Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Lao People's Democratic Republic Peace Independence Democracy Unity Prosperity MINISTRY OF ENERGY AND MINES Lao PDR: Domestic Grid Optimization Project (P178477) HAZARDOUS WASTE MANAGEMENT PLAN Prepared by Electricité du Lao (P178477) First Draft Page 1 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Table of Content 1 Introduction...................................................................................................... 13 1.1 Background ....................................................................................................... 13 1.2 Application of Hazardous Waste Management Plan (HWMP) ............................ 17 1.3 Scope of Hazardous Waste Management Plan (HWMP) ................................... 18 2 Relevant Legislations and International Treaties .......................................... 19 2.1 National Legislation ........................................................................................... 19 2.2 International Treaties ......................................................................................... 21 2.3 International Guidelines ..................................................................................... 23 3 Required Actions and Relevant Guidance for Hazardous Waste Management ............................................................................................................... 25 4 Management of PCB Related Hazardous Waste ............................................ 32 4.1 Key Steps and Relevant Guidance .................................................................... 32 4.1.1 Requirements of Certified Contractors ......................................................... 32 4.1.2 Guidance for Implementation of Case 1 and Case 4 .................................... 33 4.2 Sampling ........................................................................................................... 33 4.3 Labelling ............................................................................................................ 34 4.4 Packaging .......................................................................................................... 38 4.5 Handling ............................................................................................................ 40 4.6 Storage .............................................................................................................. 41 4.7 Transportation ................................................................................................... 42 4.8 Emergency Response ....................................................................................... 43 4.9 Health and Safety Protection ............................................................................. 44 5 Treatment PCB contaminated oil of transformer ........................................... 46 5.1 Retrofilling of Transformers ................................................................................ 46 5.2 General description of the mobile unit for chemical dechlorination and regeneration of PCB oil from electrical equipment ............................................................................. 47 5.3 Disposal of PCB contaminated waste ................................................................ 47 5.4 Timeline for Treatment and Disposal ................................................................. 47 6 Institutional Responsibilities, Monitoring, and Reporting ............................ 48 6.1 Project Owner .................................................................................................... 48 6.2 Relevant Governmental Ministries and Departments ......................................... 49 (P178477) First Draft Page 2 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 6.3 Contractor Under UNIDO Project (Service Provider for PCB Treatment Process) 51 7 Capacity Building ............................................................................................ 53 7.1 Current Trainings by Safety Unit of EDL ............................................................ 53 7.2 Proposed Training Programs ............................................................................. 54 7.3 Estimated Budgets............................................................................................. 56 8 Budgets for Hazardous Waste Management ................................................. 57 8.1 Budget for Decontamination of PCB-contaminated liquid and equipment and disposal of associated PCB contaminated waste ......................................................... 57 8.2 Budget for Disposal of PCB-contaminated waste associated with PCB- contaminated liquid and equipment during PCB testing process .................................. 57 Annex-1 : TOR for PCB Treatment Services Under UNIDO Project ........................ 59 Annex-2: Inventories Results for big transformers PB............................................ 73 List of Tables Table 1-1 Components of the Proposed Project and its Brief Description ..................... 13 Table 1-2 List of Targeted Substations and Its Transformers to be removed ................ 15 Table 2-1 List of Relevant National Legislation ............................................................. 19 Table 2-2 Major Relevant International Agreements ..................................................... 21 Table 2-3 Major Relevant International Guidelines ....................................................... 23 Table 3-1 Required Actions and Relevant Guidance .................................................... 26 Table 7-1 List of Trainings relevant to HWMP .............................................................. 55 List of Figures Figure 1-1 Locations of the Substations ....................................................................... 14 Figure 2-1 Waste Management Hierarchy .................................................................... 24 Figure 4-1 Label for suspect PCB-contaminated Equipment ........................................ 35 Figure 4-2 Label for Container ...................................................................................... 35 Figure 4-3 Label for confirmed PCB-Contaminated Equipment .................................... 36 Figure 4-4 Label for confirmed PCB-contaminated Equipment with Contamination less than 0.05% total PCB ............................................................................................ 37 Figure 4-5 Hazard Symbols for PCB-contaminated Equipment .................................... 38 Figure 4-6 Label for transformers decontaminated below 0.005% PCBs ...................... 38 (P178477) First Draft Page 3 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 4 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan List of Abbreviations Abbreviation A Ampere ADB Asia Development Bank CA Community Awareness CB Circuit Breaker CEO Chief Executive Officer CERC Contingent Emergency Response Component C-ESMP Constructor’s Environmental and Social Management Plan CHA Cluster Munitions Hazard CHS Community Health and Safety CoA Charts of Accounts CoC Code of Conduct CPA Certified Public Accountant CR Critically Endangered CSC Construction Supervision Consultant CT Current Transformer CVT Capacitor Voltage Transformer DPCI Department of Pollution Control and Inspection DS-ES Disconnector Switchgear with Earthing Switchgear E East E&S Environmental and Social EAP Environmental Action Plan E&S Environmental and Social EDL Electricite Du Laos EHS Environmental and Health and Safety EPA Environmental Protection Agency EPL Environmental Protection Law ESF Environmental and Social Framework ESHS Environmental, Social, Health, and Safety ESMP Environmental and Social Management Plan ESS Environmental and Social Standard GHG Green House Gas (P178477) First Draft Page 5 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Abbreviation GoL Government of Laos ha Hectare HPP Hydro Power Plant HQ Head Quarter HWMP Hazardous Waste Management Plan IBAT Integrated Biodiversity Assessment Tool IDA International Development Association IESMC Independent Environmental and Social Monitoring Consultant IPPs Independent Power Producers IUCN International Union for Conservation of Nature KBAs Key Biodiversity Areas kg Kilogram kha Kilohectare km Kilometer kV Kilovolt kVA Kilovolt amps L Liter LA Lighting Arresters Lao PDR Lao People’s Democratic Republic LFND Lao Front for National Development LMP Labour Management Procedures LPRP Lao People’s Revolutionary Party m meter MAG Mines Advisory Group MEM Ministry of Energy and Minerals MOIC Ministry of International Cooperation MONRE Ministry of Natural Resources and Environment MVA Megavolt-amperes MW Megawatt N North NE Northeast NES National Environmental Standards NIP National Implementation Plan (P178477) First Draft Page 6 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Abbreviation NW Northwest OE Owner’s Engineer OHS Occupational Health and Safety PCBs Polychlorinated biphenyls PM Project Manager PMU Project Management Unit PONRE Provincial Natural Resource and Environment Office POPs Persistent Organic Pollutants PPE Personal Protective Equipment ppm Part Per Millions PSV Phonsavanh S South SC Stockholm Convention SE Southeast SI System Integration SMEs Small and Medium Enterprises SS Substation SS-ESMP Site Specific Environmental and Social Management Plan SW Southwest TBD To be discussed ToR Term of Reference Tr Transformer UNEP United Nations Environment Programme UNIDO United Nations Industrial Development Organization USD United States Dollar VOCs Volatile Organic Compounds W West WB World Bank (P178477) First Draft Page 7 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Definition Transformer An active component of power management systems, electrical transformers are used to transform voltage or current from one level to another, usually from a higher voltage or current to a lower voltage or current by applying the principle of magnetic induction between coils to convert voltage and/or current levels. Dielectrics used in transformers can range from oils, air to solid resins. (EPA (Ireland)) PCB Polychlorinated Biphenyls means an organic chemical substance that is toxic for a long period, persists in life forms and nature, spreads over far distances, cannot degrade by itself in nature and is seriously harmful to health, life properties, and the environment. (Lao’s regulation) PCB Contaminated A container, packaging material, and equipment contaminated with the Waste chemical substance is damaged or out-of-use, for re-containing or repackaging while waiting for decontamination and disposal; (Lao’s regulation) PCB Contaminated Any equipment that contains more than 5 liters of fluid with a PCB equipment concentration of more than 0.005% by weight is classed as PCB contaminated equipment. / Equipment which contains PCB-contaminated liquid or contained PCB-contaminated liquid which was not appropriately decontaminated. (EPA (Ireland)) Retrofilling A crude decontamination method that involves draining PCB- contaminated oil from a transformer and refilling it with a PCB-free insulating fluid. (EPA (Ireland)) Decontamination The process of removing contaminants from a substance or changing their chemical nature to transform them into harmless substances. (UNEP) Closed application Applications in which PCBs are in a totally enclosed equipment. Under these conditions, PCBs only enter the environment in limited cases, such as leaks or spills of equipment (examples: transformers, capacitors). (UNEP) Hazardous waste Hazardous waste is waste having possible adverse impacts to human health and the environment as a result of physico-chemical and/or biological properties rendering it dangerous. Hazardous wastes may be found in different physical states such as gaseous, liquids, or solids including sludge. A hazardous waste is a special type of waste because it cannot be disposed of by common means like other by-products of our everyday lives. (P178477) First Draft Page 8 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Executive Summary E-1: The Domestic Grid Optimization Project in Lao PDR includes financing replacement or rotation of transformers in targeted sub-stations that have low performance and high technical losses. Under the Proposed Project, twelve transformers from eight differents sites are planned to be removed. E-2: As a member of Stockholm Convention on Persistent Organic Pollutants (POPs), Lao PDR has performed PCB inventories of transformers since 2005 while developing National Implementation Plan (NIP) for the Stockholm Convention. Polychlorinated biphenyls (PCBs) were among the first twelve compounds included in the list of persistent organic pollutants (POPs) by the Stockholm Convection on POPs. PCBs were used as an electrical insulating oil (dielectric fluid) in electrical equipment such as transformers until 1970s. Once in the environment, PCB enter the food chain: Over 90% of human exposure to PCB is through food. Such exposure also has neurotoxic and immunotoxin effects. In addition, PCB undergo long-range transport through air, water and migratory species. E-3: Under the UNIDO financed project, PCB inventory for the EDL transformers was undertaken in cooperation with MoNRE in 2016. Among the twelve transformers, one transformer was found to be contaminated with PCBs, according