure                         Cost      Institutional responsibility
                                                                  dumping of pesticides are known and collect
                                                                  obsolete/POPs pesticides stored by population to be
                                                                  included in immediate repackaging plan
                                                                  2.3. Prepare detailed rayon evacuation plan
                                                                  (repackaging plan per warehouse, labeling and
                                                                  registration, evacuation schedule and transportation
                                                                  routes)
                                                                  2.4. Prepare a rayon emergency plan (for evacuated
                                                                  and central stores, transportation) accompanied by
                                                                  provision of accidental releases combating technology.
 ● Rehabilitation of                 1. Prevent air and soil      1.1. Remove and repackage contaminated dust and           GoM/    MD, SDES and MK together with
 designated warehouses               pollution by spreading       construction wastes, reassembling building parts before   MK126   contracted construction company;
 involving construction              of contaminated dusts        the start of reparation/rehabilitation works                      rayon agricultural, health and
 machinery operations and            and construction             1.2. Implement works only under low wind and no rain              environmental authorities to carry out
 civil works at the                  wastes dispersion            conditions                                                        supervision and control.
 contaminated areas                  during reparation /          1.3.Ensure availability of water proof sheets for                 Contracted construction company;
                                     rehabilitation works         temporary coverage of open building holes in order to             rayon agricultural, health and
                                                                  prevent rain and wind effects inside the building                 environmental authorities to carry out
                                                                  1.4.Decontaminate construction machinery and                      supervision and control
                                                                  transport after works
                                                                  1.5.Keep the stock of construction materials out of
                                                                  contaminated areas and bring to the site only daily
                                                                  required amount
                                     2. Prevent occupational      2.1. Control health status of workers before and after    GoM/    2.1-2.3. Contracted construction
                                     health risk for workers      the works                                                 MK      company; rayon health authorities to
                                                                  2.2. Use personal protection devices and respiratory              carry out supervision and control
                                                                  masks
                                                                  2.3. Ensure workers uniform to be kept at the site and
                                                                  decontaminated after finishing of works
                                     3. Minimize                  3.1.Inform local population in advance on possible        GoM/    3.1-3.2. Local authorities under




126
      Milieukontact, a Dutch NGO, is responsible for 1-2 selected rayons

ECOS
Environmental Impact Assessment Report                                                              Page   124 of 179
Draft Version – Do not quote



           Phase                   Issue/Targets                        Mitigating Measure                         Cost     Institutional responsibility
                               disturbance factors for   restrictions for attendance of territories close to      MK      cooperation with contracted
                               nature and human          warehouses during reconstruction                                 construction company
                               surroundings              3.2. Establish temporary rules, agreed with local                3.3-3.4. Contracted construction
                                                         landowners and community, to prohibit planting of                company; rayon health and
                                                         vegetables and livestock grazing around warehouses in            environmental authorities to carry out
                                                         reparation.                                                      supervision and control
                                                         3.3.Establish precautionary symbols around
                                                         warehouses in reparation, clearly indicating not
                                                         trespassing zones.
                                                         3.4. For noisy operations consider spring time
                                                         reproduction of wild fauna (for warehouses located
                                                         closely to large forests.

 Construction

 Not applicable

 Operation
 ● Repackaging of              1. Prevent spillage and   1.1. Cover the warehouse floor at the place designated   GoM/    1.1-1.5. MD, SDES, MK rayon
 pesticides and                leaks during repacka-     for repackaging by two layers of polyethylene sheets     MK      agricultural and environment
 contaminated floor dusts      ging and avoid            for collecting dispersed matters after the works.                authorities to carry out supervision
 and other contaminated        contamination of          1.2. For pumping of liquid pesticides to install the             and control.
 wastes at 340 warehouses      packaging materials       pump and clean drum at the metal platform, placed in
 ● Loading plastic drums to                              the leakage keeping small reservoir.
 military trucks                                         1.3. Use clean wood platform elevated above the floor
 ● Transportation to central                             for placing of drums during bags loading to prevent
 warehouse                                               drums external surface contamination.
 ● Re-loading and placing                                1.4. Immediately evacuate fulfilled in drums out of
 of drums inside the central                             store and load to trucks.
 warehouse                                               1.5. Keep empty new drum stock out of contaminated
                                                         areas and bring to the site only minimum required
                                                         number of drums and only if fulfilled drums are
                                                         already loaded to a truck
                               2. Minimize dispersion    2.1. Consider strong wind and rainfall events as         GoM/    2.1-2.3. MD, SDES, MK for relevant
                               and spreading of          limiting factors for repackaging                         MK      warehouses; rayon agricultural and
                               contaminated wastes,      2.2. Ensure availability of water proof sheets for               environment authorities to carry out
                               floor dust, old package   temporary coverage of open building holes in order to            supervision and control

ECOS
Environmental Impact Assessment Report                                                                  Page   125 of 179
Draft Version – Do not quote



           Phase                   Issue/Targets                         Mitigating Measure                             Cost    Institutional responsibility
                               and other contaminated    prevent rain and wind effects inside the building
                               materials                 2.3. Repack all contaminated wastes and used support
                                                         materials (signs, shelving, fire extinguishers, timber,
                                                         plastic pallets and tubs, rubber floor coverings,
                                                         disposable overalls, clothing, boot covers, used
                                                         respirators filters, used wipes, etc)
                                                         2.4. Develop specific additional mitigation measures
                                                         for sites if impacts to natural areas (forests, floodplains,
                                                         surface and ground water) and human settlements
                                                         would be evident
                               3. Prevent occupational   3.1. Control health status of staff before and after the       GoM/   3.1-3.4. MD, SDES, MK for relevant
                               health risk               works                                                          MK     warehouses; rayon health authorities
                                                         3.2. Provide adequate training to staff                               to carry out supervision and control
                                                         3.3. Use personal protection devices and respiratory
                                                         masks
                                                         3.4. Ensure staff uniform to be kept at the site and
                                                         decontaminated after finishing of works
                               4. Prevent                4.1. Inform local population in advance on possible            GoM/   4.1-4.2. Local authorities under
                               contamination of          restrictions for attendance of warehouses closest              MK     cooperation with MD, SDES and MK
                               agricultural crops and    territories during repackaging                                        4.3-4.4. MD, SDES, MK. Rayonal
                               livestock and minimize    4.2. Establish temporal rules, agreed with local                      health and environmental authorities
                               disturbance factors for   landowners and community, for prohibiting of                          to carry out supervision and control
                               nature and human          vegetables planting and livestock grazing around
                               surroundings              warehouse
                                                         4.3.Establish precautionary symbols around
                                                         warehouses, clearly indicating not trespassing zones
                                                         4.4. For noisy operations and extensive traffic consider
                                                         spring time reproduction of wild fauna (for warehouses
                                                         located closely to the extensive forest)

 Decommissioning
 Not applicable




ECOS
Environmental Impact Assessment Report                                                                Page   126 of 179
Draft Version – Do not quote

POPs obsolete pesticides sub-component

(A2) Inventory and risk assessment.


          Phase                    Issue/Target                          Mitigating Measure                           Cost    Institutional responsibility

Preparatory
● prepare an inventory plan    1. Ensure better safety    Not specially required                                     GEF     Contractors
for each central store         planning
● develop risk assessment
methodology, tools and
reporting

Construction
Not applicable



Operation
● resorting of drums           1. Prevent                 1.1 Implement all required works inside warehouse if       GEF     1.1-1.4. Contracted company in
● reloading inside             volatilisation, wind       possible                                                           coordination with selected
warehouse                      dispersion, spillage and   1.2 Designate special place/platform for sampling and              laboratory. Rayon agricultural
● opening of drums             leaks during sampling,     identification inside warehouse, preferably elevated               authorities to carry out supervision
● sampling                     resorting of drums and     from the floor and covered by two layers polyethylene              and control.
● risk assessment of           contamination of           sheets, in order to prevent contamination of external
potentially contaminated       packaging materials        surface of drums.
sites                                                     1.3 If operations inside warehouse are impossible or
                                                          limited: (i) use available and preliminary protected,
                                                          rehabilitated and cleaned sections of warehouse, or (ii)
                                                          use of military tent safety placed near warehouse,
                                                          ensuring covering of floor by water proof material and
                                                          other spills prevention measures, or (iii) assemble
                                                          temporary water proof tent at the paved basement with
                                                          barriers and fences.
                                                          1.4 Avoid works outside warehouse at strong winds
                                                          and rainfalls conditions
                               2. Prevent occupational    2.1 Control the health status of workers                   GEF/    2.1-2.4 Contracted company and

ECOS
Environmental Impact Assessment Report                                                                  Page   127 of 179
Draft Version – Do not quote



          Phase                    Issue/Target                            Mitigating Measure                            Cost         Institutional responsibility
                               health risk                  2.2. Use personal protection devices and respiratory        NATO      selected laboratory. Rayon health
                                                            masks                                                                 authorities to carry out supervision
                                                            2.3 Ensure workers uniform to be kept at the site and                 and control.
                                                            decontaminated after finishing of works
                                                            2.4 Sampling teams should apply adequate
                                                            prevention/safety measures

Decommissioning
Not applicable



POPs obsolete pesticides sub-component

(A3). Repackaging for transportation and final disposal.



          Phase                     Issue/Target                               Mitigating Measure                              Cost             Institutional
                                                                                                                                               responsibility

Preparatory
● prepare repackaging,         1. Ensure better safety       Not specially required                                         GEF          Contractors
transportation and             planning and emergency
emergency plans                response preparedness

Construction
● Not applicable (however,     1. Adequately protect         To be developed in details if decision will be taken           GEF
may be required if one site    designated site to            accordingly. A full site-specific risk assessment may be
will be selected for           minimize human and            required
repackaging                    environmental hazards

Operation
● re-packaging in UN           1. Prevent volatilisation,    1.1. All repackaging works to be implemented at the            GEF          1.1-1.8. Contracted company.
approved packs                 wind dispersion, spillage     designated and protected areas (well paved or lined                         Rayon agricultural and

ECOS
Environmental Impact Assessment Report                                                              Page   128 of 179
Draft Version – Do not quote



          Phase                     Issue/Target                          Mitigating Measure                             Cost           Institutional
                                                                                                                                       responsibility
● compression of old metal     and leaks during re-      platforms, under temporary waterproof roof, with                       environmental authorities to
drums                          packaging and loading     spills/leakage barriers) and only within the perimeter of              carry out supervision and
● loading of UN approved       and prevent               warehouse                                                              control.
filled packs to heavy trucks   contamination of UN       1.2. Limit works under strong winds and rainfalls
● transportation               approved packaging        conditions
                               materials                 1.3. Avoid surface contamination of UN approved packing
                                                         materials, equipment (lifting, pumping, etc.) and kept the
                                                         UN-approved packs stock out of contaminated areas.
                                                         1.4. Emptied old metal drums to be filled by absorbent
                                                         with a drip tray before crushing. Liquid residue of crushed
                                                         drums to be pumped immediately into head drum. Solid
                                                         residuals after crushing to be placed in open head drums
                                                         with the PE-liner of 200 micron
                                                         1.5. UN approved transit bins to be preliminary leak tested
                                                         by water, which after all tests should be pumped at a
                                                         required drum and further processed as pesticides wastes.
                                                         Dried transit bins to be lined with a layer of polyethylene
                                                         sheet.
                                                         1.6. The layer of absorbent (15 mm deep) to be placed
                                                         inside each UN approved box prior to packing
                                                         1.7. Collect and pack all wastes and used contaminated
                                                         supporting materials in double containment
                                                         1.8. Decontaminate all equipment and durable parts to be
                                                         used in other site before transportation
                               2. Prevent occupational   2.1.Control the health status of workers                        GEF    2.1-2.3. Contracted company.
                               health risk               2.2. Use personal protection devices and respiratory masks             Rayon health authorities to
                                                         2.3. Ensure workers uniform to be kept at the site and                 carry out supervision and
                                                         decontaminated after finishing of works                                control.
                               3. Minimise disturbance   3.1. Develop specific additional mitigation measures for        GEF    3.1-3.2 Contracted company.
                               of environment during     sites classified as highly and considerably risky for natural          Rayon environmental and
                               operation                 areas (forests, floodplains, surface and ground water, etc.)           health authorities to carry out
                                                         and human settlements.                                                 supervision and control.
                                                         3.2. Avoid noisy operations and extensive heavy trucks
                                                         traffic during spring time (for warehouses located close to
                                                         large forest areas) and during the night (warehouses located
                                                         near residential areas)


ECOS
Environmental Impact Assessment Report                                                                Page   129 of 179
Draft Version – Do not quote



           Phase                      Issue/Target                           Mitigating Measure                           Cost           Institutional
                                                                                                                                        responsibility
                                  4. Increase preparedness   4.1 Provision of accidental releases combating equipment     GEF     4.1. Contracted Company
                                  level for accidental       and capacity.
                                  releases mitigation

Decommissioning
Not applicable



POPs obsolete pesticides sub-component

Remediation activities will not be financed in the framework of this project. In the same time, the GRM should take all available
measures to mitigate the risks associated with emptied storehouses, including low-cost measures as local containment, fencing,
labeling, etc. The project will finance capacity building activities including monitoring of old obsolete pesticides storage sites.
Regular sampling of soil, surface and ground water will be undertaken at more than 300 sites in order to keep the situation under
control and to prevent potential spreading of obsolete pesticides around.

