Document of The World Bank Report No: ICR00003593 IMPLEMENTATION COMPLETION AND RESULTS REPORT (TF-94744) ON A GEF GRANT IN THE AMOUNT OF US$ 7 MILLION TO THE SOCIALIST REPUBLIC OF VIETNAM FOR A PCB MANAGEMENT PROJECT December 23, 2015 Environment and Natural Resources Global Practice EAST ASIA AND PACIFIC REGION CURRENCY EQUIVALENTS Exchange Rate Effective June 30, 2015 Currency Unit = Vietnamese Dong (VND) VND21,821 = US$1 FISCAL YEAR January 1 – December 31 ABBREVIATIONS AND ACRONYMS CPS Country Partnership Strategy DA Designated Account DONRE Department of Natural Resources and Environment EA Environmental Assessment EMP Environmental Management Plan EVN Vietnam Electricity FM Financial Management GA Grant Agreement GEF Global Environment Facility GEO Global Environmental Objective ISR Implementation Status and Results Report MOIT Ministry of Industry and Trade MONRE Ministry of Natural Resources and Environment MT Metric Ton MTR Mid-term Review NAP National Action Plan NIP National Implementation Plan NSC National Steering Committee PAD Project Appraisal Document PCB Polychlorinated Byphenil PCD Pollution Control Department PIM Project Implementation Manual PMU Project Management Unit POPs Persistent Organic Pollutants QCBS Quality- and Cost-based Selection TOR Terms of Reference VEA Vietnam Environmental Administration Senior Global Practice Director: Paula Caballero, GENDR Practice Manager: Iain G. Shuker, GENDR Project Team Leader: Ruxandra Maria Floroiu, GENDR ICR Team Leader: Solvita Klapare, GENDR COUNTRY PCB Management Project CONTENTS Data Sheet A. Basic Information B. Key Dates C. Ratings Summary D. Sector and Theme Codes E. Bank Staff F. Results Framework Analysis G. Ratings of Project Performance in ISRs H. Restructuring I. Disbursement Graph 1. Project Context, Global Environment Objectives and Design ................................... 1 2. Key Factors Affecting Implementation and Outcomes .............................................. 4 3. Assessment of Outcomes ............................................................................................ 9 4. Assessment of Risk to Development Outcome......................................................... 13 5. Assessment of Bank and Borrower Performance ..................................................... 14 6. Lessons Learned ....................................................................................................... 15 7. Comments on Issues Raised by Borrower/Implementing Agencies/Partners .......... 17 Annex 1. Project Costs and Financing .......................................................................... 18 Annex 2. Outputs by Component ................................................................................. 19 Annex 3. Economic and Financial Analysis ................................................................. 30 Annex 4. Bank Lending and Implementation Support/Supervision Processes ............ 31 Annex 5. Beneficiary Survey Results ........................................................................... 33 Annex 6. Stakeholder Workshop Report and Results................................................... 34 Annex 7. Summary of Borrower's ICR and/or Comments on Draft ICR ..................... 36 Annex 8. Comments of Cofinanciers and Other Partners/Stakeholders ....................... 43 Annex 9. List of Supporting Documents ...................................................................... 44 MAP A. Basic Information Vietnam PCB Country: Vietnam Project Name: Management Project Project ID: P099460 L/C/TF Number(s): TF-94744 ICR Date: 10/20/2015 ICR Type: Core ICR Lending Instrument: SIL Borrower: MONRE & MOIT Original Total USD 7.00M Disbursed Amount: USD 6.83M Commitment: Revised Amount: USD 7.00M Environmental Category: B Global Focal Area: P Implementing Agencies: Vietnam Environmental Administration (VEA), Ministry of Natural Resources and Environment (MONRE) Ministry of Industry and Trade (MOIT) Vietnam Electricity (EVN) Cofinanciers and Other External Partners: N/A B. Key Dates Revised / Actual Process Date Process Original Date Date(s) Concept Review: 09/29/2005 Effectiveness: 03/12/2010 Appraisal: 02/06/2009 Restructuring(s): 12/16/2014 Approval: 06/23/2009 Mid-term Review: 07/09/2012 10/08/2012 Closing: 12/31/2014 06/30/2015 C. Ratings Summary C.1 Performance Rating by ICR Outcomes: Moderately Satisfactory Risk to Global Environment Outcome Moderate Bank Performance: Moderately Satisfactory Borrower Performance: Moderately Satisfactory C.2 Detailed Ratings of Bank and Borrower Performance Bank Ratings Borrower Ratings Quality at Entry: Satisfactory Government: Satisfactory Implementing Quality