to the inventory conducted under the UNIDO project. Given this situation, for implementation of the proposed project, the Polychlorinated Biphenyls (PCB) Risk Management Protocol is being developed as part of the ESIA study to apply to all activities that include the replacement of all transformers, including transformers identified prior to the Project Appraisal as well as additional under the proposed project. According to the Protocol, PCB testing of all transformers to be removed (twelve) will be performed prior to any project activities at each substation. E-4: When the transformers test positive for presence of PCBs, the generation of hazardous waste (the waste associated with PCBs) is anticipated throughout the series of processes such as dismantling the transformers, draining of PCB-contaminated oil, packaging, transport, and decontamination/disposal of PCB-contaminated oil. This hazardous waste management plan (HWMP) is therefore applied when PCBs are detected in transformer oil. E-5: This HWMP set up the procedures for handling, management, storage, and disposal of hazardous materials (PCB contaminated waste as defined above) in order to avoid any harms caused by hazardous waste on the environment as well as on the staff working at substations. This document follows the Lao PDR’s national legislations related to toxic and hazardous chemicals including PCBs. In addition, the available international guidelines and good practices relevant to the management of PCBs and decontamination/disposal of PCBs liquid and equipment are also applied appropriately at the relevant parts of the HWMP. This plan consists of the following key components: (1) review of relevant national legislation, international treaties and guidelines (P178477) First Draft Page 9 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (2) the required actions and relevant guidelines for the hazardous waste management (3) guidance for the management of PCB-related hazardous waste including sampling, labeling, handling, storage, packaging, transportation, emergency response, health and safety protection. (4) the dedication of responsible entities during implementation of the Proposed Project (5) the institutional capacity strengthening plan related to hazardous waste management plan E-6: The followings are the steps involved in the Protocol for PCB Risk Management: Step 1: All transformers to be removed will be tested with a portable PCB analyzer for identification PCB containing the transformer oil. Step P1: If PCB is detected in transformer oil, labelling shall be performed for PCB containing transformer. The detail guidance of labelling of PCB containing or contaminated equipment, container, and waste is included in the Hazardous Waste Management Plan. Step P2: In accordance with Stockholm Convention, it should be managed based on the concentration with respect to the volume of oil (Liter). Referring to EPA (Ireland)’s guide to the disposal and decontamination of PCB contaminated transformers and other PCB application, the following specific approach is developed for managing the PCB containing equipment and PCB contaminated equipment. The following four cases are categorized with different management approach. Case 1: If any volume of oil with total PCB contamination level (%w/w) is less than 0.005% (50ppm), the PCB containing oil shall be disposed as hazardous waste (identified by Lao’s legislation) at end of useful life. Case 2: If volume of oil less than 5 L with total PCB contamination level (%w/w) is greater than 0.05% (500ppm), the PCB contaminated oil shall be disposed as PCB contaminated waste in environmentally sound manner at end of useful life Case 3: If volume of oil greater than 5 L with total PCB contamination level (%w/w) is between 0.005% (50ppm) and 0.05% (500ppm), EDL shall notify to the relevant authority (MoNRE) of equipment. And the PCB contaminated oil shall be disposed as PCB contaminated waste in environmentally sound manner at end of useful life (but not later than 2028 as of Stockholm Convention). Case 4: If volume of oil greater than 5 L with total PCB contamination level (%w/w) is greater than 0.05% (500ppm), EDL shall notify to the relevant authority (MoNRE) of equipment. The immediate decontamination or disposal shall be performed in environmentally sound manner. (P178477) First Draft Page 10 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Step P3: In case of Case 2 and/or Case 3, it is necessary to confirm that EDL the PCB- contaminated transformers are listed under the UNIDO project to be treated and/or disposed of. The detail guidance for Case 1 and/or Case 4 is included in the hazardous waste management plan. The project will not be accepted unless it is in the list of the UNIDO project and work will not begin until it is treated. Step P4: If treatment will be performed under UNIDO financed project, it is evaluated that the PCB contaminated transformers will be managed under the safe and environmentally sound management procedures. PCB-contaminated oil will be treated by a mobile treatment facility with PCB Dechlorination System and Oil Regeneration System at target substation. If those transformers will not be decontaminated/disposal under UNIDO, the project activities (the replacement of PCB contaminated transformers) will not be permitted under Proposed Project until a new acceptable treatment process meeting ESF requirements is identified. In the event that the decontamination or disposal cannot be implemented timely manner even under UNIDO program, no work may be initiated at site. Step P5: All by-product materials including soil or water contaminated with PCB during the on-site treatment process of PCB using mobile treatment facility shall be packed, transported, and disposed in the environmentally sound management manner. Step P6: Transformer with PCB-free oil will be relocated to the safe storage either at site or other substation to be services again if it is in good operational condition and having transformer life is less than 40 years. E7: Under the proposed project, the followings steps will require to contract with certified contractors. 1. In order to implement Step 1, it is required to hire a certified contractor for performing sampling and testing of oils of all transformers to be removed from eight substations by using a mobile analyzer funded by the WB under proposed project. 2. In order to implement Step P4 and Step P5, Contractor who will provide on-site treatment service must be entity who was approved by MONRE under the UNIDO financed project and/or any subsequent decontamination processes that may be put in place and agreeable to the Bank. 3. In order to implement Step P6: EDL is required to hire an experienced contractor for performing handling. E-8: The Contractor who will be contracted with EDL to perform the Project funded by the WB and be involved in each step must be approved by MONRE and the contractor is required to submit a Contractor’s ESMP (See Annex-4 of ESIA) to PMU and WB for prior review before commencing any relevant activities. (P178477) First Draft Page 11 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan E-9: The detail timeline for the treatment and disposal process for PCB-contaminated waste at each substation shall be prepared while preparing of site specific ESMP after project effectiveness. EDL will ensure the commitment of the contractor under the UNIDO finance project for the treatment of PCB-contaminated transformer identified by the UNIDO project in the past and targeted by the World Bank Project within three months after project effectiveness or at the time of preparation of site specific ESMP. (P178477) First Draft Page 12 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 1 Introduction 1.1 Background The Domestic Grid Optimization Project in Lao PDR includes financing replacement or rotation of transformers in targeted sub-stations that have low performance and high technical losses. The Proposed Project includes three components with sub-components: Table 1-1 Components of the Proposed Project and its Brief Description Component Description Component-1: Substation Investments and Grid Monitoring Systems with sub- components Component-1(a): This sub-component encompasses the activities such as the replacement or installation of transformers at the identified locations, switchgears, insulators, wires, supporting structures (gantry, tower etc.), procurement of pre-fabricated mobile substations, etc. The additional locations for future investment will be considered too. Component-1(b): This sub-component covers the procurement of necessary equipment including portable polychlorinated biphenyl (PCB) analyzers, system design and planning software, and EDL staff training for key systems operations. Component-2 Financial Management System and SAP Implementation focus on providing the technical assistance and capacity building required for the strengthening of EDL’s financial management system and for completing an effective functioning, integration and adoption of the SAP. Component-3: Project Implementation Support Component-4: Contingent emergency response The locations of the substations which will involve under Component-1 are plotted on the map as shown in Figure 1-1. Thoses are laid on the domestic grid over the whole nation. (P178477) First Draft Page 13 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Figure 1-1 Locations of the Substations The Proposed Project activities to be undertaken at the Substations under Component- 1, include the removal of transformers that are likely contaminated with polychlorinated biphenyls (PCB) oil. The PCBs are not biodegradable and, instead, bioaccumulate and, in case of the exposure with PCBs, a number of impacts of PCBs on health and the environment can be identified through the bio-accumulation processes. The wastes associated with PCBs are identified as the hazardous waste. In the Proposed Project’s implementation, it is anticipated the generation of hazardous waste (PCB contaminated waste) during the dismantling and replacement of old transformers if the old transformers are contaminated with PCBs. It could contribute significantly to environmental degradation if not properly managed; therefore, appropriate management must be provided to protect the environment during the PCB test on transformers, dismantling and replacement of old transformers by new ones without PCB, etc. Thus, it will be necessary to contribute to the prevention and management of the potential environmental, social and health impacts and risks related to the production of this waste in Laos. The following table shows the tentative list of substations where transformer replacement or rotation is planned to be made. Out of eleven sites, twelve transformers from eight sites are to be removed. (P178477) First Draft Page 14 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Table 1-2 List of Targeted Substations and Its Transformers to be removed No. of PCB Testing Distribution Outlines of the Province / Transformers Status (PCB No. Substation Activities Prefecture to be content) * removed 1 Ban Na Installing a 30MVA Tr Champasak - and making parallel Province operation possible with the existing 30MVA Tr 2 Bang Yo Replacing two 25MVA Champasak 2 No Tr with two new Province 50MVA Tr and 22kV side enforcement 3 KokSaad Replacing 22MVA Tr Vientiane 2 Yes for both and 30MVA Tr with Prefecture Trs / two new 50MVA Tr (No contamination) 4 M. Kham Replacing 10MVA1 Tr Xiangkhouang 1 Yes with a new 30MVA Tr Province and adding a new (No 30MVA Tr, installing contamination) switchgears, a shunt reactor, a control building, and operators house on the secured substation yard 5 Na Lea Replacing 20MVA Tr Oudomxay 1 Yes (Oudomxai) with a 30MVA Tr and Province this will make parallel (104 ppm, but operation possible origin of this with the existing oil is not 30MVA Tr known) 6 Pak Bo Replacing two 20MVA Bolikhamxai 2 Yes for No.1 Tr with two new Province Tr 50MVA Tr and 22kV side enforcement. (No contamination) No for No. 2 Tr 1This historical transformer was used for the first 115kV high voltage grid connection between Lao PDR and Thailand. (P178477) First Draft Page 15 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan No. of PCB Testing Distribution Outlines of the Province / Transformers Status (PCB No. Substation Activities Prefecture to be content) * removed Paksan 7 Replacing a 16MVA Tr Bolikhamxai 1 No (Pakxan) with a new 30MVA Tr Province and this will make parallel operation possible with the existing 30MVA Tr 8 Phonsavanh Installing a 115kV line Xiangkhouang - bay as a stand-by bay Province to transfer power to M. Kham in case of existing bay failure or repair and modifying existing two independent local SCADA systems into one new local one in the building’s expanded space 9 Salaphoukh Installing one new Luang - oun 20MVA Tr, Prabang switchgears, a control Province building, two tension towers, and operators house on the secured substation yard 10 Saphaothon Replacing a 20MVA Attapeu 1 Yes g non-standard tap Tr Province with a standard new (No one to improve voltage contamination) control range and this will make parallel operation possible with existing 20MVA Tr 11 Vangvieng Replacing two 16MVA Vientiane 2 No Tr with two new Province 30MVA Tr Total 12 Note: *The detail of testing and results of PCB are described in section 1.2. See the