PCBs sub-component

(B1) PCBs detailed inventory:

           Phase                       Issue/Target                            Mitigating Measure                          Cost           Institutional
                                                                                                                                         responsibility

Preparatory
Not applicable as it is already
designed


Construction
Not applicable



ECOS
Environmental Impact Assessment Report                                                               Page   130 of 179
Draft Version – Do not quote



            Phase                     Issue/Target                           Mitigating Measure                             Cost             Institutional
                                                                                                                                            responsibility

Operation
● operational stops of            1. Avoid unexpected       1.1. Develop sampling program, including prevention and         GEF/eq    1.1.-1.3. Contracted company
electricity companies and         leakage during sampling   liquidation measures, related to different types of equipment   uip-      or equipment holders
large electricity consumers                                 to be tested                                                    ment
● sampling                                                  1.2 Ensure absorption material and container for wastes         holders
                                                            available at the sampling time
                                                            1.3 Repack all materials contaminated during leakage
                                  2. Minimize the adverse   2.1. Set-up of sampling plan agreed by electric companies       GEF/eq    2.1 Contracted company or
                                  impact to                 and large electricity consumers, preferably accommodated to     uip-      equipment holders
                                  consumers/processes due   the planned operational breaks and prophylactic stops.          ment
                                  to operational stops of                                                                   holders
                                  enterprises
Decommissioning

Not applicable



PCBs sub-component

(B2) PCBs disposal at small electrical sub-stations

           Phase                     Issue/Target                           Mitigating Measure                              Cost            Institutional
                                                                                                                                           responsibility

Preparatory
Not applicable as it is already
designed


Construction
Not applicable



ECOS
Environmental Impact Assessment Report                                                              Page   131 of 179
Draft Version – Do not quote



           Phase                    Issue/Target                           Mitigating Measure                              Cost             Institutional
                                                                                                                                           responsibility

Operation
● operational stops of         1. Minimize the adverse   1.1 Set-up of replacing plan agreed by electric companies,        GEF/eq    Contracted company or
electricity sub-stations for   impact to electricity     preferably accommodated to the planned operational breaks         uip-      equipment holders
replacing of capacitors        consumers                 and prophylactic stops                                            ment
● dismantling of capacitors                                                                                                holders
● transportation
                               2. Prevent leakage and    2.1 Carefully dismantle the capacitors by help of scaffolding     GEF/eq    Contracted company or
                               contamination of          and lifting mechanisms avoiding accidental fall from the          uip-      equipment holders
                               grounds, platforms, IBC   original platform.                                                ment
                               containers                2.2 Carefully lower the capacitors to the ground, covered by      holders
                                                         two layers polyethylene sheets (for leaking, heavy corroded
                                                         or damaged capacitors).
                                                         2.3 Avoid removal or damage of the ceramic isolators on top
                                                         of the capacitors
                                                         2.4 Place dismantled and visually checked capacitors to the
                                                         IBC container filled with absorbent materials at the bottom.
                                                         2.5 In case of broken capacitors, the IBC container should
                                                         be filled with absorption material after placing the capacitors
                                                         in it.
                                                         2.6 Decontaminate original steel platforms on which the
                                                         capacitors are currently attached
                                                         2.7 Existing storage containers (two in Donduseni and two
                                                         in Soroca) can be decontaminated or can be used for storage
                                                         of contaminated topsoil to be further disposed as PCBs
                                                         containing wastes
                               3. Prevent occupational   3.1.Control health status of workers                              GEF/eq    Contracted company or
                               health risk               3.2. Use personal protection devices, suitable gloves and         uip-      equipment holders
                                                         respiratory masks                                                 ment
                                                         3.3. Ensure workers uniform to be decontaminated after            holders
                                                         finishing of works
Decommissioning

Not applicable



ECOS
Environmental Impact Assessment Report                                                              Page   132 of 179
Draft Version – Do not quote

PCBs sub-component

(B2) PCBs disposal at Vulcanesti electrical station

           Phase                      Issue/Target                          Mitigating Measure                             Cost             Institutional
                                                                                                                                           responsibility

Preparatory
Not applicable as it is already
designed


Construction
● establishing of two lined       1. Prevent further      1.1. Establish two lined sites with cofferdam at the territory   GEF/eq    Contracted company or
sites of 10 x 20 m each with      contamination of the    of Vulcanesti electric station and near the excavated pits if    uip-      equipment holders
a 1.2 m high cofferdam            surrounding territory   space is available.                                              ment
● establishing of buffer                                  1.2. If space within the perimeter of Vulcanesti electrical      holders
storage for IBC containers                                station would be limited for construction, the temporary land
                                                          acquisition closely to the Vulcanesti power station fences
                                                          would be necessary.
                                                          1.3 If lined sites should be placed down of Vulcanesti
                                                          electric station perimeter, the 1.2 m cofferdam should be
                                                          protected against possible flooding events after the heavy
                                                          rains in the valley.
                                                          1.4 Drainage (perforated tubes or other type) for drained
                                                          water accumulation from the excavated soils should be
                                                          installed above lining sheets and ended by small
                                                          accumulation reservoir equipped by treatment unit (activated
                                                          carbon filter) before discharge to the environment.
                                                          1.5 The cofferdam and excavated soils should be covered by
                                                          a waterproofed lining on the top.
                                                          1.6 Construction of 300-500 m of accessible road to the
                                                          lined sites will be necessary.
                                                          1.7 Buffer storage platform (preferably at the territory of
                                                          Vulcanesti electrical station) should be paved by asphalt
                                                          (200 m2) and provided with accessible road, a bund wall, a
                                                          sump and fences with warning signs.



ECOS
Environmental Impact Assessment Report                                                              Page   133 of 179
Draft Version – Do not quote



             Phase                  Issue/Target                           Mitigating Measure                             Cost             Institutional
                                                                                                                                          responsibility

Operation
● dismantling and packing of   1. Prevent leakage and    1.1. Carefully lower the original steel platforms with battery   GEF/eq    Contracted company or
capacitors                     contamination of          of capacitors by means of two powerful 4-weels-                  uip-      equipment holders
                               grounds, platforms, IBC   construction lifts.                                              ment
                               containers                1.2.Carefully dismantle the capacitors using scaffolding and     holders
                                                         lifting mechanisms avoiding accidental fall from the original
                                                         platform.
                                                         1.3.Carefully lower the capacitors to the ground, covered by
                                                         two layers polyethylene sheets (for leaking, heavy corroded
                                                         or damaged capacitors).
                                                         1.4.Avoid removal or damage of the ceramic isolators on top
                                                         of the capacitors
                                                         1.5.Place dismantled and visually checked capacitors to the
                                                         IBC container filled with absorbent materials in the bottom
                                                         1.6. In case of broken polluted capacitors, the IBC container
                                                         should be filled with absorption material after placing the
                                                         capacitors in it.
                                                         1.7. Decontaminate original steel platforms on which the
                                                         capacitors are currently attached
                                                         1.8. Existing storage containers can be decontaminated or
                                                         can be used for storage of contaminated soil for further
                                                         disposal as PCBs containing wastes
                               2. Prevent occupational   2.1.Control health status of workers                             GEF/eq    Contracted company or
                               health risk               2.2. Use personal protection devices, suitable gloves and        uip-      equipment holders
                                                         respiratory masks                                                ment
                                                         2.3. Ensure workers uniform to be decontaminated after           holders
                                                         finishing of works
● excavation of dumped         1. Prevent further        1.1. Capacitors and associated soil with visible capacitor       GEF/eq    Contracted company or
capacitors and packing of      contamination of          parts should be excavated and placed in IBC containers           uip-      equipment holders
contaminated soils             surrounding areas         (filled with absorbent material at the bottom) immediately.      ment
                                                         1.2. Excavated soils from the dumping pits should be placed      holders
                                                         to the lined sites (partly to the metal containers used for
                                                         storing damaged capacitors). The most polluted soil layers,
                                                         particularly from the bottom of the pits, should be placed at
                                                         a lower part of the lined sites to prevent further

ECOS
Environmental Impact Assessment Report                                                         Page   134 of 179
Draft Version – Do not quote



           Phase                    Issue/Target                      Mitigating Measure                              Cost             Institutional
                                                                                                                                      responsibility
                                                    contamination of previously excavated soils by drainage
                                                    leaking water.
                                                    1.3. It might be necessary to implement steel protective
                                                    balustrades in order to prevent soil collapse.
                                                    1.4 Water from the pit bottom should be pumped from the
                                                    excavated area and stored for analysis and required future
                                                    treatment (activated carbon filter placed at the lined sites if
                                                    applicable).
                                                    1.5 Placing of excavated and slightly dried contaminated
                                                    soils to the IBC containers (filled by absorbent material t the
                                                    bottom) should be implemented in dry and no wind
                                                    conditions.
                                                    1.6 Keep empty IBC containers stock out of contaminated
                                                    areas in order to prevent external site contamination.

Decommissioning
● liquidation of lined sites   1. Prevent further   1.1. Contaminated waters (if treatment is not affordable),        GEF/eq    Contracted company or
                               contamination of     lining materials, drainage tubes and other supporting             uip-      equipment holders
                               surrounding areas    materials, which would be probably higher contaminated,           ment
                                                    should be placed again in IBC containers (filled by               holders
                                                    absorbent materials at the bottom) for shipment.




ECOS
Environmental Impact Assessment Report                                Page   135 of 179
Draft Version – Do not quote




7.2    Monitoring Plan

The potential benefits to the public health and the environment from successful
completion of this project are significant. However, during its implementation
significant hazards to both health and the environment may be created. Many layers
of safeguards exist including measures written into the project document,
professional guidelines, national and international law. Adherence to these should
ensure a high level of health and environmental protection.

Regular monitoring will be required to ensure that mitigation is being carried out and
to also determine whether or not additional impacts, not identified in this
environmental review, have not been overlooked. Monitoring for the appropriate
application of health, safety and environmental protection measures at all stages of
the project will be the formal responsibility of the project management, the
independent project monitors and counterpart staff designated for this task (e.g. the
State Ecological Inspectorate). Key to effective monitoring will be the establishment
of a set of simple baseline data against which to measure effects of various activities.
In order for monitoring to be effective, monitoring results must be reviewed by
project management, and where appropriate, acted upon to eliminate or reduce the
impact to an acceptable level (e.g. established standard). A detailed monitoring
procedure will be developed including: (i) designing a monitoring system, procedure
and schedule; (ii) establishing a set of baseline data; (iii) monitoring different types
of activities that will result either directly or indirectly from the project; (iv)
preparing monitoring reports that will include recommended corrective actions; and
(v) determining the cumulative effect of activities.

There will be two main monitoring types:
●     Health monitoring: before, during and after operations in the field commence
      full medical examinations, including full blood tests, should be performed,
      tailored to monitor all staff working on the project. It is advised that operational
      staff is tested every three months. All analysis will be carried out by an
      accredited laboratory. In the case of workers showing adverse effects from their
      work activities an investigation into working practices, level of supervision and
      understanding of protective procedures will be undertaken by the Project.
●     Environmental monitoring: This monitoring should be used to ensure that the
      working methodology adopted is correct and has the minimal effect on the
      workforce and the environment / general public. The key to the elimination of
      impact outside the working area is risk assessment. A training program will be
      tailored to focus on contamination prevention.