of Supervision: Moderately Satisfactory Moderately Satisfactory Agency/Agencies: Overall Bank Overall Borrower Moderately Satisfactory Moderately Satisfactory Performance: Performance: C.3 Quality at Entry and Implementation Performance Indicators Implementation QAG Assessments Indicators Rating Performance (if any) Potential Problem Quality at Entry Project at any time No None (QEA): (Yes/No): Problem Project at any Quality of Yes None time (Yes/No): Supervision (QSA): GEO rating before Moderately Closing/Inactive status Satisfactory D. Sector and Theme Codes Original Actual Sector Code (as % of total Bank financing) General energy sector 50 50 Public administration- Energy and mining 10 10 Public administration- Industry and trade 10 10 Solid waste management 30 30 Theme Code (as % of total Bank financing) Environmental policies and institutions 30 50 Pollution management and environmental health 70 50 E. Bank Staff Positions At ICR At Approval Vice President: Axel van Trotsenburg James W. Adams Country Director: Victoria Kwakwa Victoria Kwakwa Practice Iain G. Shuker Hoonae Kim Manager/Manager: Project Team Leader: Ruxandra Maria Floroiu Douglas J. Graham ICR Team Leader: Solvita Klapare ICR Primary Author: Solvita Klapare F. Results Framework Analysis Global Environment Objectives (GEO) and Key Indicators (as approved) The development objective of the project is to: (i) develop national capacity in Vietnam to manage all PCBs; and (ii) on a pilot basis in Participating Provinces safely store significant amounts of PCBs in anticipation of future disposal. Revised Global Environment Objectives (as approved by original approving authority) and Key Indicators and reasons/justifications N/A (a) GEO Indicator(s) Original Target Formally Actual Value Values (from Revised Achieved at Indicator Baseline Value approval Target Completion or documents) Values Target Years Risks of contamination from all inventoried PCBs are monitored by government Indicator 1 : authorities (% of sites that are known to house PCBs that have been visited by authorities) Value (quantitative or 0% 100% N/A 94% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 94% achieved. All sites reported or 'suspected' as housing PCBs visited by the three IAs, samples for purpose of PCB inventory taken. Regular follow-up Comments monitoring plans in place, and first batch of regular monitoring visits completed (incl. % (160 of 200 non-EVN and all 479 EVN sites are regularly monitored by EVN achievement) subsidiary staff which owns and operates the related transformers as part of their routine working procedure under EVN regulations). Inventoried PCBs in 9 demonstration sites are safely stored, preventing risks to Indicator 2 : human health and environment caused by PCBs (% of sites) Value (quantitative or 0% 100% N/A 50% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 50% achieved. 78% (7) of planned storage facilities procured and commissioned Comments within the demonstration sites. Packaging material procured, and the storages are (incl. % ready to accept PCB waste for safe storage. 21 PCB-containing transformers achievement) with oil and 2 PCB-containing oil tanks safely transferred and stored in 1 storage site (11%). Actual value assessed as 50% given the readiness of facilities to accept the PCBs, but insufficient time to complete the actual transfer. Sufficient capacity in the country will be in place by end of project to proceed to Indicator 3 : choice of a national disposal option for PCBs (% of capacity assessed qualitatively) Value (quantitative or 25% 100% N/A 75% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 75% achieved. Capacity to make such decision in place, in terms of legal framework and human capacity. The Circular on management of PCB- containing equipment, products and materials requiring phase-out and ultimate disposal of PCBs, which will serve as key regulatory document, expected to be Comments approved in early 2016. A number of regulations and technical guidelines on (incl. % disposal (incl., on decontamination and disposal of PCB-containing oil, achievement) equipment and waste; waste oil recycling; and on co-processing of hazardous waste in cement kilns) are already issued. International cooperation established (Italy, Korea and France). Actual in-depth analysis and choice of technologies is still required. Inventory results are essential to inform the choice. (b) Intermediate Outcome Indicator(s) Original Target Actual Value Formally Values (from Achieved at Indicator Baseline Value Revised approval Completion or Target Values documents) Target Years Revised and new policies and technical guidelines for sound PCB