Annex-2. (P178477) First Draft Page 16 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 1.2 Application of Hazardous Waste Management Plan (HWMP) Lao PDR has ratified the Stockholm Convention on Persistent Organic Pollutants on 28th June 2006 aiming at protecting human health and the environment. In order to fulfil its obligations under the Convention, Laos has developed its National Implementation Plan (NIP) in 2010 to establish and prioritize action plans to comply with its obligation under the Convention. The Stockholm Convention on Persistent Organic Pollutants (POPs)2 requires Parties to eliminate the use of polychlorinated biphenyls (PCB) in equipment by 2025 and to ensure the environmentally sound waste management of liquids containing PCB and equipment contaminated with PCB by 2028. During the NIP development, Polychlorinated Biphenyls (PCB) - inventory was undertaken phase by phase since 2005. Under the support of Global Environment Facility (GEF), the United Nations Industrial Development Organization (UNIDO) has initiated a Project: “PCB Management and Disposal at the Energy Sector” in 2016 with the Ministry of Natural Resources and Environment (MoNRE), the executing agency of Lao PDR. As one of the project components of the UNIDO project, PCB inventory was conducted in 2016 using PCB inventory guidance of United Nations Environmental Programme (UNEP) including the data such as the manufacturing date, dielectric type, cooling system, historical repairing, and missing or illegible name plates. As the results of the inventory conducted under the UNIDO project, out of the twelve target transformers to be replaced, PCB testing has been performed on only for four transformers. The test results of one transformer was available as shown in Table 1-2 and the rest of the results could not be traced due to many reason including limited informaiton in the inventories, mobilization of tested transformers between substationss after testing in 2016. Given this situation, for implementing the Propose Project, the Polychlorinated Biphenyls (PCB) Risk Management Protocol is being developed as part of the ESIA study to apply to all activities which include the replacement of all transformers, including transformers identified prior to the appraisal as well as additional under the proposed project. According to the Protocol, PCB testing of all transformers to be removed (twelve) will be performed prior to any project activities at each substation. When the transformers are detected positive for the presence of PCBs after testing, the generation of hazardous waste (the waste associated with PCBs) is expected throughout the series of processes such as draining of PCB-contaminated oil for decontamination on site and in situ by using a mobile facility, especially for 115kV large transformers. This hazardous waste management plan (HWMP) is therefore applied when PCBs are detected in transformer oil. The management of the other type of hazardous waste which may resulted from the construction works will cover in the SS-ESMP of such specific site. 2 Stockholm Convention on Persistent Organic Pollutants, http://www.pops.int (P178477) First Draft Page 17 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 1.3 Scope of Hazardous Waste Management Plan (HWMP) This HWMP establishes procedures for handling, management, storage, and disposal of hazardous materials (PCB-contaminated waste as defined above) to prevent harm from hazardous waste to the environment as well as to the personnel working in the substations. The HWMP will thus allow to account for the expected PCB contaminated waste that will be produced; to minimize the production of these wastes at all levels; to popularize the actions need for managing PCB contaminated transformers, and to eliminate the wastes according to the most appropriate method. This document follows the Lao PDR’s national legislations related to toxic and hazardous chemicals including PCBs. In addition, available international guidelines, and good practices regarding the management of PCBs and decontamination/disposal of PCB-containing liquids and equipment are also applied appropriately in the relevant parts of the HWMP. This plan consists of the following key elements: (1) review on relevant national legislation, international treaties international guidelines. (2) required actions and relevant guidelines for hazardous waste management. (3) guidance for management of PCB-related hazardous waste including sampling, labeling, handling, storage, packaging, transportation, emergency response, health and safety protection. (4) the dedication of responsible entities during the implementation of the Proposed Project. (5) the institutional capacity strengthening plan related to the hazardous waste management plan. (P178477) First Draft Page 18 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 2 Relevant Legislations and International Treaties The relevant national legislation in terms of managing hazardous waste and disposal and decontamination and disposal of electrical transformers are briefly described. International treaties related to transboundary movement of hazardous waste and the prior informed consent procedure for certain hazardous chemicals and pesticides in International Trade. 2.1 National Legislation Lao PDR has stipulated the law, decrees, and guidelines related to hazardous chemicals, and waste management including storage, labelling, and transportation. Particularly, specific regulations on PCB management have been recently developed, including the use, storage and disposal of PCBs. Lao PDR published its Decision on the Management, Monitoring, Treatment, and Disposal of Polychlorinated Biphenyls (PCBs) in Transformers in 2020. In addition, the guideline for PCB Management and Disposal is announced in 2021, which instruct to follow the existing national decrees, and agreements related to chemical labelling, and storage. Table 2-1 List of Relevant National Legislation Decrees/Regulations Brief Description / Guidelines/ Instructions Ministerial Instructions These Instructions aim to classify hazardous waste and ensure that public on Hazardous Waste and private stakeholders in the sectors who generate hazardous waste and Management, No. the communities concerned have the same understanding on the 0744/MONRE, 11- implementation approaches related to the import, export, transfer, storage, Feb-2015 use, recycling and disposal of hazardous waste in the entire country, which aims to prevent and reduce the generation of hazardous waste and operate advance notification regulations and approval procedures by the competent authority and the National Focal Point of Basel Convention. Law on the Chemicals This law lays down the principles, regulations and measures regarding the (2016) management, monitoring, inspection, implementation and undertaking of chemical activities for the purpose of encouraging and promoting quality in order to maintain the business and use of chemicals in accordance with the technical terms, efficient, effective work and ensuring the safety to the health, life, property, environment and society, contributing to the national economic and social sustainable development. (P178477) First Draft Page 19 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Decrees/Regulations Brief Description / Guidelines/ Instructions Agreement on the This agreement issued for guiding the development of waste management Waste by Industry and define the rules, regulations and procedures in managing the waste Factory and Handicraft from industry factory and handicraft activities. It defined different types of waste – under part II, article 4 and different way for managing them. Article No. 0555, Dated 20 7, 8, 9 and 10 indicates the details of locations, appropriate way for March, 2016 collection, transportation and disposal. Important listed of prohibitions in part V are heart of this agreement. Part V of agreement clearly identified the roles and responsibilities and obligations of waste generation bodies. That they must closely follow up; monitor and provide feedback to parties that are generating waste. They have to ensure that parties concerned on waste management strongly follow all related legislations. Agreement on The agreement on the chemical labelling (15 SEP 2021) is ministerial chemical labelling agreement; it purposely define the rules, regulation, procedures and (2021) measurements for the management, application of chemical substance labelling. This agreement has guidance the proper procedures, tools and appropriate ways in labelling chemical in order that we can prevent/protect and promote human and environment safety and for sustainable and green development. It standardizes the labels for different type of chemicals in different ways, for examples, using Chemical production identification, pictograms, signal words, hazard statements, precautionary statements, manufacturer, or Supplier identification. Agreement on The agreement on the chemical storage has major purpose of defining the chemical storage procedures; regulations; measurements for management, monitoring of the (2021) chemical substance storage. In achieving this we can ensure the safety, technical accurate, promoting human health and environment safety. It specified the nature of store, that must compromise, it must be separated, must be keep with special packaging materials, must comprised with specific technical knowledge, and dedicate four types of warehouses (for service, for import-export business, for factory, for project). This agreement also clearly identified the structure of the warehouse with annexes standard like silence, detector, fire control, water supply system. The table of distance for each group of chemicals plus the maximum of quantity that each group can be stored. Agreement On This agreement aims to provide guidelines on the management of PCBs Management and used in electric transformers, and to reaffirm Laos’ international Monitoring of PCB commitments under the Stockholm Convention on Persistent Organic Decontamination and Pollutants. Disposal for Electrical It defines regulations, methods, and measures on management and Transformers (Dec monitoring of PCB decontamination and disposal for electric transformers 2020) as well as PCB-contaminated waste, in order to prevent and control pollution with corrective technical rules aiming to ensure health and safety, lives of human, animals and plants, and environmental impacts; contributing into socio-economic development and environmental protection following the green and sustainable direction. (P178477) First Draft Page 20 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Decrees/Regulations Brief Description / Guidelines/ Instructions Guideline for PCBs This guideline is prepared by Ministry of Natural Resources and Management and Environment (MONRE) for the management and disposal of PCBs and long- Disposal (2021) term residual organic chemicals (Persistent Organic Pollutants: POPs) based on the review of various national and international legislations such as Basel, Rotterdam, and Stockholm Conventions. This manual provides general information about PCB, management measures, PCB classification, Analysis of concentration, handling, collection, packaging, labelling, transportation, storage, and treatment and disposal methods. 2.2 International Treaties Table 2-2 Major Relevant International Agreements International Requirements Agreement Basel Convention on Lao PDR is also a signatory to the Basel Convention in 2010. Within list of the Control of waste streams in Annex I of the Convention is the category Y10, which Transboundary concerns: "Waste substances and articles containing or contaminated with Movements of polychlorinated biphenyls (PCBs) and/or polychlorinated terphenyls (PCTs) Hazardous Wastes and/or polybrominated biphenyls (PBBs)”. and their Disposal All wastes, equipment, oils, substances, or materials contaminated with PCB at a concentration greater than 50 mg/kg are considered toxic. Exports of equipment and oils contaminated with PCB above this threshold must be (Relevant Ministry in in compliance with the regulations under the Basel Convention. Among Lao PDR: Ministry of others, this means that PCB wastes can only be exported with the written Industry and prior informed consent of the importing state and for environmentally sound Commerce) management. All equipment containing coolant liquids at concentrations below 50 mg/kg PCB are internationally recognized as being PCB-free and having no special requirements. In 2020, the Ministry of Industry and Commerce (MoIC), Lao PDR, published the Decree define rules; procedures; measurements instrument for the authorization or registration of chemical substance when import-export. (P178477) First Draft Page 21 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan International Requirements Agreement Stockholm Convention Lao PDR is a contracting member of the Stockholm Convention on Persistent Organic Pollutants, having ratified the convention on June 28, (Relevant Ministry in 2006. Parties to the convention are required to eliminate the use of PCBs in Lao PDR: Ministry of existing equipment by 2025 and ensure environmentally sound waste Natural Resources management of them by 2028. Laos thus issued the National and Environment) Implementation Plan under the Stockholm Convention in March 2016 to phase out the