To follow up on the mitigation measures a number of qualitative and quantitative
indicators are proposed designed to monitor that mitigation measures are being
followed. The proposed indicators include the following:




ECOS
Environmental Impact Assessment Report                            Page   136 of 179
Draft Version – Do not quote



●    Increase/reduction in quality of the natural environment, including biophysical
     parameters (e.g. water quality) and biodiversity of flora and fauna, arising from
     project related activities;
●    Increase/reduction in obsolete pesticide related human health impacts as a result
     of project related activities;
●    Number of people trained in pesticide management, including handling and
     storage practices;
●    More indicators should be proposed during the project implementation.

Details on the monitoring activities to be taken as part of the Environmental
Management Plan are provided in the table below.




ECOS
Environmental Impact Assessment Report                                          Page    137 of 179
Draft Version – Do not quote


                                                               MONITORING PLAN TABLES

POPs obsolete pesticides sub-component

(A1) Immediate repackaging and centralization of obsolete pesticides

    Phase              What              Where               How             When                Why                      Cost             Responsibility
                   parameter is to   is the parameter     is the          is the            is the parameter    Install     Operate   Install        Operate
                   be monitored?     to be monitored?     parameter to    parameter to      to be monitored
                                                          be              be monitored-     (optional)?
                                                          monitored/      frequency of
                                                          type of         measurement
                                                          monitoring      or continuous?
                                                          equipment?
                   ● Soil quality    ● Soil and air (in   ● Chemical      Before start of   To establish        TBD         TBD       Contractor,    Contractor,
Baseline           ● Air quality     the vicinity of      analysis        works             baselines against                         Centre of      Centre of
                   ● Surface and     pesticide stores     ● Medical                         which impacts                             Preventive     Preventive
                   ground water      (340 + 37).          examination                       can be measured                           Medicine       Medicine
                   ● Health status   ● Water (at          and blood                                                                   Ecological     Ecological
                   of workers        selected sensitive   tests                                                                       Inspectorate   Inspectorate
                   ● Health status   sites)
                   of vulnerable     ● Health
                   public groups     monitoring (at
                                     working place
                                     and at selected
                                     sensitive sites)
                   ● Air quality     ● Air monitoring     ● Chemical      ● Weekly          To ensure that      TBD         TBD       Contractor,    Contractor,
Construct          at working        (inside and near     analysis        ● Before and      environmental                             Centre of      Centre of
                   place             the central          ● Medical       after works       safety,                                   Preventive     Preventive
                   ● Health status   pesticide stores     examination     ● Spot            occupational                              Medicine       Medicine
                   of workers        (37).                ● Visual site   inspections       health and                                Ecological     Ecological
                   ● Status and      ● Health             inspection                        construction                              Inspectorate   Inspectorate
                   conformity of     monitoring (at                                         rules are
                   works             working place)                                         followed
                   ● Soil quality    ● Soil and air (in   ● Chemical      ● At old          To check on         TBD         TBD       Contractor,    Contractor,
Operate            ● Air quality     the vicinity of      analysis        pesticide         potential                                 Centre of      Centre of
                   ● Surface and     pesticide stores     ● Medical       stores (during    environmental                             Preventive     Preventive
                   ground water      (340 + 37).          examination     operation, at     dissipation of                            Medicine       Medicine

ECOS
Environmental Impact Assessment Report                                         Page   138 of 179
Draft Version – Do not quote


    Phase              What              Where               How            When                Why                      Cost             Responsibility
                   parameter is to   is the parameter     is the         is the            is the parameter    Install     Operate   Install        Operate
                   be monitored?     to be monitored?     parameter to   parameter to      to be monitored
                                                          be             be monitored-     (optional)?
                                                          monitored/     frequency of
                                                          type of        measurement
                                                          monitoring     or continuous?
                                                          equipment?
                   ● Health status   ● Water (at          and blood      least once).      pesticides.                               Ecological     Ecological
                   of workers        selected sensitive   tests          ● At central      To ensure the                             Inspectorate   Inspectorate
                   ● Health status   sites)                              pesticide         occupational
                   of vulnerable     ● Health                            stores (every 3   health of workers
                   public groups     monitoring (at                      months, during    and the health of
                                     working place                       storage).         vulnerable public
                                     and at selected                     ● Occupationa     groups
                                     sensitive sites)                    l health (every
                                                                         3 months).
                   ● Air quality     ● In the vicinity    ● Chemical     ● Annually (at    To check on         TBD         TBD       Ecological     Ecological
Decom-                               of old pesticide     analysis       least two years   potential                                 Inspectorate   Inspectorate
                                     stores (340)                        after evacua-     environmental
mission                                                                  tion)             dissipation of
                                                                                           pesticides


POPs obsolete pesticides sub-component

(A2) Inventory and risk assessment of obsolete pesticides

    Phase              What              Where               How            When                Why                      Cost             Responsibility
                   parameter is to   is the parameter     is the         is the            is the parameter    Install     Operate   Install        Operate
                   be monitored?     to be monitored?     parameter to   parameter to      to be monitored
                                                          be             be monitored-     (optional)?
                                                          monitored/     frequency of
                                                          type of        measurement
                                                          monitoring     or continuous?
                                                          equipment?



ECOS
Environmental Impact Assessment Report                                        Page   139 of 179
Draft Version – Do not quote


    Phase              What              Where              How            When               Why                      Cost             Responsibility
                   parameter is to   is the parameter    is the         is the           is the parameter    Install     Operate   Install        Operate
                   be monitored?     to be monitored?    parameter to   parameter to     to be monitored
                                                         be             be monitored-    (optional)?
                                                         monitored/     frequency of
                                                         type of        measurement
                                                         monitoring     or continuous?
                                                         equipment?

Baseline           N/A


Construct          N/A
                   ● Air quality     ● Air monitoring    ● Chemical     ● Air quality    To check on         TBD         TBD       Contractor,    Contractor,
Operate            ● Health status   (inside and         analysis       (weekly).        potential                                 Centre of      Centre of
                   of workers        outside the         ● Medical      ● Occupationa    environmental                             Preventive     Preventive
                   ● Status and      central pesticide   examination    l health         dissipation of                            Medicine       Medicine
                   conformity of     stores (37).        and blood      (monthly).       pesticides.                               Ecological     Ecological
                   works             ● Health            tests          ● Spot           To ensure that                            Inspectorate   Inspectorate
                                     monitoring (at      ● Site         inspections      occupational
                                     working place)      inspection     during works     health and safety
                                                                                         rules are
                                                                                         followed

Decom-             N/A
mission




POPs obsolete pesticides sub-component

(A3) Repackaging for transportation and final disposal of obsolete pesticides

ECOS
Environmental Impact Assessment Report                                        Page   140 of 179
Draft Version – Do not quote


    Phase              What              Where              How            When                Why                     Cost             Responsibility
                   parameter is to   is the parameter    is the         is the            is the parameter   Install     Operate   Install        Operate
                   be monitored?     to be monitored?    parameter to   parameter to      to be monitored
                                                         be             be monitored-     (optional)?
                                                         monitored/     frequency of
                                                         type of        measurement
                                                         monitoring     or continuous?
                                                         equipment?
Baseline           N/A

Construct          N/A

                   ● Air quality     ● Air monitoring    ● Chemical     ● Air quality     To check on        TBD         TBD       Contractor,    Contractor,
Operate            ● Health status   (inside and         analysis       (weekly).         potential                                Centre of      Centre of
                   of workers        outside the         ● Medical      ● Occupationa     environmental                            Preventive     Preventive
                                     central pesticide   examination    l health          dissipation of                           Medicine       Medicine
                                     stores (37).        and blood      (monthly).        pesticides.                              Ecological     Ecological
                                     ● Health            tests          ● On-site         To ensure the                            Inspectorate   Inspectorate
                                     monitoring (at      ● On-site      inspection        occupational                                            Labour
                                     working place)      inspection     (weekly)          health of staff                                         Inspection ?
                                                                                          To ensure
                                                                                          compliance with
                                                                                          safety rules
                   ● Soil quality    ● In the vicinity   ● Chemical     ● Annually (at
Decom-                               of the central      analysis       least two years
                                     pesticide stores                   after
mission                              (37)                               evacuation)




ECOS
Environmental Impact Assessment Report                                       Page   141 of 179
Draft Version – Do not quote

PCBs sub-component

(B1) PCBs detailed inventory

    Phase              What              Where             How            When               Why                      Cost             Responsibility
                   parameter is to   is the parameter   is the         is the           is the parameter    Install     Operate   Install        Operate
                   be monitored?     to be monitored?   parameter to   parameter to     to be monitored
                                                        be             be monitored-    (optional)?
                                                        monitored/     frequency of
                                                        type of        measurement
                                                        monitoring     or continuous?
                                                        equipment?
Baseline           N/A

Construct          N/A

                   ● Enforcement     ● Energy           ● Point        ● Selected       To check            TBD         TBD       Ecological     Ecological
Operate            of regulation     companies and      inspection                      whether holders                           Inspectorate   Inspectorate
                   on PCBs           electricity                                        of power
                   identification    consumers                                          equipment are in
                   in dielec-tric                                                       compliance with
                   oils and                                                             the requirements
                   labelling of                                                         of the regulation
                   power
                   equipment

Decom-             N/A
mission




ECOS
Environmental Impact Assessment Report                                            Page   142 of 179
Draft Version – Do not quote

PCBs sub-component

(B2) PCBs disposal

    Phase              What              Where               How             When                 Why                      Cost             Responsibility
                   parameter is to   is the parameter     is the         is the              is the parameter    Install     Operate   Install        Operate
                   be monitored?     to be monitored?     parameter to   parameter to        to be monitored
                                                          be             be monitored-       (optional)?
                                                          monitored/     frequency of
                                                          type of        measurement
                                                          monitoring     or continuous?
                                                          equipment?
                   ● Soil quality    ● Soil (on           ● Chemical     ● Before            To establish        TBD         TBD       Contractor,    Contractor,
Baseline           ● Groundwate      substations          analysis       starting the        baselines against                         Hydrometeo     Hydrometeo
                   r quality         territories)                        works               which impacts                             Centre         Centre
                                     ● Groundwater                                           can be measured
                                     (in adjacent
                                     wells)
                   ● Soil quality    ● Soil (proximal     ● Chemical     ● Soil              To prevent          TBD         TBD       Contractor,    Contractor,
Construct                            to the lined sites   analysis       (monthly)           further                                   Hydrometeo     Hydrometeo
                                     and near buffer                                         contamination of                          Centre         Centre
                                     storage for IBC                                         the surrounding
                                     containers in                                           territory;
                                     Vulcanesti)
                   ● Soil quality    ● Soil (proximal     ● Chemical     ● Soil quality      To check on         TBD         TBD       Contractor,    Contractor,
Operate            ● Groundwate      to capacitor         analysis       (monthly).          potential                                 Centre of      Centre of
                   r quality         batteries).          ● Medical      ● Excavated         environmental                             Preventive     Preventive
                   ● Health status   ● Excavated soil     examination    soil (spot          dissipation of                            Medicine       Medicine
                   of workers        from pits with       and blood      analysis from       PCBs.                                     Ecological     Ecological
                   ● Drainage        broken               tests          different           To check the                              Inspectorate   Inspectorate
                   water from the    capacitors           ● On-site      depths)             level of                                                 Labour
                   lined site        ● Groundwater        inspection     ● Drainage          contamination of                                         Inspection
                                     (in adjacent                        water               excavated soil.
                                     wells)                              (monthly)           To ensure the
                                     ● Health                            ● Occupationa       occupational
                                     monitoring (at                      l health            health of workers
                                     working place)                      (monthly).          To ensure
                                                                         ● On-site           compliance with
                                                                         inspection          safety rules

ECOS
Environmental Impact Assessment Report                                       Page   143 of 179
Draft Version – Do not quote


    Phase              What              Where             How             When              Why                     Cost             Responsibility
                   parameter is to   is the parameter   is the         is the           is the parameter   Install     Operate   Install        Operate
                   be monitored?     to be monitored?   parameter to   parameter to     to be monitored
                                                        be             be monitored-    (optional)?
                                                        monitored/     frequency of
                                                        type of        measurement
                                                        monitoring     or continuous?
                                                        equipment?
                                                                       (weekly)
                   ● Lined site      ● Vulcanesti       ● Visual       ●                To check the       TBD         TBD       Ecological     Ecological
Decom-             and buffer        substation         inspection                      completion of                            Inspectorate   Inspectorate
mission            storage                                                              work




ECOS
Environmental Impact Assessment Report                                      Page   144 of 179
Draft Version – Do not quote




7.3     Institutional Strengthening

The implementation of the project would require an institutional strengthening to secure
adequate execution of the following functions:
        Policy making
        Administration
             o Enforcement
             o Monitoring

Referring to the administration of the POPs issue in the country and in broader sense the
issue of chemical pollution prevention in Moldova in general it would be beneficial to
finance the establishment of an Office of Chemical Safety within the Ministry of
Ecology responsible for managing the problem of chemical safety by coordinating the
implementation of 4 relevant international Conventions.