country’s use of PCBs. The National Implementation Plan under the Stockholm Convention had observed that Laos had no specific law or regulation for managing equipment or waste containing PCBs and identified some electric transformers as a source of waste containing PCBs. Recently, Lao PDR enforced the specific regulations related to PCB management in 2021. In 2010, the Lao PDR ratified the Rotterdam Convention. is an international Rotterdam Convention treaty designed to facilitate informed decision-making by countries with on the Prior Informed regard to trade in hazardous chemicals. It establishes a list of covered Consent Procedure for chemicals and requires parties seeking to export a chemical on that list to Certain Hazardous first establish that the intended importing country has consented to the Chemicals and import. It also requires that a party seeking to export a chemical that is not Pesticides in listed under the Convention but that is subject to a ban or severe restriction International Trade in its own territory must provide notice to the importing country of the (Relevant Ministry in proposed export. Lao PDR: Ministry of Natural Resources and Environment) Also known as the Global Goals, they were adopted by all United Nations The Sustainable Member States in 2015 as a universal call to action to end poverty, protect Development Goals the planet and ensure that all people enjoy peace and prosperity by 2030. (SDG) (2015) Goal No 126Calls for to “ensure sustainable consumption and production patterns” and requires in target 12.4 B that by 2020, to achieve the environmentally sound management of chemicals and all wastes throughout their life cycle, in accordance with agreed international frameworks, and significantly reduce their release to air, water and soil to minimize their adverse impacts on human health and the environment. (P178477) First Draft Page 22 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 2.3 International Guidelines Table 2-3 Major Relevant International Guidelines Guidelines Brief Description PCB Management The purpose of this PCB Management Guidance is to support stakeholders Guidance: engaged in the maintenance, handling, transport and interim storage of Maintenance, liquids containing PCB and equipment contaminated with PCB, taking into Handling, Transport account practical experience and applicable international obligations. Based and Interim Storage of on collected experiences and lessons learned from experts, countries and Liquids Containing companies, existing guidelines on inventories and handling of PCB, and PCB and Equipment relevant regulations considering regional variations, the guidance lists and Contaminated with explains relevant technical guidelines, outlines important procedures and PCB, published by provides practical recommendations for implementation. The guidance also PCB Elimination features a bibliography and links sections, where the reader can find Network (PEN), references to documents of international organizations and other UNEP,2016 stakeholders that were consulted to prepare the present guidance document. A Guide to the This document presents a guide on how to dispose of or decontaminate Disposal and equipment containing PCBs taking into account relevant health, safety, Decontamination of environmental protection and waste legislation in Ireland. It provides an PCB-contaminated overview of the process of identifying and managing PCB-contaminated transformers and other equipment. Contact details of laboratories providing the required testing are PCB applications, also included. EPA (Ireland), 2017 The best method for deciding on the hazardous waste management is by using the Waste Management Hierarchy as illustrated in figure 2-1 below. This method is intended for decision making which addresses issues such as sustainability, cleaner production, health, safety, and environmental protection. It is applied to existing or proposed practices, examining and testing these at each level, starting at the top of the hierarchy. For hazardous waste, the proposed hierarchy is as follows: 1. Remove the production of hazardous waste 2. Reduce the quantity or hazard involved where elimination is not possible 3. Reuse, Recycle, and Recover by minimizing the amount of waste by improving existing technologies, introducing cleaner production. pollution prevention measures for disposal by reuse such as reuse of solvents; reuse of acidic and alkali solutions; reuse of chromium from tanneries; recycling as this entails pre- treatment of waste as it can be used as raw materials; and/or recovery which involves treating “waste” by products to be used as raw materials in the same or another process. This also includes the recovery of energy which may be available from the waste. 4. Treat waste to stabilize, immobilize, contain, or destroy hazardous properties. (P178477) First Draft Page 23 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 5. Dispose of residues with a minimum of environmental impact among them in sanitary landfills. –or appropriately contain, isolate, and store hazardous waste for which no acceptable treatment or disposal option is currently available. This HWMP targets to reach the level of treat for the management of anticipated hazardous waste (PCB contaminated waste) under this Proposed Project. Figure 2-1 Waste Management Hierarchy3 3 Source: OGP. (2009). Guidelines for waste management with special focus on areas with limited infrastructure. Accessed 21 November 2015 at http://www.ogp.org.uk/pubs/413.pdf (P178477) First Draft Page 24 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 3 Required Actions and Relevant Guidance for Hazardous Waste Management Figure 3-2 Flow Diagram of Management of the PCB Related Risks during Project Implementation if PCB is present in Transformer Oil To follow the procedures of the PCB risk management protocol, the detailed actions must be implemented. In carrying out those actions, the relevant guidance in terms of management of hazardous waste generation, handling, storage, transportation, and decontamination of materials, liquids and equipment contaminated with and containing PCBs shall be documented. (P178477) First Draft Page 25 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Table 3-1 Required Actions and Relevant Guidance Required Actions Guidance to be followed Responsible Entities Indicated Timeline Step 1: Sampling and Identification of PCB Contamination 90 Days after Project Effectiveness 1. A certified contractor shall be contracted for sampling See Section 4.1.1 EDL and identification of PCB Contamination for all transformers to be removed under the Proposed Project. 2. The samples of PCB containing oil from the See Section: 4.2 Certified Contractor transformer shall be taken by qualified and experienced technicians. Samples shall be stored in the sealed container, packed, and transported to the certified laboratory. 3. PCB testing will be performed using the portable PCB See Section: 4.2/4.3 Certified Contractor analyzer to determine the concentration of PCB in the transformer oil at the proper laboratory in Lao PDR (e.g., Laboratory of MoNRE). The containers shall be labelled as guided. Step P1: If Positive, Labelling shall be performed for PCB containing Transformer Within 1 week after the PCB is identified. (P178477) First Draft Page 26 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Required Actions Guidance to be followed Responsible Entities Indicated Timeline 1. The labelling of electrical equipment that contains PCB See Section: 4.3 SS staff shall be done as soon as it has been identified. The labelling can facilitate the tracking of PCBs. Step P2: Selection of Management Method of PCB containing transformer: in accordance with Stockholm Convention, it Within 1 week after the PCB is should be managed based on the concentration with respect to the volume of oil (litre). identified. Case 1. If any volume of oil with total PCB contamination See Section: 4.1.2 EDL level (%w/w) is less than 0.005% (50ppm), the PCB containing oil shall be disposed as hazardous waste (identified by Lao’s legislation) at end of useful life. Case 2. If volume of oil less than 5 L with total PCB Go to Step P3: EDL contamination level (%w/w) is greater than 0.05% (500ppm), the PCB contaminated oil shall be disposed as PCB contaminated waste in environmentally sound manner at end of useful life. Case 3. If volume of oil greater than 5 L with total PCB Go to Step P3: EDL contamination level (%w/w) is between 0.005% (50ppm) and 0.05% (500ppm), EDL shall notify to the relevant authority (MoNRE) of equipment. And the PCB contaminated oil shall be disposed as PCB contaminated waste in environmentally sound manner at end of useful life (but not later than 2028 as of Stockholm Convention). (P178477) First Draft Page 27 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Required Actions Guidance to be followed Responsible Entities Indicated Timeline Case 4. If volume of oil greater than 5 L with total PCB See Section 4.1.2 EDL contamination level (%w/w) is greater than 0.05% (500ppm), EDL shall notify to the relevant authority (MoNRE) of equipment. The immediate decontamination or disposal shall be performed in environmentally sound manner. (Immediate actions shall be performed within 90 days after project effectiveness) Step P3: For Case 2 and/or Case 3, it is necessary to confirm that EDL will arrange those PCB-contaminated transformers Within 2 weeks after the PCB is to be listed under the UNIDO financed project to be treated and/or disposed of. identified. 1. PMU and EDL will notify to MoNRE and will coordinate See Section 5.3 PMU with MoNRE and UNIDO to arrange or confirm those PCB containing and contaminated transformers to be treated/decontaminated under the UNIDO financed project. Step P4: If treatment will be performed under UNIDO financed project and/or any subsequent decontamination processes Treatment process shall be that may be put in place and agreeable to the Bank, it is evaluated that the PCB contaminated transformers will be managed performed within 8 weeks after under the safe and environmentally sound management procedures. Under UNIDO project, decontamination of PCB using the PCB is identified. a Mobile Treatment Facility will be undertaken at the Site. (P178477) First Draft Page 28 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Required Actions Guidance to be followed Responsible Entities Indicated Timeline 1. Contractor who will provide on-site treatment service See Section 4.1.1 PMU must be entity who was approved by MONRE under the UNIDO financed project or entity who will be approved by MONRE. Step P 4-1:PCB oil draining and new PCB-free oil filling TBD with contractor. Not later than 4 weeks after the contractor is selected. 1. It is prohibited to dismantle the transformer from As per guidance from the EDL PMU existing location before draining PCB contaminated oil or Decision of MoNRE (Dec containing oil. 2020) 2. The mobile treatment facility will be set up at safe Annex-1 and See Section Contractor location of the Site with concrete floor and proper 4.8 emergency preparedness for oil spillage or leakage during operation. 3. Draining PCB contaminated oil from the transformer See Section: 5 Contractor under UNIDO and filling a new PCB free new mineral oil to the financed project or a new transformer. contractor Step P 4-2: Dechlorination of PCB contaminated transformer oil TBD with contractor. Not later than 4 weeks after the contractor is selected. (P178477) First Draft Page 29 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Required Actions Guidance to be followed Responsible Entities Indicated Timeline 1. Dechlorination of PCB contaminated transformer oil See Section: Annex-1 Contractor under UNIDO finance Project or a new contractor 2. If the dechlorinated oil regeneration will be performed See Section: 4.4 Contractor under UNIDO finance at site, the packaging of regenerated oil (<5ppm of PCB) Project or a new contractor shall be sealed in proper drum/container to prevent accidental release. Step P5: Disposal of PCB contaminated waste TBD with contractor. Not later than 6 weeks after the contractor is selected. 1. All by-product materials including soil or water See Section: Annex-1 Contractor under UNIDO finance contaminated with PCB during the on-site treatment Project or a new contractor process of PCB using mobile treatment facility shall be packed, transported, and disposed in the environmentally sound management manner. Step P6: Relocation of Transformer with PCB-Free Oil TBD with contractor. Not later than 2 weeks after the contractor (Transformers with PCB-free transformer oil to be in service again if it is in good operation condition) is selected. 1. Dismantling and relocation of retrofilled Transformer See Section: 4.5 / 4.6 Experienced Contractor with PCB-free transformer oil to the temporary storage warehouse (P178477) First Draft Page 30 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Required Actions Guidance to be followed Responsible Entities Indicated Timeline 2. The retrofilled transformer will be mobilized to other See Section: 4.5 / 4.6 Experienced Contractor S/S for operation if it is in good operation condition and transformer life is <40 years. 