This Office should work in close cooperation with the Project Implementation Unit (or
PIU could be incorporated within the Chemical Safety Unit) as well as with the Waste
Management Division of the Ministry.

Assuming that Project Implementation Unit (PIU) will be composed from staff with
relevant knowledge and experience in project management this component of
institutional strengthening could be omitted from the list of training to be provided.
Otherwise training on Project management and Logical Framework Approach is needed
to secure the use of appropriate management tool to implement and monitor the project.

All above mentioned actors along with PCB equipment holders and all relevant
monitoring institutions should form the core of a National Chemical Safety
Informational System (Special designed PCB, POPs and other envisaged by 4
Conventions in question chemicals).

While referring to the implementing of the EMP as such the following institutional
arrangements would be required:
        PIU should consider establishment of the Environment Management Group of
         experts to supervise the proper implementation of the mitigation measures and
         monitoring program as well as to transfer knowledge and skills to the local
         counterparts.
        Provide on the job training to the relevant enforcement national institutions (e.g.
         Territorial Environmental Inspections) to build technical expertise in the field of
         environmentally sound POPs management and – in the long run –
         environmentally sound pesticides management in general. Also Inspectors should



ECOS
Environmental Impact Assessment Report                                    Page   145 of 179
Draft Version – Do not quote



         be provided with adequate tools for monitoring and reporting (PCBs test kits,
         Chemical safety Database and PCs in 4 regional Environmental inspections)
        Instruct in the proper techniques of inspections, monitoring, use of monitoring
         equipment, data collection, storage, reporting, etc.

Furthermore, the EMP is usually slightly (or more than that) revised during the initial
stage of project implementation. This job could be done by Environmental Group within
the PIU mentioned above. In both cases, the revision of the EMP will cover the
institutional strengthening issues and the stuff like equipment purchase, training needs
and needs for consulting services will be more specifically identified since at that stage
of project cycle the construction and operational phases are defined in details.

Details on the institutional strengthening correlated with the POPs Project components
and phases of the Mitigation and Monitoring Plan are provided in the tables below.




ECOS
            Environmental Impact Assessment Report                                               Page   146 of 179
            Draft Version – Do not quote



            Institutional Strengthening: Equipment Purchase
                Project Components                                 Type of equipment needed         Number          Unit       Total     Local or         Recipient
                                                                                                    of Units        Cost       Cost    International
                                                                                                                                         Purchase

Component 1: Management and Destruction of POPs
Sub-Component 1.1 Destruction of Stockpiles of
POPs Contaminated Obsolete Pesticides
                                                          ● Decontamination equipment.             TBD          TBD        TBD         Local           * MOD, DES
Activity 1.1.1
                                                          ● Safety equipment for workers.          TBD          TBD        TBD         International   * MOD, DES
Immediate repackaging and centralization of obsolete
                                                          ● Air Quality Sampling Equipment         15           TBD        TBD         Local           * SEI Lab, REI,
pesticides
                                                                                                                                                       Hidrometeo
                                                          ● Decontamination equipment,             included     include    included    included in
Activity 1.1.2.                                           ● Safety equipment for workers           in above     d in       in above    above costs
Repackaging for transportation and final disposal         ● Air quality sampling equipment         costs        above      costs
                                                                                                                costs
Subcomponent 1.2
 Management of PCBs and Destruction of Stockpiles
of Obsolete Capacitors
Activity 1.2.1                                            ● Purchase / Design Software for PCB     1            1500       1500        Local           *CCM, PIU
Inventory of PCB Containing or Contaminated               Inventory database.
Equipment.                                                ● PCB Test kit.                          2500         10         25,000      International   *Equip. Holders
                                                          ● Equipment for PCB analysis by gas      TBD          TBD        TBD         International   *SEI Lab,
                                                          chromatography                                                                               Hidrometeo
Activity 1.2.2                                                                                     -            -          -
Destruction of Obsolete Capacitor Stockpiles
a) Dismantling of 17,300 obsolete capacitors and          ●   Decontamination equipment
packing in closed containers                              ●   Safety equipment
b) Excavation of 2,000 capacitors buried in two pits in   ●   Storage Tanks for drained water      TBD          TBD        TBD         Local
the Vulcanesti substation and packing in closed           ●   Activated carbon filters             TBD          TBD        TBD         Local
containers
c) Shipment and destruction of 19,300 capacitors and
up to 50 tons highly polluted soil
Activity 1.2.3                                            ● Sampling equipment and Gas             TBD          TBD        TBD         Local           SEI Lab,
Feasibility Study of Site Clean-up at Vulcanesti          Chromatography equipment                                                                     Hidrometeo
Substation
TOTAL PER COMPONENT 1                                                                                                      TBD




            ECOS
            Environmental Impact Assessment Report                                                  Page    147 of 179
            Draft Version – Do not quote

            Institutional Strengthening: Training / Study Tours
      Project Structure: Components, sub-                      Type of training             Number of Students       Duration    Venue of       Training    Cost, $US
           components and activities                                                          and Institution           of       Training       provider   (Local and
                                                                                                                     training                               Foreign)

Component 1: Management and Destruction of POPs
Sub-Component 1.1 Destruction of Stockpiles of
POPs Contaminated Obsolete Pesticides
                                                       ● Safety at work in dangerous        ● Hired workers         1 day       On the job   Contractor    No cost
                                                       conditions (toxic substances)        ● Hired workers                     place
Activity 1.1.1 Immediate repackaging and
                                                       ● Emergency preparedness             ● 6 (Regional EI        1 day                                  No cost
centralization of obsolete pesticides
                                                       ● Air Quality sampling               inspectors)             1 day       On the Job   SEI Lab       TBD
                                                       equipment
                                                       ● Safety at work in dangerous        ● Hired workers         1 day       On the job   Contractor    No cost
Activity 1.1.3.
                                                       conditions (toxic substances)                                            place
Repackaging for transportation and final disposal
                                                       ● Emergency preparedness             ● Hired workers
Subcomponent 1.2
Management of PCBs and Destruction of
Stockpiles of Obsolete Capacitors
                                                       ● Training in PCB Inventory          ● Inspectors,           1 day       Chisinau     Local         1550,0
                                                       database use                         Holders’ database                                consultants   $US
                                                       ● Training the SEI inspectors to     keepers.
                                                       assist the holders of equipment to   ● Holders and SEI       1 day       Chisinau     Local
Activity 1.2.1
                                                       undertake the inventory.             inspectors                                       consultant    1550,0
Inventory of PCB Containing or Contaminated
                                                       ● Testing the Transformers                                                                          $US
Equipment.
                                                       training (sampling and inventory     ● Holders of            1 day       Chisianu     Local
                                                       methodology)                         Equipment and SEI                                Consultant    1350,0
                                                                                            inspectors                                                     $US

Activity 1.2.2
Destruction of Obsolete Capacitor Stockpiles
                                                       ● training in the safe methods of    ● Team of workers,      0,5 day     On the       Foreman       No cost
                                                       handling and packaging of            SEI inspectors                      work place
a) Dismantling of 17,300 obsolete capacitors and       capacitors,
packing in closed containers                           ● personnel health and safety
                                                       protection measures, etc.

b) Excavation of 2,000 capacitors buried in two pits   ● Training in filtering the water    ● Team of workers       Half day    On the       Equipment     Included in
in the Vulcanesti substation and packing in closed     through activated carbon filter                                          work place   provider      delivery



            ECOS
            Environmental Impact Assessment Report                                            Page   148 of 179
            Draft Version – Do not quote

      Project Structure: Components, sub-                   Type of training           Number of Students      Duration      Venue of         Training         Cost, $US
           components and activities                                                     and Institution          of         Training         provider        (Local and
                                                                                                               training                                        Foreign)
containers                                                                                                                                                    price
c) Shipment and destruction of 19,300 capacitors
and up to 50 tons highly polluted soil
                                                     ● Training on Sampling and Gas    Sampler technicians                                                    Trained
Activity 1.2.3
                                                     Chromatography equipment          from Hidrometeo,                                                       under
Feasibility Study of Site Clean-up at Vulcanesti
                                                                                       Moldelectrica, SEI                                                     subcompon
Substation
                                                                                                                                                              ent 1.2.1
TOTAL PER COMPONENT 1                                                                                                                                         1,700 $US




            Institutional Strengthening: Consultant Services
Project Structure: Components, sub-components                Type of Service                                      Justification                                Cost, $US
                  and activities                                                                                                                              (Local and
                                                                                                                                                               Foreign)

Component 1: Management and Destruction of POPs
Sub-Component 1.1 Destruction of Stockpiles of
POPs Contaminated Obsolete Pesticides
                                                     Provide consultancy in terms of   In order to minimize the environmental and social risks of the         5,000 $US
                                                     selecting the warehouses aiming   project the selection of the warehouses should be done in
                                                     at the maximum lowering the       accordance with the national standards for toxic substances
                                                     environmental and health risks    storage. The elaborated by EIA Team risk assessment matrix
Activity 1.1.1 Immediate repackaging and
                                                                                       should be applied while selecting the depots.
centralization of obsolete pesticides
                                                                                       Knowledge on national and international environmentally sound
                                                                                       handling of toxic substances stocks standards will be provided to
                                                                                       the local decision-makers.
                                                                                       Recipient of the consultancy: LPA, MOD, DES
Activity 1.1.3.                                      N/A                                                                                                      -
Repackaging for transportation and final disposal
Subcomponent 1.2
Management of PCBs and Destruction of
Stockpiles of Obsolete Capacitors
Activity 1.2.1                                       Development of Detailed           There is no National regulation governing the PCB management in        35,000
Inventory of PCB Containing or Contaminated          Management Plan to prevent        the country yet. The activity 1.2.1 foresees the elaboration of such   $US



            ECOS
             Environmental Impact Assessment Report                                               Page   149 of 179
             Draft Version – Do not quote

Project Structure: Components, sub-components                  Type of Service                                        Justification                               Cost, $US
                  and activities                                                                                                                                 (Local and
                                                                                                                                                                  Foreign)
Equipment.                                             accidents and releases of PCBs.     a regulation. The holders of equipment will have to develop their
                                                                                           own Accident Prevention and Release of PCB Management Plan.
                                                                                           Guideline for elaboration of such a Management Plan will be the
                                                                                           subject of local consultancy.
                                                                                           Recipients: PCB containing equipment holders, MENR, SEI,
                                                                                           Energy sector institutions, etc.
Activity 1.2.2
Destruction of Obsolete Capacitor Stockpiles
a) Dismantling of 17,300 obsolete capacitors and       N/A                                                                                                       -
packing in closed containers
b) Excavation of 2,000 capacitors buried in two pits   N/A                                                                                                       -
in the Vulcanesti substation and packing in closed
containers
c) Shipment and destruction of 19,300 capacitors       N/A                                                                                                       -
and up to 50 tons highly polluted soil
                                                       International Consultancy to        Due to the two incidents of capacitor explosions in 70th , and        250,000
                                                       conduct the site Clean-up           leakage by corrosion of the 33-years old capacitors in Vulcanesti     $US
                                                       Feasibility Study                   substation, the clean-up of extremely contaminated Vulcanesti
                                                                                           station area should be done. Measurements taken in the spring
                                                                                           2005 clearly demonstrate that the PCBs are mobile in the soil and
                                                                                           there is an urgent need for preventing further dissipation of PCBs
                                                                                           to the surroundings.
                                                                                           A feasibility study should anticipate the elaboration of the Clean-
Activity 1.2.3                                                                             up Plan.
Feasibility Study of Site Clean-up at Vulcanesti
Substation                                             Local sub-contractor to deal with   The feasibility study would have to have recent data (more            85,000
                                                       drilling boreholes for              detailed ones and coming from rigorously considered sampling          $US
                                                       groundwater sampling. Program       program covering media other then soil, underground waters for
                                                       for soil, water and steel           instance). This work is recommended to be sub-contracted by
                                                       construction sampling and           Local Engineer, Geology company.
                                                       international samples analysis

                                                       Development of the Remediation      Recommended to be considered tendered locally.                        70,000
                                                       Plan                                                                                                      $US
                                                                                                                                                                 425,000
TOTAL PER COMPONENT 1
                                                                                                                                                                 $US




             ECOS
Environmental Impact Assessment Report                                  Page   150 of 179
Draft Version – Do not quote




8 Public Involvement and Information Disclosure
The Public Consultation and disclosure process has been governed by the rules
established by National Legislation (EE&EIA Law and RPIEDM) and the WB, GEF
OPs. aiming at securing the transparency of decision making and also, to the maximum
extent, raising the role of the local stakeholders in the Project Cycle Management
process’ decision points.