3. Regular monitoring of presence of PCB in transformer EDL’s Engineering Team oil from those transformers The activities described in Step 1, P1, P2, P3 and P6 will be financed by the World Bank. If EDL could arrange PCB-contaminated transformers to be listed under UNIDO project for decontamination, as described in P3, the activities in P4 and P5 will go under UNIDO funded project. If it is not possible, any other subsequent decontamination processes that may be put in place and agreeable to the Bank will be considered. (P178477) First Draft Page 31 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 4 Management of PCB Related Hazardous Waste 4.1 Key Steps and Relevant Guidance 4.1.1 Requirements of Certified Contractors Under the proposed project, the followings steps will require to contract with certified contractors. 1. To implement Step 1, it is required to hire a certified contractor for performing sampling and testing of oils of all transformers to be removed from eight substations, by using a mobile analyzer funded under the Project. 2. To implement Step P4 and StepP5, Contractor who will provide on-site treatment service must be entity who was approved by MONRE under the UNIDO financed project or who will be approved by MONRE for EDL Project funded by WB. 3. To implement Step P6: it is required to hire an experienced contractor for performing handling. The contractor must be entity who is approved by MONRE. The Contractor working for EDL Project funded by WB involved in each step must be a MONRE approved entity and the contractor is required to submit a Contractor’s ESMP (See Annex-4 of ESIA) to the PMU and WB for prior review before commencing any relevant activities. The Contractor’s ESMP shall include the recommendations included in this HWMP. In case the steps (P4-1, P4-2, P5) for decontamination of PCBs are carried out under UNIDO financed project before the WB financed project becomes effective, EDL is required to document the process in a complete and timely manner. Once the WB project becomes effective, the WB will conduct due diligence of the process performed by the Contractor engaged under the UNIDO project before the proposed investment activities for this substation are approved. The Contractor who will be mobilized by UNIDO to provide PCB treatment to the transformer that will be replaced under the WB financed project will be required by EDL to follow the PCB treatment procedure set forth in the HWMP prepared under the WB financed project. The above requirements need to be reflected in the updated SS ESMP and being monitored by the PMU and E&S consultants. The monitoring report will be subjected the review and endorsement of the WB. (P178477) First Draft Page 32 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 4.1.2 Guidance for Implementation of Case 1 and Case 4 Case 1: For managing of PCB-containing transformers in which a volume of oil with a total PCB contamination level (%w/w) less than 0.005% (50ppm) is stored, EDL will take full responsibility for the disposal of the PCB-containing oil as hazardous waste (identified by Lao’s legislation) at end of its service life. The relocation of transformer must follow all relevant guidelines for handling, labelling, packaging, and transportation under this hazardous waste management plan. The EDL will continue to use these transformers at the alternate location, but they must be treated by 2028 in accordance with Stockholm Convention’s requirement. EDL will track the operation of these transformers and submit the monitoring report, including but not limited to maintenance history, emergency issues, regular inspection to the WB until the end of the Project. Case 4: For managing of PCB containing transformers in which a volume of oil greater than 5 L with a total PCB contamination level (%w/w) greater than 0.05% (500ppm) is stored, EDL must inform the competent authority (MoNRE) of equipment. Then, EDL will assume full responsibility for the immediate decontamination or disposal of the PCB- contaminated oil/equipment in an environmentally sound manner within six months of obtaining the analytical test results. The Contractor who may be contracted with EDL for compliance to the Project requirement by the WB must be a MONRE approved entity and the contractor is required to submit a Contractor’s ESMP to the PMU and WB for prior review before commencing any relevant activities. 4.2 Sampling Sampling for PCB contamination must be conducted properly. Any unidentified transformer will be presumed to be a PCB-containing transformer when the sample is collected. Adverse impacts associated with the sampling process include accidental spills, increased production of PCB waste and occupational hazards. Sampling shall be conducted with the following steps: • Before initiating the sampling, place a large metal tray under the drain cock to contain potential spills during the process. • Carefully open the drain cock and drain the adequate volume of sample into the sampling container. The type of containers to be used for the sample collection will be determined by the contracted laboratory. • When the adequate volume of sample is collected, close tightly the drain cock. • Seal the container and place it immediately into a labelled secondary sample container bag to prevent leaks. • Wipe spills from the sampling point. • Place equipment contaminated during the sample in a plastic bag for later disposal as PCB contaminated waste or decontamination. • At the end of the sampling, the used metal tray will undergo decontamination in the event of contamination with the sampled oil. (P178477) First Draft Page 33 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan In case of accidental spill during the implementation of the sampling protocol, an immediate response must be adopted to limit the impact of the spill. The following list summarizes the steps to be taken when cleaning up a spill: • Immediately close the drain cock. • Spray absorbent material on the spilled liquid. The absorbent will allow solidification of the spilled oil which will provide a quick containment of the spill. • Collect the solidified material by a disposable scoop. • Dispose of collected solidified material as well as any contaminated PPEs or equipment inside a labelled plastic bag for later disposal as PCB contaminated waste or decontamination. Teams conducting the sampling must be equipped with adequate PPE to ensure their safety throughout the process. This will include disposable coveralls, shoe covers, safety goggles and disposable PCB-resistant gloves (one pair per sample). A spill clean-up kit must be available to the sampling team for immediate intervention in case of accidental spills. Teams performing the sampling must undergo extensive training based on the protocols described and pass a competency prior to conducting the sampling on site. Failure to follow the above protocol will put the entire team at risk and place the site at unnecessary risk of contamination. Disposal of waste from sampling: Any contaminated material generated during the sampling of transformer oil must be carefully labelled in the same manner as the collected samples. Labelling will differentiate PCB-contaminated waste from uncontaminated waste generated during sampling and analysis once laboratory results are obtained. Segregation of the waste generated during this phase will reduce the volume of contaminated waste that will need to be treated later. The PCB-contaminated waste will be collected in plastic bags to be contained in specialized labelled and sealable drums and sent for interim storage. Packaging is addressed later in the report. 4.3 Labelling Labelling is required for following categories: • any equipment that contains or is likely to contain more than 5 liters of PCB- contaminated materials. • all entrances to the building where the PCB-contaminated equipment is located, and decontaminated transformers. • labeling of containers or containers containing PCBs or PCB contaminated wastes. All labels should indicate that the equipment (and premises containing equipment) is “Contaminated by PCBs” and must be visible, legible, indelible and in a color that contrasts with the equipment to which they are affixed. Alert personnel that the labelled equipment or waste requires special handling with appropriate PPE. (P178477) First Draft Page 34 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Examples of the labels are shown in the following diagrams. The material used for the label shall be durable, not easily torn or degraded. The words shall be printed in Lao and English language with clarity, precision, readability, and visibility. Label in Figure 4-1 should be used when the oil in transformer is tested positive with portable analyzers. Figure 4-1 Label for suspect PCB-contaminated Equipment Label in Figure 4-2 should be used for any container containing PCBs or PCB contaminated wastes. Figure 4-2 Label for Container Equipment contaminated with more than 0.05% total PCBs must be labeled as shown in Figure 4-3, as soon as contamination is confirmed. Label should mention the requirement of safe handling such as wear appropriate PPE for handling of PCB high risk contaminated equipment. All doors to the premises where the equipment is located should also be labelled with the same label. (P178477) First Draft Page 35 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Warning!! PCB-Contaminated Equipment Awaiting Disposal. Wear Appropriate PPE for Handling. Figure 4-3 Label for confirmed PCB-Contaminated Equipment PCB-contaminated equipment in authorized service containing less than 0.05% total PCBs shall be labeled as shown in Figure 4-4. All doors to the premises where the equipment is located should also be labelled with the same label. Warning!! In use PCB Contaminated Equipment <0.05% Internal PCB Oil Contamination less than 0.05% (500ppm) Wear appropriate PPE in case of handling. (P178477) First Draft Page 36 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Figure 4-4 Label for confirmed PCB-contaminated Equipment with Contamination less than 0.05% total PCB Although the GHS system is not widely implemented in Laos, the following hazards symbols must be used for storage and transportation of PCB-contaminated equipment in combination with above labels. These signs are intended to be understood regardless of the literacy or language skills of the workers viewing them. (P178477) First Draft Page 37 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Figure 4-5 Hazard Symbols for PCB-contaminated Equipment May cause damage to respiratory system through prolonged or repeated exposure; Do not Toxic to aquatic life with long lasting effects: eat, drink or smoke when using this product. Do Avoid release to the Environment not breathe dust/fume/gas/mist/vapors/spray. The transformers decontaminated below 0.005% total PCBs should be labelled with Figure 4-6. Figure 4-6 Label for transformers decontaminated below 0.005% PCBs Decontaminated PCB Equipment Fluid containing PCBs was replace - with ------------------------------------------- (name of substitute) - on --------------------------------------------- (date) - by --------------------------------------------- (undertaking) Concentration of PCBs in - Old Fluid ------------------------------------ (% by weight) - New Fluid ----------------------------------- (% by weight) 4.4 Packaging All containers of PCB containing or contaminated equipment, materials, liquids must be appropriately packaged with the following practices: (P178477) First Draft Page 38 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan • Packaging must be UN approved and conform to specific packaging requirements specified for PCB-contaminated equipment. Containers must be capable of retaining at least 1.25 times the volume of the PCB-contaminated materials in the equipment. It should be a leak proof inner packaging made of earthenware, plastic or metal. • Packaging used is typically plastic lined UN approved drums. For example, the outer packaging that is: (i) a drum made of steel, aluminium, plywood, fibre or plastic, or (ii) a box made of wood, plywood, reconstituted wood or fibreboard. There must be sufficient absorbent material in the packaging to absorb at least 1.1 times the volume of liquid which is contained in the devices. Sufficient absorbent material (capable of absorbing 110% of the internal volume of the packaged PCB material) placed between the inner and outer packaging to prevent any liquid from escaping from the outer packaging. “Absorbent material” includes any material such as sawdust, coconut fibre, or any of various other natural fibres that are inherently absorbent. • For disposal of PCB-contaminated equipment that does not fit into UN approved 120-200L metal drums, for example transformers and larger circuit breakers, the equipment should be packaged in heavy duty plastic bags and heat-sealed. The plastic bags containing the equipment should be tied together on loading pallets and carried in cargo transport units fitted with a leak-proof metal tray to a height of at least 800mm and containing sufficient absorbent material capable of absorbing 1.1 times the volume of liquid. • Liquids or solids contaminated with PCBs (e.g., rags, PPE) or small items of PCB- contaminated equipment should be: o Stored in 120-200L metal UN approved drums which are packed with absorbent material so that any leaks will be absorbed and hermetically sealed, o Small items of PCB-contaminated equipment should be wrapped in heavy duty plastic bags prior to storage in UN approved drums, o Small capacitors should be placed in the drum with the terminals upwards to prevent leaking, and o Stored so that an air space of 7 to 10 centimetres is left to allow for liquid expansion. Packaging of PCB-contaminated waste is to be done by the contractors under the management of UNIDO project or other contractor subsequently hired for additional decontamination work, which is believed to be conducted in a safe and appropriate manner which is internationally recognized. The Term of Reference (TOR) for transportation of PCB-contaminated waste is attached in Annex – 1. In addition to the works specified in the TOR, the above measures shall be undertaken. However, as the decontamination process is expected to be carried out by mobile equipment on site, the transportation of contaminated equipment or oil is not expected under this Project. (P178477) First Draft Page 39 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 4.5 Handling The contractors who will be involved in the process of handling equipment, materials, or wastes containing or contaminated with PCBs must follow the guidance described in the Guideline for PCBs Management and Disposal (2021). It includes separating PCB- containing or PCB-contaminated waste from other types of waste, inspecting containers for abnormalities, such as leaks, rust holes, high temperatures. If found, take immediate corrective action, cleaning up spill areas, if spilled, with cloth, paper, or absorbent materials such as sawdust, cleaning the contaminated surface with solvents such as kerosene at least three times, avoiding throwing away or bundling materials exposed to PCBs, such as absorbent materials, cloth, paper, plastic, and preventing the leakage of the wasted dirty liquid into public water sources. The contractors shall ensure that all the staffs must be provided with required health and safety trainings related with PCBs risks, electricity safety and hazard control measures, environmental safety measures associated with the removal of contaminated equipment and prevention and management of possible PCB spills. However, as the decontamination process is expected to be carried out by mobile equipment on site, the transportation of contaminated equipment or oil is not expected under this Project. Health and Safety Each substation, where transformer removal is intended must has – • PPE required for the site staffs assisting contractors / EDL engineering teams • Spill Kits • Spill response procedures All staffs dealing with handling, draining PCB-contaminated oil and/or decontamination of PCB-contaminated equipment must: • wear adequate Personal Protective Equipment (PPE) i.e., one-piece chemical resistant suit, chemical resistant gloves, boots; and if deemed required face breathing mask. • ensure to have adequate ventilation in the area where the PCB-contaminated equipment. • When handling PCB fluids, or when the potential for close contact with PCBs exists (e.g., leakage inspections, spill clean-up, transfer from transformer to drums, etc.) proper clothing and gear must be worn to prevent contact with skin and eyes from spills, splashes and also, to prevent inhalation of fumes which may be generated when PCB fluids are heated above 55ºC. • In any operation where there is risk of contact, plastic or rubber clothing should be worn, including gloves, boots, overalls, and chemical resistant apron which covers the boot tops. Eye protection is necessary whereas chemical safety googles, face shields or safety glass with side shields are all satisfactory. Clothing that has become contaminated must be disposed as a PCB waste. (P178477) First Draft Page 40 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan • Handling of hot PCB fluids must be avoided. A full-face respirator is required when fluid temperatures exceed 55ºC. Ventilation of the working area must also be sufficient to remove generated vapours. Electrical Safety It must be ensured that PCB-contaminated equipment is disconnected from the electricity supply, before draining, moving it to storage or transport vehicle, commencing decontamination, or disposal activities. Work in Confined Spaces Prior to entry and occupancy, all confined spaces (e.g., tanks, sumps, vessels, etc.) must be tested for the presence of toxic, flammable and explosive gases or vapours, and the lack of oxygen. Adequate ventilation must be provided before entry and during occupancy of these spaces. Personnel must use air-supplied respirators when working in confined spaces which may become contaminated or deficient in oxygen during period of occupancy. Observers/assistants must be stationed outside of confined spaces to provide emergency assistance, if necessary, to personnel working inside these areas. 4.6 Storage The appropriate storage facilities/area shall be required in case of the following situations: (1) Relocation/ temporary storage of retrofilled transformers (2) Temporary storage of PCB contaminated oil (in case of drained oil is packaged for transportation) (3) Temporary storage of PCB containing or PCB contaminated waste The appropriate storage area or facilities shall meet the following characteristics are met. • Location – The storage area should be distant from sensitive areas such as community areas, schools, hospitals, water bodies at least one kilometre away. It should not be prone to natural disasters such as flooding. • Spill Containment - The storage area should be bunded. The floors and bund should be impermeable to PCBs. All floor drains, sumps or other openings in the floor should be closed and sealed to prevent the release of liquids. Spill kits should be readily available, and all staff authorised to enter the storage area must be trained in using spill kits and the hazards associated with PCBs. • Security – The storage area should be securely locked, and access should be restricted to the authorised personnel. Doors must be appropriately labelled (see section 4.3) (P178477) First Draft Page 41 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan • Fire protection – PCBs and PCB-contaminated equipment must be kept separate from flammable materials and holders should take all necessary precautions to avoid any risk of fire involving PCBs. The storage of combustibles should not be allowed within 10 metres of the equipment, and the storage area should have the necessary firefighting equipment. • Firefighting – Non-water fire extinguishing system such as chemical firefighting extinguishers are recommended to install. • PCBs segregation - No other waste should be stored within the designated storage area and no manufacturing or other activity should be undertaken there. PCB-contaminated oil must not be mixed with other waste oils. • Adequate ventilation – there should be a fresh air inlet and an air exhaust to the outside. • Weatherproofing – The storage area (especially for transformer casing) should be located indoors, but if this is not possible an outside storage area should be covered with a waterproof barrier that protects the PCB-contaminated equipment and/or waste PCB containers and prevents moisture from entering the curbing or sides of the floor surface underneath. • Control the temperature in the storage building to a low temperature because the higher the temperature, the more PCB will evaporate. (UNEP recommends to control the temperature in the storage building below 25 degree Celsius). 4.7 Transportation Any PCB equipment containing more than 500g of PCB mixture must not be transported unless the PCB equipment has been securely contained and packaged as described in Section 4.4. The driver must be instructed as to precisely what is being loaded onto the vehicle. The vehicle should be stabilized with the appropriate equipment (e.g., wheel chocks) and adequate warning signs erected in the area where loading takes place. At a minimum for all PCB-contaminated wastes (and especially for transformers): • Liquid-proof containers or trailers with a drip tray capable of storage of the fluid contents of the equipment being transported must be used. The sides of the trailer and container must be higher than the shipped materials, to ensure full coverage. • There must be internal fixing points with adequate load bearing to fasten the equipment securely. • There should be a completely open loading platform for unloading operations. • Adequate weatherproofing must be provided, such as a tarpaulin (cover), to prevent water infiltration during transportation. (P178477) First Draft Page 42 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan • For disposal of PCB-contaminated capacitors that do not fit into UN approved 120 200L metal drums the capacitors should be packaged in heavy duty plastic bags and heat-sealed. The capacitors should be tied together on loading pallets, and • Liquids or solids contaminated with PCBs or small items of PCB-contaminated equipment should be packed as outlined in Section 3.4. However, as the decontamination process is expected to be carried out by mobile equipment on site, the transportation of contaminated equipment or oil is not expected under this Project. 4.8 Emergency Response I. Spill Response Procedures The response in case of leaks and spills must be immediate and include the following steps: • The staff must be equipped with clothing and accessories for personal protection. • Stop and contain the spill source, close a valve, seal the container and apply absorbent material in the venue. • Communicate the emergency to the head of substation and E&S Division of EDL. • Assess the magnitude of the emergency and proceed accordingly. • If the spill is on a flat surface, apply absorbent blankets or sawdust and then deposit blankets or sawdust with shovels into containers that are kept for this purpose. • If the spill was caught in a catchment tank, it needs to be pumped and deposited in containers. • After the spill has been cleaned up, samples need to be taken to check whether the soil has been contaminated. • If the contamination persists on the surface, it might be necessary to remove the contaminated layer to subsequently eliminate it. • Personal protective clothing and accessories which are contaminated, need to be stored and disposed of as PCB waste. • All contaminated tools and equipment made of metal should be stored as such, but separately from other waste to verify the possibility to decontaminate them. • All contaminated waste arising from the operation, such as water used for washing, absorbent material, clothing, debris, etc. should be placed in airtight containers for destruction by an authorized entity later on. Staff dealing with spills must take the following first-aid precautions: • if PCBs come into contact with eyes, immediately irrigate eyes with water for at least 15 minutes and obtain medical attention. • if PCBs come into contact with skin, immediately remove any contaminated clothing and wash affected skin with soap and water. (P178477) First Draft Page 43 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan • if swallowed, wash out mouth several times with clean water, drink water, and obtain medical attention; and • if inhaled, move to a fresh air zone and obtain medical attention. If the “emergency event” involves a chemical leakage from the electric transformers or a leakage of the waste while it is being transported, the transporter must formally report the incident to the local administration. In addition, at the provincial level, the Department of Natural Resources and Environment and the Department of Industry and Commerce must be notified. 4.9 Health and Safety Protection Prior to working on suspected or confirmed PCB-contaminated equipment, protection measures should be in place and relevant staff should be trained on chemical safety, electrical safety and spill management. Health, safety, and environmental considerations apply equally to PCB-contaminated equipment owner, EDL staff, and all companies and staff contracted to service, dismantling, transport, decontaminate or dispose of such equipment. Emergency Response in case of Fire Although PCB is classified as inflammable liquid, it is added to transformer oil and thus mixed oil will burn if it catches a fire or at high temperatures. Therefore, they should be stored separately from other flammable products such as fuel oil, coal, wood products and compressed gases. During the combustion and pyrolysis of PCB, polychlorinated dibenzofurans (PCDFs) and polychlorinated dibenzodioxins (PCDDs) can be formed. These substances can be even more toxic than PCB and they can be the main hazard from a PCB fire. In the case of a fire, the following steps should be taken: • Immediately upon noticing the fire, set off the alarms. • Notify the head of substation and fire-fighters. • The personnel assigned for this procedure must be equipped with clothing and accessories for personal protection. • Apply suitable extinguishing material on the fire. Materials used to extinguish fires involving PCB are chemical foam, carbon dioxide, nitrogen flow and dry chemicals. Water should not be used as it will become contaminated and increase the area of contamination. • All waste products of the fire should be cleaned similarly to the procedure detailed for spills. • The personal protection clothes and accessories which are contaminated should be stored as PCB waste. (P178477) First Draft Page 44 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan • Clothes worn should not be washed for re-use but should be considered as contaminated waste. • After the fire has been extinguished, the affected area should be closed off by fencing, to perform the clean-up. (P178477) First Draft Page 45 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 5 Treatment PCB contaminated oil of transformer The treatment and disposal of PCB contaminated waste including transformer oil, transformer and associated waste generated from process of treatment and handling will be conducted by the contractor under UNIDO Project or a new certified contractor of EDL approved by MONRE. The detail scope of work and technical information can be found in the TOR for PCB treatment service as attached in Annex -1 and briefly explains in section 5.2. The PCB contaminated transformer oil (>50 ppm and <4000ppm) will be treated with dechlorination system and the dechlorinated oil regeneration system. The final concentration of PCB in the dechlorinated fluid shall be 5 ppm or less. 5.1 Retrofilling of Transformers Retrofilling of transformer means that a crude decontamination method that involves draining PCB-contaminated oil from a transformer and refilling it with a PCB-free insulating fluid. (EPA (Ireland)) 1) Depending on the size of the transformer, sufficient time must be allowed (at least two hours or more) to ensure all PCB contaminated oil will drain completely from the old transformer. It is recommended that pumping be used to minimize residual PCB contamination (prior to retrofilling). 