8.1     Public Consultation during Project Preparation

Considering the Sustainable POPs Management project elaboration a logic continuation
of the NIP development process one can say that the public involvement began long
before the formal POPs project cycle starts.

The participatory process during NIP development involved many representatives of
civil society and representatives of interested institutions who endorsed the Document.
Thus, the public involvement within the POPs Project preparation did not start from the
Greenfield and to the considerable extent is built upon the experience and lessons leant
from NIP elaboration. This made the planning of the public involvement process easier
as well as ease it implementation.

Hence, the EA team, in coordination with the SA team and PIU, planned and structured
the process in three steps: Information Dissemination, Identifying the stakeholders
concern, Disclose the decision made with due explanation.

Step 1: Information dissemination
        Pro-active Public Information: On February 8, 2005, the MENR and PIU
         announced national public consultations regarding a draft ToR for EIA and draft
         Table of Content (ToC) for an EIA report, and posted both documents on the
         web-site of the PIU and REC. Announcements were made at the PIU web-site, in
         the media and through the network of REC with access to over 250 local NGOs.
         The PIU sent e-mail invitations to over 150 groups and individuals. Director of
         the PIU and Stockholm Convention National Focal Point were key contact
         persons for public inquiries.
        Public consultations on a draft ToR and ToC for an EIA took place on February
         18th, 2005 with about 30 people in attendance. Presentation on project’s
         objectives, scope and components were made. Also both applicable World Bank
         EA and safeguard policies were presented. Representatives of the Ecological

ECOS
Environmental Impact Assessment Report                                      Page   151 of 179
Draft Version – Do not quote



         Inspection, MENR presented national requirements for an EIA and a state
         ecological expertise. All participants found both drafts to be good quality
         documents which adequately reflected on the scope of the project and
         requirements of Moldovan legislation, and that the project would be beneficial to
         Moldova. The comments are summarized and presented in the public
         consultation minutes (see Annex 3).
        More than a hundred persons from the affected villages were met (randomly)
         during the month of March 2005 to informally discuss and find out their thoughts
         and judgment towards the centralization of the obsolete pesticide in general and
         for how long the POPs warehouse is welcome in their own community. The
         general conclusion which can be drawn is that majority of the persons are against
         the idea to keep the pesticide stored for long time next to their houses. Moreover,
         their wiling to discuss the issue reveals the fact that there is not too much
         patience remained and that they want to know when exactly the pesticides will be
         taken away from their village. It should be also mentioned that this is a rare case
         when people and their mayors talk in unison.
        First notification on access to information: 1 month before the Public
         Consultation Meeting (PCM), published in a nation wide distributed news paper
         “Moldova Suverana” (all the mayoralties in Moldova are subscribed to this
         newspaper), a notification on access to information a) disclosed the information
         on POPs Project objectives and outcomes and invited persons to submit ideas,
         comments and proposals regarding the POPs Project objectives and planned
         actions. The published notification has elucidated the following: a) the list of
         relevant information available, b) where the information is stored, c) summary of
         the POPs Project and the description of the present Project Cycle stage (
         particularly the objectives, the scopes and preliminary findings of both EIA and
         SA Studies), d) the ways the people can get the information and submit their
         ideas, suggestions, comments, concerns - i.e. via mail (address), hotline (phone
         number), e-mail (e-address), POPs web-site (web address), name of the
         responsible institution/officer and the time limits when suggestions and opinions
         could be forwarded.
        Pro-active targeted notification: Phone conversation with the mayors of all 37
         sites in question were held to stress their attention about the published
         notification and invite them - in line with EE&EIA Law - to post the advertising
         at the publicly accessible places (usually on so called “Table of Announcements”
         mandatory present in each mayoralty in Moldova) as well as to identify one
         person (being not a representative of the local authorities) to participate on the
         community’s behalf in the second Public Consultation Meeting.

Step 2. Identifying the stakeholders’ concern
        In coordination with the SA Team and PIU the list of participants to the Public
         Consultation Meeting has been made: one representative of the local authorities
ECOS
Environmental Impact Assessment Report                                     Page   152 of 179
Draft Version – Do not quote



         from each site (mayor or vice-mayor), one representative acting on behalf of the
         concerned public, the representatives from Government, the MENR, local NGOs,
         academic institutions, WB projects, experts.
        2 weeks before the PCM the invitations to attend the Public Consultation
         Meeting on the 19th of May 2005 in Chisinau (Enclosed the invitation contained
         the Summary of Anticipated Environmental Impacts - a short, written in every
         day’s language 5 page description of the findings of the EA Study) have been
         sent to the affected communities. Also, representatives from 20 NGOs have been
         invited.
        Public consultations on Draft EA Study and Social Assessment took place on
         May 19th, 2005 at the Ministry of Ecology in Chisinau with about 60 people in
         attendance. The minutes of Meeting are attached to this report as Annex 3.
        The received views and suggestions have been considered and those relevant
         reflected in the Final version of the EA Report.

Step3. Disclosing the decision made with due explanation.
        The final version of the EA (containing the Minutes of PCM annexed) is placed
         on the Web-site, and the letters with the decision made (the project strategy –
         alternative chosen) with due explanations of the reasons the decision is based on
         have been sent by regular mail to all participants at the PCM.

8.2     Public Involvement during Implementation

There are three main instruments of public participation during the environmental
decision making: 1) access to relevant information, 2) the right to participate 3) the right
to complain and appeal.

These instruments should form the foundation of the Public Participation Plan (PPP) to
be developed once the PAD is approved and detailed Project design is completed.

The public involvement during the project implementation is seen as a process fitting
some basics and simple principles that have to be followed while developing the PPP.

They are:
        Clearly identify the decision making points and link public to them.
        Correlate the PPP with the local legislation (and try to use also common sense if
         there is lack of some legal provisions, e.g. Moldavian legislation do not oblige
         the developer to explain to people the reason of taking a particular decision as
         well as to provide the information about how to submit complains (the right to
         appeal)
        Make sure the stakeholders are provided with relevant, reliable and up-dated
         information.

ECOS
Environmental Impact Assessment Report                                    Page   153 of 179
Draft Version – Do not quote



        Make sure the main groups involved are provided with the possibility to express
         its opinion.
        Make sure that public has been heard and make sure that the public has this sense
         too.
        Reserve enough funds to fit the scope of the PPP as well as set aside some
         financial resources which might be needed to cover the cost of independent
         public assessment of the project (project implementation).

The decision points during the project implementation will refer mainly to the procedure
foreseen by national and international laws and regulation to govern the project
activities.

At least the plan will involve public to participate in the planning of the (i) impacts
monitoring and mitigation measures during the operational stages; then at the mid point
of project implementation the public will be involved in the (ii) mid-term environmental,
economic, and social impacts assessment of the project; and finally the public
involvement will be secured (iii) in project results evaluation by interviewing public
opinion after the project is complete.

All above will be achieved by using the large variety of methods of public involvement,
like site visits, discussions, round tables, workshops, investigation of specific issues,
interviews, etc. The PPP will form an integral part of the Project Operation Management
Plan.




ECOS
Environmental Impact Assessment Report                                     Page   154 of 179
Draft Version – Do not quote




9 Conclusions
The project is considered to be an essential element in ensuring a safer environment for
Moldovan population and in assisting the country to comply with its international
obligations in the framework of the Stockholm Convention on POPs. In the same time,
improving environment conditions by mitigating POPs-related problem can help to
stimulate economic growth, reduce poverty and contribute to sustainable development,
especially in rural areas.

The effective execution and mainstreaming the EMP into project activities, and
adherence to the principles and framework outlined throughout this document will allow
the considerable potential social and environmental benefits of the project to be realized.
Through direct clean-up activities the project can make a significant contribution to
environmental and human health issues, while capacity building, education and
awareness will play a role in ensuring that the problem of POPs stocks does not reoccur.
Long-term and potentially nationwide indirect benefits are anticipated as a result of
enhanced capacity and skills that the Project will develop as a result of its capacity-
building programs.

The potential risks represented by some of the project activities should be carefully
considered and effectively managed. The need to comply with international conventions
and national legislation on hazardous wastes and to follow best management practices is
therefore paramount in ensuring safe and diligent implementation. The effective
implementation of measures contained in the EA and the compliance with international
and national conventions, legislation and codes must then be monitored and enforced.

Implementation of the project with well-defined EMP, with adequately budgeted and
clearly defined mitigation, monitoring and capacity building activities and institutional
responsibilities, will ensure inter alia: avoiding, preventing and mitigating potential
adverse socio-environmental impacts and enhancing project’s environmental benefits;
cleaner and safe waters and soils, agricultural products; protecting biodiversity;
improving access to global markets of local products; increasing aesthetical and
economic values of various environmental media and property, and stimulating tourism.




ECOS
Environmental Impact Assessment Report   Page   155 of 179
Draft Version – Do not quote




ANNEXES




ECOS
Environmental Impact Assessment Report                                    Page    156 of 179
Draft Version – Do not quote




Annex 1. List of Preparers

Project Developers:

Ruslan Melian, PhD, team leader

Valeriu Mosanu, PhD, environmental expert

Corneliu Busuioc, M. Sc., institutional/stakeholder/public participation expert

Victor Bujac, M.Sc., environmental engineer

Tatiana Belous, PhD, legal/economic expert

Field Team:

Veaceslav Purcic

Mihai Carabet

Petru Prunici

Vitalie Stepanov

Ion Mironov

Victor Ciocarlan




ECOS
Environmental Impact Assessment Report                                 Page   157 of 179
Draft Version – Do not quote




Annex 2. References

    1. Atlas of the Republic of Moldova, 1978, 1990.

    2. Biological Diversity Conservation. National Strategy and Action Plan, 2002.

    3. Disposal of bulk quantities of obsolete pesticides in developing countries.
       Provisional technical guidelines. UNEP, WHO, FAO. 1996.

    4. Economic Growth and Poverty Reduction Strategy Paper (2004-2006),
       Government of Moldova, 2004.

    5. Flood Risk in Moldova, Acvaproiect, 2002.

    6. JICA EIA study for water supply of the northern part of Moldova, 2002.

    7. Market Access and Rural Services Project, Sectoral Environmental Review,
       draft, 2000.

    8. Water Cadastre of the Republic of Moldova, 1998

    9. Moldova: Public Economic Management Review, Report No. 25423-MD,
       Poverty Reduction and Economic Management Unit, Europe and Central Asia
       Region, The World Bank, Washington, DC, February 20, 2003, p.4.

    10. National Implementation Plan for the Stockholm Convention on Persistent
        Organic Pollutants, 2004.

    11. Prevention and Disposal of Obsolete Pesticides Stocks in Ethiopia,
        Programmatic Environmental Assessment, 2004.

    12. Problems of Flooding, European Associated Center on Flood Problems in
        Moldova, Acvaproiect, 2001.

    13. Prut River Basin Management Project, TACIS, 2000

    14. Prut River Tributaries: Environmental Protection Review. Protection Strategy
        and Options, TACIS, 2001

    15. Red Book of Moldova, 2001.
ECOS
Environmental Impact Assessment Report                                   Page   158 of 179
Draft Version – Do not quote



    16. Regional Study: Managing Natural Disasters in Europe and Central Asia, World
        Bank perspective, Country Risk Template (Republic of Moldova), World Bank,
        2003.

    17. Sectoral Environmental Review. Market Access and Rural Services Project,
        2000

    18. State of the Environment Report, 2003.

    19. Statistical Yearbook, Department of Statistics and Sociology, 2004.

    20. Study of the Quality of Rural Drinking Water, WB, 1997.

    21. UNEP, Basel Convention Series. SBC Nr. 2005 / 1 & 2.

    22. Volneanschi A., Romanciuc P. Hygienic evaluation of the content of
        organochlorinated pesticides in breast milk (Rom.) Proceedings of the III
        Congress of hygienists, microbiologists, epidemiologists and parazitologists of
        the Republic of Moldova, Chisinau, 1992. P. 68-70.




ECOS
Environmental Impact Assessment Report                                   Page   159 of 179
Draft Version – Do not quote




Annex 3. Record of Public Consultations Meetings
   Meeting Minutes on Public Consultation on draft ToR/ToC for the EIA study


On February 8, 2005, the MENR and PIU announced national public consultations
regarding a draft ToR for EIA and draft Table of Content (ToC) for an EIA report, and
posted both documents on the web-site of the PIU and Regional Environmental Center
(REC). Announcements were made at the PIU web-site, in the media and through the
network of a REC with access to over 250 local NGOs. PIU sent e-mail invitations to
over 150 groups and individuals. Director of the PIU and Stockholm Convention
National Focal Point were key contact persons for public inquiries.

Public consultations on a draft ToR and ToC for an EIA took place on February 18th,
2005 with about 40 people in attendance. The Press Agencies were represented by
BASA-Press and Radio-Moldova Channel 1.

Mr. Valentin Plesca, Project manager made a presentation on project’s objectives, scope
and components. Mr. Andrei Barannik presented both drafts and explained the
applicable World Bank EA and safeguard policies. Representatives of the Inspection,
MENR presented national requirements for an EIA and a state ecological expertise.

All participants found both drafts to be good quality documents which adequately
reflected on the scope of the project and requirements of Moldovan legislation, and that
the project would be beneficial to Moldova. Few comments are summarized below:

1. Mr. Ilya Trombitchi, Eco-TIRAS representative, suggested the project shall take
higher aims, i.e. seek to ensure final destruction of POPs pesticides and PCB, and not be
limited to proposed repackaging and long-term storage and such approach would only
delay the final solution and may even increase the threat POPs pose to the environment
and population (Mr. Barannik replied that an EIA will consider all feasible alternatives)

2. Mr. Vladimir Garaba, MEM Chisinau representative, suggested that all population of
Moldova shall participate in consultations (Mr. Barannik replied that Moldovan
population has actively participated in preparing the POPs NIP approved by the
government, and the proposed project addresses priority issues identified in the NIP. It
was further explained that public consultation should first take place with potentially
directly affected local population and local NGOs, and that SA will identify concerns
and solicit suggestions from key stakeholders thus taking into account views of broad

ECOS
Environmental Impact Assessment Report                                     Page   160 of 179
Draft Version – Do not quote



societal groups. The project will envision active public participation in its
implementation)

3. Mrs. Lilia Curchi, Natura News Paper, suggested that EIA should support public
awareness. Another speaker suggested that public awareness was increasing thanks to
environmental media, but was still low and inadequate (Mr. Barannik replied that the
“pesticide and institutional components will address both issues, and Mr. Simoncic and
local consultants are actively working with diverse stakeholders to develop the scope of
relared project component.)

4. Mr. Trombitchi suggested that Transnistria has significant POPs-related problems and
inquired why it had not been included in the project (Mr. Barannik replied that GEF and
the World Bank responded to the request from the government of Moldova which
identified priorities it was interested to address, and this did not include activities in
separatists region.)

5. Mr. Arcadie Leahu, Laboratory of State Ecological Inspection representative
suggested that water pollution an erosion should be taken into consideration during EA
preparation (Mr. Barannik replied that it was standard practice for EA to consider all
factors which could have an impact on the successful project implementation.)

6. Ms. Lilia Curchi suggested that there was an increasing awareness of the population,
particularly school children on POPs issues, due to activities of environmental media,
but this awareness was still low and inadequate, and proposed more attention to be paid
to this activity in the project design (Mr. Barannik replied that the project will include a
component that will seek to address related priority issues.)

7. one speaker suggested that public environmental management, legislation and level of
knowledge regarding international best practice was inadequate and low (Mr. Barannik
replied that technical pesticides, PCB and institutional component will seek to address
these shortcoming and propose measure to strengthen relevant institutions, improve
legislation and ensure technology and knowledge transfer.)

8. Mr. Mogoreanu noted that Moldovan legislation stipulated public expertise of the
project and that World Bank on previous occasions refused financing for it (Mr.
Barannik replied it was a good stipulation and according to the law it was up to NGOs to
initiate it and arrange for its financing.)

9. Ms. Tatiana Stratulat, National Scientific and Practical Center for Preventive
Medicine, Ministry of Health suggested that the ToC suggested too many alternatives for
consideration (Mr. Barannik replied that local EA consultants may arrange alternatives
and analyze them according by various types and criteria, but shall include the following
key scenarios: “with and without project,” long-term storage and final destruction within
the framework of socio-environmental and cost-benefit analysis.)

ECOS
Environmental Impact Assessment Report                                     Page   161 of 179
Draft Version – Do not quote



10. Mr. Ruslan Melian, ONG ECOS representative, suggested that the sites from which
POPs pesticides would collect to a central storage would need rehabilitation (Mr.
Barannik replied that during project preparation the scope and responsibilities for such
rehabilitation would be elaborated.)

11. Mr. Gheorghe Copacinschi, Chief of Laboratory, State Ecological Inspection
representative, stressed the importance of environmental monitoring and performance
indicators (Mr. Barannik replied that World Bank EA policy required elaboration of an
environmental management plan which would include targeted environmental
monitoring and standards, and necessary indicators, including for project performance.)

         Meeting Minutes of Public Consultation on draft EA and SA Reports
                              (Chisinau, 19 May 2005)

On April 28, 2005, the MENR and PIU announced national public consultations
regarding the draft report on Environmental Impact Assessment and the draft report on
Social Assessment. Announcements were made at the PIU web site, in the biggest
national newspaper and through the network of REC with access to over 250 local
NGOs. PIU sent invitations by mail to all Mayors and representatives of local public
from 37 settlements/sites where obsolete pesticides are/are to be centralized. Director of
the PIU was the key contact person for public inquiries.

Public consultations on the draft EIA and SA reports took place on 19 May 2005 with
about 50 people in attendance. The mass media were represented by Radio Moldova
Channel 1.

Mr. Valentin Plesca, Project manager, made a presentation on project’s objectives, scope
and components. Mr. Corneliu Busuioc, member of EIA team, presented the main
findings of the environmental assessment, implemented by ECOS. Mr. Vladimir Haraba,
member of SA team, presented the results of the social assessment, implemented by
MEM.

The participants found both reports to be comprehensive and good quality documents
and the project would be beneficial to Moldova. Many of participants took part in
discussions and their comments are summarized below.

1. Nicolai Curu, Mayor of village Gaidar, where 68 tons of obsolete pesticides are
currently stored, expressed the worries of the local population about the present
situation, which is not sustainable. The facility has been designated by the authorities as
an intermediary and temporary solution, despite the relatively poor condition of the
warehouse and the opposition of the locals. The pesticides are stored in improper
conditions (only bags, no barrels) and the locals are concerned about the perpetuation of
this situation. He suggested that the evacuation of pesticides from Gaidar store has to be
urged.

ECOS
Environmental Impact Assessment Report                                     Page   162 of 179
Draft Version – Do not quote



Andrei Barannik replied that the GRM made several attempts to solve the problem but
lacks finance and capacity, therefore it requested GEF assistance. The GRM plans to
finalize the centralization by the end of 2005. It can probably be urged through mass
media or even in court. As far as the GEF is concerned, the activity of the local project
team allowed shortening the preparatory project phase by 6 months. Now the GRM will
have to take a decision concerning the GEF project; further this will have to be endorsed
by the World Bank (as the implementing institution) and, if things go well, the project
can start at the beginning of 2006.

We know that the GRM cannot implement its own decisions but this is the problem of
Moldova, the GEF only can assist the GRM in this. We have to do it right. It is very
clear that the risks will increase in time and a final disposal solution has to be found for
this problem.

2. Tatiana Ghilan, Mayor of village Tudora reported that over 200 tons of obsolete
pesticides were deposited in the local store. The authorities promised to find a final
solution for these pesticides and to evacuate the facility within 1.5-2 years but did not
keep their promise. During the storage period the local authorities did everything they
could to maintain the facility in good condition, in order to minimize the risks for the
public. The Mayor suggested in this respect that, when prioritizing the process of
repackaging for transportation and final disposal, the amount of obsolete pesticides
stored as well as the ‘good housekeeping’ practices of the local authorities have to be
considered as prioritization criteria.

Ruslan Melian (ECOS) mentioned that despite good status of the building there are other
risk factors in Tudora like close sensitive areas (forest at 50 m) or landscape
characteristics which facilitate pesticide transport to the surface and ground waters. This
increases the index of integrated risk and makes earlier involvement of the Tudora site in
the project activities more likely.

3. Col. Tudor Vasilcov (DES) had a reaction to the speech of the Mayor of Gaidar. He
brought some clarifications about the works implemented by DES at the Gaidar site. He
reported that Gaidar facility was only an intermediary solution on the way to the
designated rayon storage at Bugeac, Comrat. This temporary solution was proposed (and
imposed) due to a number of factors: (i) most of the currently stored 68 tons were stored
there before the centralization process started; (ii) DES was forced (by the authorities) to
implement the works quickly, despite the lack of plastic barrels for repackaging; and (iii)
the works were implemented under difficult winter conditions. Despite that,
implemented works improved the general situation at Gaidar site since prior to the DES
actions, the obsolete pesticides were just dumped on the floor and now they are packed
in bags and carefully stored. Col. Vasilcov informed that the Gaidar site is a priority
concern and immediately after MAFI supplies the plastic barrels, the bags with


ECOS
Environmental Impact Assessment Report                                     Page   163 of 179
Draft Version – Do not quote



pesticides stored at Gaidar will be put into barrels and evacuated to the designated rayon
site in Bugeac, Comrat.

4. Petr Nezalizov, Mayor of Bugeac, Comrat suggested that designated rayon storage
facility is a matter of permanent concern and a final solution for the obsolete pesticides
problems has to be found as soon as possible since the current situation is not
sustainable. He also acknowledged the conclusions of environmental assessment and
agreed that export of obsolete pesticides to a third country for final disposal is the best
option.

5. Ilia Trombitki (NGO Eco-Tiras) suggested that a carefully designed and controlled
landfill should be seriously considered as a project alternative. In his opinion, a proper
site could be identified even in such a densely populated country as Moldova and this
solution could be cheaper than the transportation for destruction in a third country.
Besides, the latter alternative has a moral component in the sense that any country has to
try solving its own problems at home rather than exporting them to other countries and
risking to induce protests from their population.

Andrei Barannik replied that the landfill alternative was considered during the EA Study
but was not recommended due to a number of factors, which were reported by the EIA
team.

6. Vistor Stratila (NGO Eco-Lex) suggested that, two years ago, the academician Tudor
Lupascu offered to build a mobile incineration unit for hazardous waste, meeting all
safety and environmental standards, at a cost of 500,000 MDL (some 40,000 USD). He
asked whether this offer was seriously considered.

Several participants made remarks in the sense that this proposal was totally unrealistic
and unfeasible. Col. Ion Doroban (MOD) reported that the Ministry had recent contacts
with Norwegian experts who recommended the high-temperature incineration as the
most frequently used, safest and cost-efficient current destruction method for hazardous
chemicals.

7. Ion Alexandreanu, Mayor of Cimislia suggested that activities undertaken by GRM
were not carefully designed and planned. For example, in Cimislia some 150 tons of
obsolete pesticides are stored but not all of them are properly packed; due to improper
storage of unidentified pesticides there were cases of self-ignition, etc.

Vladimir Haraba (MEM, Chisinau) replied that during this year the National
Environmental Fund (so far, the main internal financing source) allocated only 0.5
million MDL out of 4 million MDL planned for this year but this is only part of the
problem. The limited resources are usually dispersed for country-wide actions instead of
focusing the efforts on finalizing the works rayon by rayon, with clear, tangible and
measurable results.

ECOS
Environmental Impact Assessment Report                                     Page   164 of 179
Draft Version – Do not quote



8. Gheorghe Grecu, Mayor of Oniscani, Calarasi also stressed that GRM decision was
not well planned (e.g. no provisions for guarding and fencing were made). He remarked
that the problem will not stop to exist after the evacuation of current obsolete pesticides
stockpiles if it will not be accompanied by wider pesticide management strategies and
prevention measures.