2) Once the old transformer is completely drained, the transformed will be re-filled with PCB-free insulating fluid. The residual PCB concentration in the transformer’s fluid following retrofilling could be approximately up to 10% of the original PCB contamination. Applying the 10% approximation, if a transformer containing less than 0.5% (5000ppm) is retrofilled correctly, a residual PCB concentration of between 0.005% (50ppm) and 0.05% (500ppm) total PCB is probable but not guaranteed. 3) Retrofilling will be undertaken by Contractor experienced in working with high voltage equipment and in replacing dielectric fluids. 4) Once a PCB-contaminated transformer is retrofilled, it should be put back into operation for at least 90 days before the oil can be sampled for analysis for PCB content. Test to be taken must conform to IEC 61619. If residual PCB contamination is below 0.05% (500ppm) of the total PCB then decontamination by retrofilling is considered successful. 5) It is important to note that retrofilled transformer with PCB contamination of more than 0.005% (50ppm) (but less than 0.05% (500ppm)) is still considered a PCB- contaminated transformer and must be disposed of as PCB contaminated waste at the end of its life cycle. There are also other requirements associated with in- use PCB-contaminated equipment, such as labelling and annual notification to the MoNRE. (P178477) First Draft Page 46 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 5.2 General description of the mobile unit for chemical dechlorination and regeneration of PCB oil from electrical equipment4 UNIDO has selected the contractor for provision of PCB treatment service (SetCar). It presents about the function of mobile treatment unit for chemical dechlorination and regeneration of PCB contaminated oil. Oil generation process follows five steps below: (1) Extraction of PCB oil from electrical equipment. (2) Dehalogenation of PCB contaminated oil. (3) Purification of the treated oil by filtration. (4) Regenerating (by degassing and dehydration) filtered oil. (5) Refilling the electrical equipment with treated oil. Technology proposed by Setcar (contractor for a PCB treatment service under UNIDO finance project) guarantees the achievement of the following treated oil parameters: • PCB final concentration: minim 1-5 ppm • Water content: 6-7 ppm • Impurity size: <1µm • Breaking strength: >250 kV/cm The mobile treatment unit for chemical dechlorination and regeneration of PCB oil from electrical equipment is installed in the container box and it is equipped with three modules: Module 1- two de-chlorination reactors, reactor for reagent preparation, mixer, heat exchanger, activated carbon filter, drop separator, pumps, electrical panel; - Module 2 - filter press, thermal boiler, oil tanks, filter bags, pumps, oil dehydration unit (Capacity 1m3/h) electrical panel; Module 3 - filter press, oil degassing and dehydration unit (Capacity 4m3/h), pumps, electrical panel, ventilation unit. 5.3 Disposal of PCB contaminated waste Hazardous waste (i.e., any unused reagent and by-products) generated at each step, including sampling and treatment processes will be disposed of appropriately by the contractor at local and/or international facilities if Lao PDR does not have approved facilities to accept such wastes. 5.4 Timeline for Treatment and Disposal The detail timeline for treatment and disposal process of PCB-contaminated waste at each substation will be prepared during the preparation of the site-specific ESMP after project effectiveness. EDL will ensure the commitment of the contractor under UNIDO finance project for the treatment of PCB-contaminated oil and transformer three month after project effectiveness or at the time of preparation of site-specific ESMP. 4 SetCar: presentation for Lao, (Contractor under UNIDO finance project) (P178477) First Draft Page 47 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 6 Institutional Responsibilities, Monitoring, and Reporting 6.1 Project Owner The Electricite Du Laos (EDL) is the project implementing organization and EDL will take the owner role to comply with the agreement on management and monitoring of PCB decontamination and disposal of electric transformers, stipulated under Ministry of Natural Resources and Environment (MoNRE). According to the above-mentioned Agreement, the following are the key role and responsibilities of the EDL, • The owner of transformer and PCB-contaminated waste shall keep the storage of transformer and waste while waiting for the decontamination and disposal. [Article 6 Storage and Transportation of Transformers and PCB-contaminated Waste] • The owner of transformer and PCB-contaminated waste shall report the status of storage to the provincial departments including Natural Resources and Environment, Energy and Mines, Industry and Commerce for every six months in order to conduct monitoring. [Article 6] • In the event of leakage or emergency, he or she shall take responsibility in solving the cause and preliminary impact of such incident then reporting to the village authorities, and district/municipality/capital authorities with timely manner in order to allow the authorities to alert the people. In addition, the owner of transformer and PCB-contaminated waste shall also inform the Provincial Department of Natural Resources and Environment and other line sectors of the province(s)/Vientiane Capital City to take the corrective action. [Article 6] • The decontamination of PCBs in transformer shall be operated by the approved service provider as stipulated in Article 13 of this Agreement by information the Provincial Department of Industry and Commerce, and Natural Resources and Environment five working days prior to the decontamination. The person who manages and uses the transformer shall be responsible for any expenses derived from PCB decontamination based on the agreement with the service provider as well as the costs of participation by the line sectors in accordance with the financial regulations. [Article 10 Decontamination of PCBs in Electric Transformer] • The disposal of PCBs in electric transformers and waste shall be implemented in similar manner of decontaminating PCBs in electric transformer as stipulated in the Article 10 of this Agreement. [Article 11 Disposal of PCBs Electric Transformer] • Upon completion of decontamination, the Provincial Department of Natural Resources and Environment shall issue the certificate endorsing the result of the decontamination for the person who manages and uses transformer and shall report (P178477) First Draft Page 48 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan to the Department of Pollution Control and Monitoring within ten working days. [Article 10] The following are the rights of the EDL as per the agreement- 1) Being protected in terms of legitimate rights and interests in accordance with the laws and regulations. 2) Receiving information about the waste containing PCBs. 3) Proposing, complaining or claiming about violations of his/her rights in operating business services of decontamination and disposal of PCBs in electric transformer and PCB-contaminated waste; and 4) Exercising other rights as stipulated by the laws and regulations. The following are the obligation of the EDL as per the agreement- 1) Respecting and strictly complying with the relevant laws and regulations. 2) Paying custom duties, taxes and implementing other obligations in relation to the management of electric transformer and PCB-contaminated waste in accordance with the laws and regulations. 3) Building the premise that provides storage of transformers and PCB-contaminated waste waiting for decontamination and disposal. 4) Providing information and reporting about the management of electric transformer and PCB-contaminated waste to the Provincial Departments: Natural Resources and Environment and Industry and Commerce. 5) Being liable for any damages caused by negligence, reckless or self-intention in managing the electric transformer and PCB-contaminated waste. 6) Facilitating relevant sectors in performing their duties in accordance with the laws; and 7) Implementing other obligations as stipulated by the laws and regulations. During implementation period for decontamination process, EDL’s Engineering Team of PMU will monitor the contractor of the UNIDO for complying with the requirement of UNIDO’s TOR by cooperation with MoNRE. The EDL’s PMU will ensure that the guidance in this HWMP is applied during the PCB treatment process. EDL’s PMU will ensure the completion of decontamination of PCB contaminated liquids of the transformers removed before ending of Proposed Project Implementation. And EDL shall obtain the certification endorsing the results of the decontamination from Provincial Department of Natural Resources and Environment and report the acceptance of certificate to the WB. 6.2 Relevant Governmental Ministries and Departments The following table indicated the role and responsibilities of relevant governmental ministries and departments which involves in management and monitoring of PCB decontamination and disposal of electric transformers as per the agreement. (P178477) First Draft Page 49 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan No. Provincial Responsibilities Departments 1 Natural Resources and The Provincial Department of Natural Resources and Environment (NRE) Environment shall propose the Provincial Department of Industry and Commerce to consider the order to suspend the business operation in decontamination and disposal of PCBs in electric transformer and PCB-contaminated waste in order to take the corrective actions. [Article 14 Suspension and Termination of Business Operations in Decontamination and Disposal of PCBs in Electric Transformer] In the case of not taking the corrective action as mentioned, Provincial Department of Natural Resources and Environment shall propose the Provincial Department of Industry and Commerce to consider the order to terminate the business operation in decontamination and disposal of PCBs in electric transformer and PCB-contaminated waste. [Article 14] Upon completion of decontamination, the Provincial Department of Natural Resources and Environment shall issue the certificate endorsing the result of the decontamination for the person who manages and uses transformer and shall report to the Department of Pollution Control and Monitoring within ten working days. [Article 10 Decontamination of PCBs in Electric Transformer] The Provincial Department(s) of natural Resources and Environment coordinates with Provincial Department(s) of Energy and Mines, Industry and Commerce, other departments and Electricity Du Laos, electric service providers, the relevant district offices and the District Office(s) of Natural Resources and Environment to conduct the survey and inventory of PCBs in electrical transformers within its local boundaries, followed by reporting the Provincial/Vientiane Capital Administrations and the Department of Pollution Control and Monitoring in order to centrally consolidate, conduct inventory nationwide and to report the top authorities of MoNRE. [Article 4 Survey and Inventory] (P178477) First Draft Page 50 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan No. Provincial Responsibilities Departments 2 Department of Pollution The Department of Pollution Control and Monitoring Control and Monitoring coordinates with the line agencies of Ministry of Energy and Mines, Industry and Commerce, Public Works and Transportation, and other ministries, and concerned local authorities to conduct the study and propose the site designated for decontamination and disposal of PCBs in electric transformer and PCB-contaminated waste to the Ministry of Natural Resources and Environment for further endorsement. [Article 