9. One NGO representative asked about the future of emptied old pesticide stores.

Andrei Barannik replied that the project does not foresee clean-up activities at the old
sites due to focus on eliminating the immediate current threat and budget constraints.
However, the EA recommends the GRM to implement necessary low-cost measures in
order to limit the current and residual risks. The project will provide resources for
monitoring at the old sites.

10. Rodica Iordanov (Milieukontakt) stressed that problems can occur at the locations
designated for centralized storage where the works have not started yet, due to the public
opposition. The World Bank, together with GRM, should think of developing awareness
programs and creating incentives for local communities in order to smooth the
centralization. She asked whether the project foresees the disposal of PCBs (along with
obsolete pesticides) and what will be done with the pesticide waste (packaging materials,
contaminated dust, etc).

Andrei Barannik replied that this is the problem of Moldova. The GEF and World Bank
can assist but this is Moldova that has the responsibility. The efforts should be
concentrated to solve the problem gradually. The inclusion of clean-up activities may
increase the project costs by US$ 4-5 million and this could be not endorsed by the GEF
Board.

11. Nicolae Grosu (NGO Renasterea, Talmaza, Stefan Voda) stressed the problem of
the obsolete pesticides currently stored in private households.

Col. Ion Daraban said that the population in the settlements where repackaging and
transportation of pesticides was implemented has been informed about ongoing activities
and consequently people brought significant amounts of obsolete household pesticides
for repackaging. This explains the fact that reported amounts of pesticides repackaged
by MOD and DES significantly exceeded the amounts reported by previous inventories.

Col. Daraban reported about the state of implementation of the last GRM Decision on
centralized collection and safe disposal of obsolete pesticides. MOD (together with
DES) was appointed as the implementing agency. MOD is now in advanced stage of
discussions concerning a project financed by NATO. Twelve NATO countries expressed
their commitment to contribute to the project including 7 countries contributing concrete
amounts of money. The project has four components: (i) centralization; (ii)
identification; (iii) destruction; and (iv) decontamination.

ECOS
Environmental Impact Assessment Report                                      Page   165 of 179
Draft Version – Do not quote



(i) The centralization phase is now 65% accomplished. In the same time, it must be
stressed that obsolete pesticides are mixed. (ii) In order to define the suitable destruction
method, NATO allocated 143,000 Euro for pesticides identification. The tender for
equipment procurement is under way. The identification phase could last two years. (iii)
There were talks with Norway and the French firm Lafarge (owner of a big cement
factory in Moldova) concerning suitable destruction methods. The option of incineration
in cement kilns was seriously considered. (iv) The old emptied storage facilities are a
source of environmental contamination that should be dealt with. The walls and the floor
of the stores are heavily contaminated and pose health and environmental risks. In the
first phase, the buildings should be isolated using simple methods. The discussions with
NATO are done on behalf of the GRM, and are instrumented via a coordination
interdisciplinary group involving all stakeholder institutions (including MENR).

12. Vladimir Garaba (MEM, Chisinau) expressed his disappointment about the fact that
no representatives of the civil society were invited to participate in the meetings of this
group and the public was not informed about those discussions and decisions.

13. Valentina Jamba (MEM, Soroca) suggested that apparently the World Bank and the
NATO project develop independently and this is totally wrong. It would be normal for
them to cooperate in order to efficiently use the limited resources (e.g. repackaging,
transportation and disposal to be done by one project and remediation of old sites, by
another). She also expressed her discontent as regards the potential incineration of
obsolete pesticides at the cement factory in Rezina and said she would organize public
protests if the authorities would try to do it.

14. Gheorghe Grecu, Mayor of village Oniscani stressed the need for introducing POPs
issues in school programs.




ECOS
Environmental Impact Assessment Report                                       Page   166 of 179
Draft Version – Do not quote




Annex 4. Contents of the Technical Appendix (in a
separate volume)
A.      Check-list for evaluation of selected obsolete pesticides storage facilities status

B.      Criteria for selection of obsolete pesticides warehouses to be evaluated

C.      Baseline data rayon by rayon (description of the environment; data on obsolete
        pesticides stored; reports of the field teams on the investigation of obsolete
        pesticides storage sites)

D.      Survey of electrical sub-stations holding PCB-containing capacitors

E.      Data on soil contamination with POPs




ECOS
Environmental Impact Assessment Report                                                Page   167 of 179
Draft Version – Do not quote




Annex 5. Comparative review of WB Operational Policies, relevant Moldovan and EU
legislation
World Bank Safeguard          Relevant Moldovan Legislation          International Agreements           EU Legislation (selected and related to the scope of the project)
Policies                                                                ratified by Moldova
                                 On Local Public                    Convention On                      REGULATION (EC) No 2493/2000 OF THE EUROPEAN
OP 4.00: Environmental            Administration – March 18,          Environmental Impact                PARLIAMENT AND OF THE COUNCIL of 7 November2000 on
and Social Safeguard              2003                                Assessment in a                     measures to promote the full integration of the environmental
Policies—Policy                  On Licensing of Certain             Transboundary Context               dimension in the development process of developing countries
Objectives and                    Types of Activities – July         Convention On Long-range           Council Regulation (EEC) No 793/93 of 23 March 1993 on the
Operational Principles &          30, 2001                            Transboundary Air Pollution         evaluation and control of the risks of existing substances
OP/BP 4.00: Piloting the         On Industrial Safety of             (LRTAP)                            Regulation (EC) No 850/2004 of the European Parliament and of
                                  Dangerous Industrial Objects       Protocol on Persistent              the Council of 29 April 2004on persistent organic pollutants and
Use of Borrower Systems
                                  – February 11, 2000                 Organic Pollutants (LRTAP           amending Directive 79/117/EEC
to Address Environmental
                                 On Standardization – April          POPs)                              DIRECTIVE 1999/45/EC OF THE EUROPEAN PARLIAMENT
and Social Safeguard              12, 2000                           Convention On the                   AND OF THE COUNCIL of 31 May 1999 concerning the
Issues in Bank-Supported         On Industrial Safety of             Transboundary Effects of            approximation of the laws, regulations and administrative
Projects – March 2005             Dangerous Industrial Objects        Industrial Accidents                provisions of the Member States relating to the classification,
                                  – February 11, 2000                Convention On the Control           packaging and labelling of dangerous preparations (Consolidated)
                                 On Drinking Water –                 of Transboundary                   Council Directive 96/61/EC of 24 September 1996 concerning
                                  February 10, 1999                   Movements of Hazardous              integrated pollution prevention and control
                                 On Hydro-meteorological             Wastes and their Disposal          Council Directive 88/347/EEC of 16 June 1988 amending Annex
                                  Activity – February 25, 1998       ILO C155 Occupational               II to Directive 86/280/EEC on limit values and quality objectives
                                 On Protection of                    Safety and Health                   for discharges of certain dangerous substances included in List I of
                                  Atmospheric Air– December           Convention                          the Annex to Directive 76/464/EEC (Consolidated)
                                  17, 1997                           ILO C184 Safety and Health         Council Directive 80/68/EEC of 17 December 1979 on the
                                 On Wastes from Production           in Agriculture Convention           protection of groundwater against pollution caused by certain
                                  and Consumption – October                                               dangerous substances (Consolidated)
                                  9, 1997                                                                Council Directive 76/464/EEC of 4 May 1976 on pollution caused
                                 On Regime of Hazardous                                                  by certain dangerous substances discharged into the aquatic
                                  Products and Substances –                                               environment of the Community (Consolidated)
                                  July 3, 1997                                                           REGULATION (EC) No 304/2003 OF THE EUROPEAN
                                 On Ecological Expertise and                                             PARLIAMENT AND OF THE COUCIL of 28 January 2003

ECOS
Environmental Impact Assessment Report                                             Page   168 of 179
Draft Version – Do not quote

                                  Environmental Impact                                                 concerning the export and import of dangerous chemicals
                                  Assessment – May 29, 1996                                            (Consolidated)
                                 On Fire Safety – November                                           Council Directive 96/82/EC of 9 December 1996 on the control of
                                  9, 1994                                                              major-accident hazards involving dangerous substances
                                 Code on Subterranean                                                Council Directive 94/55/EC as announced in Commission
                                  Resources – June 18, 1993                                            Directive 2001/7/EC adapting for the third time to technical
                                 On Environmental Protection                                          progress Council Directive 94/55/EC on the approximation of the
                                  – June 16, 1993                                                      laws of the Member States with regard to the transport of
                                                                                                       dangerous goods by road
                                                                                                      Council Resolution of 16 June 1988 concerning export from
                                                                                                       and import into the Community of certain dangerous
                                                                                                       chemicals

                                                                                                      Council Directive 75/442/EEC of 15 July 1975 on waste

                                                                                                      European Parliament and Council Directive 94/62/EC of 20
                                                                                                       December 1994 on packaging and packaging waste

                                                                                                      Council Directive 96/59/EC of 16 September 1996 on the
                                                                                                       disposal of polychlorinated biphenyls and polychlorinated
                                                                                                       terphenyls (PCB/PCT)
                                                                                                      Directive 2000/76/EC of the European Parliament and of the
                                                                                                       Council of 4 December 2000 on the incineration of waste
                                                                                                      Council Directive 94/67/EC of 16 December 1994 on the
                                                                                                       incineration of hazardous waste
                                                                                                      Council Directive 89/429/EEC of 21 June 1989 on the reduction of
                                                                                                       air pollution from existing municipal waste-incineration plants
                                                                                                      Council Directive 91/689/EEC of 12 December 1991 on hazardous
                                                                                                       waste


                                 On Ecological Expertise and      Convention On                     DIRECTIVE 2001/42/EC OF THE EUROPEAN PARLIAMENT
OP/BP 4.01:                       Environmental Impact              Environmental Impact               AND OF THE COUNCIL of 27 June 2001 on the assessment of
Environmental                     Assessment – May 19, 1996         Assessment in a                    the effects of certain plans and programmes on the environment
Assessment – January             On Health Protection – June       Transboundary Context             Council Directive 97/11/EC of 3 March 1997 amending Directive
1999 as revised August            15, 1995                                                               85/337/EEC on the assessment of the effects of certain public
2004                             On Environmental Protection                                            and private projects on the environment
                                  – June 16, 1993
                                                                                                      Council Directive 85/337/EEC of 27 June 1985 on the assessment

ECOS
Environmental Impact Assessment Report                                                Page   169 of 179
Draft Version – Do not quote

                                 On Sanitary-epidemiological                                             of the effects of certain public and private projects on the
                                  Well-being of the Population                                            environment (Consolidated)
                                  – June 16, 1993                                                        Commission Regulation (EC) No 1488/94 of 28 June 1994 laying
                                                                                                          down the principles for the assessment of risks to man and the
                                                                                                          environment of existing substances in accordance with Council
                                                                                                          Regulation (EEC) No 793/93
                                                                                                         Commission Directive 93/67/EEC of 20 July 1993 laying down
                                                                                                          the principles for assessment of risks to man and the environment
                                                                                                          of substances notified in accordance with Council Directive
                                                                                                          67/548/EEC
                                 On Fund for Natural                Convention on Biological           COUNCIL DIRECTIVE 92/43/EEC of 21 May 1992 on the
OP/BP 4.04: Natural               Territories’ Protected by the       Diversity and Cartagena             conservation of natural habitats and of wild fauna and flora
Habitats – June 2001 as           State – February 25, 1998           Protocol on Biosafety
revised August 2004              On Natural Resources –             Convention on International
                                  February 6, 1997                    Trade in Endangered Species
                                 On Fauna – April 27, 1995           of Wild Fauna and Flora
                                 On Environmental Protection         (CITES)
                                  – June 16, 1993                    UN Convention on
                                 Land Code – December 25,            Biological Diversity
                                  1991                               Convention on Wetlands of
                                                                      International Importance
                                                                      especially as Waterfowl
                                                                      Habitat (RAMSAR)
                                                                     COE Convention on the
                                                                      Conservation of European
                                                                      Wildlife and Natural
                                                                      Habitats
                                                                     European Landscape
                                                                      Convention


                                 On Biological Security             Rotterdam Convention on
OP 4.09: Pest                     (Safety) – 21 December              the Prior Informed Consent
Management – December             2001                                Procedure for Certain
1998                             On Plant Protection –               Hazardous Chemicals and
                                  October 1, 1999                     Pesticides in International
                                 On Phytosanitary Quarantine         Trade
                                  – June 22, 1995                    ILO C184 Safety and Health
                                 On Environmental Protection         in Agriculture Convention
                                  – June 16, 1993


ECOS
Environmental Impact Assessment Report                                               Page   170 of 179
Draft Version – Do not quote




OP/BP 4.12: Involuntary
Resettlement – December
2001
                                                                   UN International Covenant
OD 4.20: Indigenous                                                 on Civil and Political Rights
Peoples – September 1991                                           UN International Covenant
                                                                    on Economic, Social and
                                                                    Cultural Rights
                                                                   UN Convention on the
                                                                    Rights of the Child
                                                                   COE Convention for the
                                                                    Protection of Human Rights
                                                                    and Fundamental Freedoms
                                                                   COE Framework Convention
                                                                    for the Protection of National
                                                                    Minorities
                                 Forestry Code –June 21,          Convention on Biological
OP 4.36: Forests –                1996                              Diversity
November 2002 as revised         On Environmental Protection
2004                              – June 16, 1993


                                 On Environmental Protection
OP/BP 4.37: Safety of             – June 16, 1993
Dams – October 2001

                                 On Water Protection Zones        UNECE Convention On the             DIRECTIVE 2000/60/EC OF THE EUROPEAN PARLIAMENT
OP/BP 7.50: Projects in           and Strips of Rivers and          Protection and Use of                AND OF THE COUNCIL of 23 October 2000 establishing a
International Waters –            Water Bodies – April 27,          Transboundary Watercourse            framework for Community action in the field of water policy
June 2001                         1995                              and International Lakes              (Consolidated)
                                 Water Code – June 22, 1993       Protocol on Water and               COUNCIL DIRECTIVE 98/83/EC of 3 November 1998 on the
                                 On Environmental Protection       Health to the UNECE                  quality of water intended for human consumption (Consolidated)
                                  – June 16, 1993                   Convention On the
                                                                    Protection and Use of
                                                                    Transboundary Watercourse
                                                                    and International Lakes
                                                                   Convention on Cooperation

ECOS
Environmental Impact Assessment Report                                               Page   171 of 179
Draft Version – Do not quote

                                                                    for the Protection and
                                                                    Sustainable Use of the
                                                                    Danube River
                                                                   Convention on the Protection
                                                                    of the Black Sea Against
                                                                    Pollution



OP/BP 7.60: Projects in
Disputed Areas – June
2001
                                 On Monuments Protection –        UNESCO Convention
OPN 11.03: Cultural               June 22, 1993                     Concerning the Protection of
Property – September             On Environmental Protection       the World Cultural and
1986                              – June 16, 1993                   Natural Heritage
                                                                  COE European Cultural
                                                                    Convention
                                                                   COE European Convention
                                                                    on the Protection of the
                                                                    Archaeological Heritage
                                                                    (Revised)


                                 On Access to Information –       UNECE Convention On                 DIRECTIVE 2003/4/EC OF THE EUROPEAN PARLIAMENT
The World Bank Policy             May 11, 2000                      Access to Information,               AND OF THE COUNCIL of 28 January 2003 on public access to
on Disclosure of                 On Environmental Protection       Public Participation in              environmental information and repealing Council Directive
Information                       – June 16, 1993                   Decision Making and Access           90/313/EEC
                                                                    to Justice in Environmental         DIRECTIVE 2003/35/EC OF THE EUROPEAN PARLIAMENT
                                                                    Matters                              AND OF THE COUNCIL of 26 May 2003 providing for public
                                                                                                         participation in respect of the drawing up of certain plans and
                                                                                                         programmes relating to the environment and amending with regard
                                                                                                         to public participation and access to justice Council Directives
                                                                                                         85/337/EEC and 96/61/EC




ECOS
Environmental Impact Assessment Report                                                     Page   172 of 179
Draft Version – Do not quote




Annex 6. State of Centralization of Obsolete Pesticides127
Rayon                  Location of selected          Total planned   Including                     State of         Repackaged solid, kg           Repackaged
                       warehouses                    amount per      Solid, kg   Liquid, l         centralization   In bags          In barrels    liquid, l
                                                     rayon,
                                                     P.U.F., kg




Anenii Noi             Military training field             19550        19550          -             In progress        19550              19550         -
                       Bulboaca

Briceni                Village Grimincauti                 132030      124330        7700            In progress       124330                0          3100

Causeni                Village Gradinita                   141714      129614       12100             Finished         129614             129614       12100

Cimislia               Town Cimislia                       149117      140117        9000            In progress       140117              34500        9000

Criuleni               Village Pascani                     44195        40695        3500             Finished          40695              40695        3500

Donduseni              Mill factory Tirnova                65130        61430        3700            In progress        61430                0           0

Dubasari               Village Pascani                     25270        21970        3300             Finished          21970              21970        3300
                       (Prumbeni)




127
      Source: Ministry of Agriculture and Food Industry.

ECOS
Environmental Impact Assessment Report                                         Page   173 of 179
Draft Version – Do not quote

Rayon              Location of selected      Total planned   Including                 State of         Repackaged solid, kg            Repackaged
                   warehouses                amount per                                centralization                                   liquid, l
Floresti           Village Temiliuti         rayon,
                                                 155235        143400    11835           In progress       143400              30240              0
                                             P.U.F., kg
                   Village Gindesti

Nisporeni          Town Nisporeni                44480          37180    7300            In progress        37180                0           7300

Ocnita             Village Clocusna              21280          20080    1200            In progress        20080                0             0

Rezina             Village Papauti               34120          28320    5800             Finished          28320              28320         5800

Singerei           Village Alexandreni           86240          77840    8400            In progress        77840              64750         8400

Soldanesti         Village Chipesca              35400          35400      -             In progress        35400                0             -

Stefan Voda        Village Tudora Village       201547         176947    24600            Finished         176947              176947        24600
                   Olanesti

Telenesti          Village Ratus                300532         296672    3860             Finished         296672              296672        3860

Ungheni            Military training field       77915          69215    8700            In progress        69215                0           8700
                   Ungheni

UTA Gaguzaia       Town Comrat                   77200          67500    9700            In progress        67500              52500         9200
Comrat

UTA Gaguzaia       Town Gaidar                   68736          68736      -             In progress        68736                0             -
Ciadir-Lunga

UTA Gaguzaia       Village Cismichioi            49000          49000      -             In progress        49000                0             -
Vulcanesti

Municipality       Village Alexandreni           13700          13291     409             Finished          13291              13291          409
Balti

Municipality       Village Pascani               49000          49000      -             In progress        49000              49000           -
Chisinau           (Porumbeni Maise

ECOS
Environmental Impact Assessment Report                                       Page   174 of 179
Draft Version – Do not quote

Rayon              Location of selected      Total planned   Including               State of         Repackaged solid, kg            Repackaged
                   warehouses
                   Institute)                amount per                              centralization                                   liquid, l
                                             rayon,
                                             P.U.F., kg
Sub-total                                       1791391        1670287   121104                          1670287             958049       92469

Cahul              Military training field       54288                                 Not started
                   Cahul

Calaras            Village Oniscani             123586                                 Not started

Edineti            Town Edinet                   2682                                  Not started

Hincesti           Village Carpineni             49895                                 Not started

Orhei              Village Pelivan               35100                                 Not started

Riscani            Village Recea                 23286                                 Not started

Straseni           Fertalitatea SA/ town         32872                                 Not started
                   Straseni

Soroca             Not selected                  25750                                 Not started

Basarabeasca       Not selected                  10420                                 Not started

Drochia            Not selected                  15300                                 Not started

Ialoveni           Not selected                  75240                                 Not started

Glodeni            Not selected                  31945                                 Not started

Falesti            Not selected                  61141                                 Not started

Leova              Not selected                  25310                                 Not started

Taraclia           Not selected                 109570                                 Not started



ECOS
Environmental Impact Assessment Report                                Page   175 of 179
Draft Version – Do not quote

Rayon              Location of selected   Total planned   Including           State of         Repackaged solid, kg   Repackaged
                   warehouses             amount per                          centralization                          liquid, l
Cantemir           Not selected           rayon,
                                               8000                             Not started
                                          P.U.F., kg
Sub-total                                    684325                             Not started




ECOS
Environmental Impact Assessment Report                                     Page   176 of 179
Draft Version – Do not quote




Annex 7. Map of location of warehouses




Legend:            - Central Warehouse;   - Old evacuated pesticides warehouses




ECOS
Environmental Impact Assessment Report                                                                                                                                                                                                Page                            177 of 179
Draft Version – Do not quote




Annex 8. Methodology Applied for Risk Assessment of Central
Warehouses
The methodology developed by ECOS and applied to the current study included the following steps.

Basing on the information contained in the questionnaires/check-lists filled in during the field
investigation of each central warehouse; the mapping of land-use situation; and the identification of
areas potentially exposed to pollution by air dispersion (radius 300 m) and runoff (up to 1000 m,
depending on the landscapes characteristics) a set of indicators was obtained. The list of criteria was
discussed and most important ones were used for further analysis as presented in the table below.
Ranking of qualitative and semi-qualitative information was applied for each individual criterion as
indicated in the table. This allowed for clustering 10 selected criteria in three categories, named
LOW, MIDDLE and HIGH risks.


Risk         Mark    Rank of individual criteria
                        Amount of pesticides stored,




category for
                                                                                                                Distance to populated areas,
                                                        Warehouse physical status,




                                                                                                                                                                                                                                                                          Location in the river flood
                                                                                                                                                                           Distance to water courses,



each


                                                                                                                                                                                                                                           Distance to pastures, km




                                                                                                                                                                                                                                                                                                         aquifer, estimated in m
                                                                                      repackaging, estimated




individual
                                                                                                                                                Distance to agriculture




                                                                                                                                                                                                             Distance to forest, km




                                                                                                                                                                                                                                                                                                         Depth to groundwater
criterion
                                                                                      Available space for




                                                                                                                                                areas, km
                                                        estimated




                                                                                                                                                                                                                                                                          plain
                        tons




                                                                                                                km




                                                                                                                                                                           km




High         ***     > 100                             Bad                            No                       < 0,5                           < 0,5                      < 0,5                         < 0,5                         < 0,5                             Yes                             <3

Middle       **      50-100                            Satisfac Limited 0,5-1                                                                  0,5-1                      0,5-1                         0,5-1                         0,5-1                             On the 3-10
                                                       tory                                                                                                                                                                                                             first
                                                                                                                                                                                                                                                                        terrace
Low          *       < 50                              Good                           Enough > 1                                               >1                         >1                            >1                            >1                                No      > 10


Each central warehouse was checked against all 10 risk criteria to identify the TOTAL RISK
INDEX. For identification of HUMAN HEALTH RISK INDEX and ENVIRONMENTAL RISK
INDEX only part of the criteria (emphasizing human or environmental concerns) was applied, as
follows:


TOTAL RISK INDEX.                                                                    All 10 criteria
HUMAN HEALTH RISK                                                                    Amount of pesticides stored or expected to be stored


ECOS
Environmental Impact Assessment Report                                          Page   178 of 179
Draft Version – Do not quote

INDEX                                    Warehouse physical status
                                         Available space for repackaging
                                         Distance to populated areas
                                         Distance to agriculture areas
                                         Distance to pastures
ENVIRONMENTAL RISK                       Amount of pesticides stored or expected to be stored
INDEX                                    Warehouse physical status
                                         Available space for repackaging
                                         Distance to water courses
                                         Distance to forest
                                         Location in the river flood plain
                                         Depth to groundwater aquifer

The calculation of numeric values for total, health and environmental risks allowed for ranking
integrated indexes according to four categories: HIGH, CONSIDERABLE, MODERATE and
LOW. The thresholds limits are indicated in the table below.


Integrated risk           Mark       TOTAL RISK            HUMAN                 ENVIRONMENT
category                             INDEX                 HEALTH RISK           AL RISK INDEX
                                                           INDEX
HIGH                      H          > 20                  > 15                  > 15
CONSIDERABLE              C          17-20                 13-15                 13-15
MODERATE                  M          13-16                 10-12                 10-12
LOW                       L          < 13                  < 10                  < 10




ECOS
Environmental Impact Assessment Report          Page   179 of 179
Draft Version – Do not quote




Annex 9. Map of integrated risk assessment and ranking of
central pesticide warehouses




                                         LEGEND:
                                         - Central pesticide warehouse
                                         - Candidate for selection as
                                           central pesticides warehouse
                                         -Integrated risk
                                         -Human health risk
                                         -Environmental risk
                                         -Higher integrated risk
                                         -Considerable integrated risk
                                         -Moderate integrated risk
                                         -Low integrated risk




ECOS

								
To top