12 Decontamination and Disposal for PCBs in Electric Transformer] The Department of pollution Control and Monitoring shall be responsible in developing the management plan and monitoring the PCB contamination and disposal of electric transformers through the collaboration with line ministries such as energy and mines, industry and commerce, and others, and concerned local authorities, then proposing the Minister of Natural Resources and Environment for endorsement in accordance with agreement by the Minister of Energy and Mines, and the Minister of Industry and Commerce. [Article 5 Developing Management Plan and Monitoring of PCB Contamination and Disposal for Electric Transformers] 6.3 Contractor Under UNIDO Project (Service Provider for PCB Treatment Process) The contractor will take the role and responsibilities of service provider as identified in the agreement. According to the Articles-13 of the agreement: Article 13 Service Provider of Decontamination and Disposal of PCBs in Electric Transformer An individual, legal entity or organization intending to decontaminate and dispose of PCBs in electrical transformers as well as PCB-contaminated waste shall apply the business operating permit with the industrial and commercial sector in order to coordinate with the Natural Resources and Environmental sector for further consideration in accordance with the laws. The person applying for the business operating permit to provide services in decontamination and disposal services for PCBs in electrical transformer and PCB- contaminated waste shall meet the following conditions: - Acquire technical and specialized skills with experience in the decontamination and disposal of PCBs in electrical transformers and PCB-contaminated waste. (P178477) First Draft Page 51 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan - Have a premise that can be used for decontamination and disposal services in accordance with the Article 12 of this Agreement; and - Have the right tools, equipment, vehicles and suitable technologies. Moreover, the contractor will implement the specific scope of works and its responsibilities upon decontamination process of PCB contaminated oil and retrofilling of transformer casing as identified in the term of reference (TOR) with the UNIDO. The TOR is attached in Annex-1. All handling, storage, packaging, transportation and process activities under UNIDO project will be implemented according to the Lao PDR’s national legislations related to toxic and hazardous chemicals including PCBs and other POPs, if available or according to USEPA or European Union pertinent international standards and guidelines for PCBs management. The contractor shall follow the guidance of this HWMP where appropriately when the handling of PCB contaminated transformers under Proposed Project. (P178477) First Draft Page 52 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 7 Capacity Building 7.1 Current Trainings by Safety Unit of EDL The EDL‘s safety unit of the Technical Standard Division under System Planning Department annually provides safety-related training to the staff of SSs. The training materials usually used for training programs are as followed: 1) Safety in working with high voltage transmission lines and substations [Human Resource dept., safety office] • Danger from high voltage electricity • Mistakes by people (3 “I) and how to solve • Innocence • Ignorance • Intention • Impact on people and electrical equipment. • Prohibitions and precautions should be taken to work in high voltage stations. • Prohibition of working in high voltage stations • Precautions for working in high voltage stations • Correct work principles for working in high voltage stations. • Relationship process. • The daily duties of the fire station staff 2) Safety Regulation and punishment policies for workers at substations – high voltage transmission lines and national control center (NCC, RCC) [EDL System planning dept., Technical Standard Division Safety Unit] • Part I General principles • Part II Management – Protection • Part III Safety regulation and working standards for substations and (power) national control center (NCC, RCC) • Part IV safety rules and procedures for high voltage transmission work • Part V Punishment for those who breach those rules 3) Job Safety Analysis • What is Job Safety Analysis (JSA)? • Ways to foresee, study about or anticipate risks • Steps for JSA? • Task selection or categorization for JSA. • Categorization • Risk anticipation in each working steps • Ranking of magnitude of risks/incidents • Extreme risk • Medium risk/impact (P178477) First Draft Page 53 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan • Low impact/risk • Ranking of opportunities for those risk to occur • Opportunities that risks will occur • Questions which workers should be asking to anticipate risks/unsafe incidents • Ways those accidents/incidents could occur • Searching for/study about preventive measures • Use existing JSA • JSA: Worker’s selection • Advantages of JSA • Job Safety analysis form 4) Worker protection equipment, PPE [State Electricity Enterprise of Laos, Power System Planning Department, Technical Standards Department, Safety Technical Unit] • What is worker protection equipment. • Types of worker protection equipment. • The benefits of worker protection. • Maintenance of worker protection equipment. • Principles of using general tools and equipment. • Pictures of correct and incorrect dressing. Recently, additional training material entitled “guidance on PCB containing electrical equipment” was prepared and tr PCB hazard training was initiated as part of the safety unit's training program to raise awareness of PCB hazards and prevent direct exposure to PCBs when using PCB containing electrical equipment. The content of training is mainly organized based on information guided by the guidelines for PCB management and disposal developed by MoNRE in 2021. The training materials need to be improved by applying good practices or international guidelines, as the current version contains only limited information for the staff. 7.2 Proposed Training Programs The content of this HWMP shall be delivered at the specific training programs presented in the ESIA study under Proposed Project. After the project's effectiveness, a series of training are planned to provide to relevant stakeholders/staff. The training related to implementation of ESIA including HWMP will be provided at Headquater Level and training related to implementation of SS-ESMP including HWMP will be provided at substation level (SSs) two times before the project implementation and during the project implementation. (P178477) First Draft Page 54 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Staff of EDL/Contractor’s employees enrolled in project implementation where hazardous materials are used or hazardous wastes are generated or PCBs are handling, those are required to receive training on the hazards associated with PCBs containing equipment, liquids, and materials and how to respond to emergencies. In addition, the EDL’s Staff/ Contractor requires training on handling spills, releases, and other emergencies. Hazards related to PCBs exposures and Safety measures shall be disseminated at the workplace. Special clean up supplies for PCBs spills shall be available and employees/workers shall be trained on how to properly use them. The following table showed the detailed Information of trainings related to HWMP which are included in the list of trainings required for implementation of E&S instruments developed under the ESIA. Table 7-1 List of Trainings relevant to HWMP Targeted audience Number No. Training Topic (No. of of Timeline Trainers Participants) trainings Training at Substation Level 1. Training for SS staffs at targeted 2 Before the E&S Division & implementation Substations project E&S of SS-ESMP & implementation Consultant(s) HWMP stage/ During and Certified project contractor implementation (implementation of HWMP) Special Trainings 1, Oil Sampling for Maintenance Team 1 Before the Supplier of PCB test or PCB under Transmission project portable PCB testing with Line and Substation implementation analyzer portable Maintenance stage analyzer/ Safety Division of EDL, measures for PMU PCB handling (P178477) First Draft Page 55 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Targeted audience Number No. Training Topic (No. of of Timeline Trainers Participants) trainings 2. Training Related Safety Unit & SS 1 During project E&S to Emergency Staff, Contractors implementation Consultants Preparedness/ Safety for Handling of Hazardous Material and Waste 7.3 Estimated Budgets Current training at each SS takes about 1 day and the training cost for each training is ranged from 1000 USD to 1500 USD. More in depth training for maintenance staff that would be directly handling the decontamination work with MONRE/UNIDO project team would be provided. The training cost for HWMP will be covered under the technical assistance budget in Component 1 of the Proposed Project. (P178477) First Draft Page 56 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan 8 Budgets for Hazardous Waste Management 8.1 Budget for Decontamination of PCB-contaminated liquid and equipment and disposal of associated PCB contaminated waste The decontamination process for PCB-contaminated liquid and equipment including the disposal of the associated PCB waste will be executed by the contractor under the UNIDO project. Moreover, the EDL will ensure that the required budget for the decontamination of all PCB tested transformers to be observed during project implementation of this project is available in case that these transformers are not covered under the current UNIDO project. At this stage, out of 12 transformers to be replaced under this project, 1 PCB contaminated transformer at Nalae Substation is covered under the UNIDO project. Hence, the maximum estimated budget for decontamination of 11 proposed transformers including the disposal of the associated PCB waste (assuming that all proposed transformers are contaminated) is 550,000 USD (50,000 USD for each transformer) and 10% contingency for further newly proposed substations. 8.2 Budget for Disposal of PCB-contaminated waste associated with PCB- contaminated liquid and equipment during PCB testing process The estimated budget for PCB testing which includes the disposal of PCB-contaminated waste such as PPE, small containers, etc. generated from the PCB testing process at 8 project sites is 40,000 USD (5,000 USD for each site). Moreover, the detailed budget including consultation, and compliance monitoring required for implementing this hazardous waste management plan will be estimated and included in the site-specific ESMP. (P178477) First Draft Page 57 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 58 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Annex-1 : TOR for PCB Treatment Services Under UNIDO Project (P178477) First Draft Page 59 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 60 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 61 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 62 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 63 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 64 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 65 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 66 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 67 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 68 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 69 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 70 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 71 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 72 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan Annex-2: Inventories Results for big transformers PB The table of Big Transformers contaminate PCBs > 50ppm in 4 Provinces Field sampling Lab Analysis No. Sampling PCBs PCBs PCBs Inventory Transfomer Transfomer Electicity Transfomer Transfomer Sampling Transformer Oil Other Field Recived Remark on Analysis Location GPS photo Village location Year Trademark Producer Oil level Resonsible by sample Concentation Concentation Date No. Use No. purpose statue Detail point weight (Kg) volume (L) information Sample by SP by Lab SP by condition <50 ppm >50 ppm Power: Chang Xayyabouly Electric Xayyabouly Chang 20.000KVA EDL Mr Tui 1 13616 Using 2018-87-111 2013 zhouxd sf10- Public bottom 47,000 13,400 PS 51.5 stations Province zhouxd.Ldt Voltage: sayyabouly nanthavong 20.000⁄115 115/22 KV Power: 20 Oudomxay 2 13456 Nalae Electric station N/A N/A N/A N/A N/A N/A KVA Voltage: bottom N/A 12,500 EDL Mr Bey PS 104 Province 115 KV Power: Ponsavanh Electric Xiengkhuang ABB Transmit 16000KVA EDL Mr Tui 3 13134 Using 801500 2002 Public bottom 52,600 14,700 PS 115 stations Province Transmit oy Voltage: xiengkhuang nanthavong 115/22 KV Power: Namnguem 5 Electric Xiengkhuang chon dong 20000KVA EDL Mr Tui 4 13473 do not used 10206 2011 China Public bottom 63,560 16,600 PS 978 stations Province tai kai Voltage: xiengkhuang nanthavong 115/22 KV Power: 20 Nongsaphaothong Auttapue MVA 5 13617 N/A N/A N/A N/A N/A N/A bottom N/A 9,700 EDL Mr Bey PS 51.4 Electric station Province Voltage: 115/22 KV (P178477) First Draft Page 73 of 74 Lao PDR: Domestic Grid Optimization Project Hazardous Waste Management Plan (P178477) First Draft Page 74 of 74