management Indicator 1 : are issued (% of number of guidelines needing to be revised or issued, as decided at start-up) Value (quantitative or 15% 100% N/A 90% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 90% achieved. Final draft Circular on management of PCB-containing equipment, products and materials, which will serve as key regulatory document, sent to MONRE minister, expected to be issued early 2016 (hence achievement Comments of 90% instead of 100%). Nine technical guidelines on each step of PCB (incl. % management in place. Necessary national technical regulations that include PCB achievement) as one of the parameters, also issued. Additional policy documents not initially listed in the PAD issued (e.g., env. health management program, pollution prevention and control directive and several environmental PCB standards). Inventories of PCBs in all regions of Vietnam carried out (% of targeted Indicator 2 : provinces) Value (quantitative or 0% 100% N/A 99% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 Comments 99% achieved. For EVN 100% (sampling - 100%; testing - 100%; labelling - (incl. % 100%); for non-EVN 96.7% (sampling - 100%; testing - 100%; labelling - 90%). achievement) Site-specific PCB management plans developed and adopted by the 4 EVN and 5 Indicator 3 : non-EVN sites, with PCB materials properly identified, packaged, labeled, and stored (% of sites) Value (quantitative or 0% 100% N/A 45% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 Comments 45% achieved. Management plans for 7 existing sites approved (78% of (incl. % planned). Storage completed in 1 demonstration site (11%). EVN has upgraded achievement) and built a number of additional storages outside of project framework. Other 6 EVN sites (without physical works of storage) to have PCB management Indicator 4 : plans developed and adopted. Value (quantitative or 0% 100% N/A 100% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 Comments 100% achieved. PCB management plans for 6 EVN non-demonstration sites (incl. % developed. achievement) 50 technicians completed technical training on PCB sampling, screening, testing, Indicator 5 : packaging, transport and handling (at 9 sites) Value (quantitative or 0% 100% N/A 680% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 Comments Target surpassed. 340 technicians completed the training in 7 storage (incl. % demonstration sites and other sites that were considered for demonstrations. achievement) Indicator 6 : 150 journalists completed general PCBs training (% of total) Value (quantitative or 0% 100% N/A 133% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 Comments (incl. % Target surpassed (200 journalists). achievement) Monitoring and Evaluation of the project operation is carried out through the 5 Indicator 7 : Project Steering Committee meetings to ensure appropriate consultation and dissemination of information (% of total) Value (quantitative or 0% 100% N/A 100% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 Comments (incl. % 100% achieved. 5 PSC meetings carried out. achievement) Indicator 8 : PCB MIS completed (% completed determined qualitatively) Value (quantitative or 0% 100% N/A 100% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 Comments 100% achieved. MIS system with 4 functions completed and operational. Non- (incl. % EVN data uploaded. EVN data to be uploaded in as soon as possible. achievement) Adopted National PCB Management Action Plan with sampling and testing- Indicator 9 : based PCB national inventory (25% meaning technical draft, 50% technical adoption; 100% political endorsement) Value (quantitative or 0% 100% N/A 50% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 Comments (incl. % 50% achieved. achievement) 50 other sites in 5 years in demonstration provinces inspected by DONREs and Indicator 10 : VEA (% of 50 sites) Value (quantitative or 0% 100% N/A 160% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 Comments (incl. % Target surpassed. 80 sites inspected. achievement) Indicator 11 : 200 technicians nationwide who have completed PCB technical training. Value (quantitative or 0% 100% N/A 110% Qualitative) Date achieved 03/12/2010 06/30/2015 06/30/2015 Comments Target surpassed. About 220 technicians completed PCB technical training. In (incl. % addition, 345 completed emergency response, 400 PCB management policy and achievement) 120 occupational health education program. G. Ratings of Project Performance in ISRs Actual Date ISR No. GEO IP Disbursements Archived (USD millions) 1 06/25/2010 Satisfactory Satisfactory 0.15 2 06/27/2011 Satisfactory Moderately Satisfactory 0.78 Moderately 3 05/07/2012 Moderately Satisfactory 1.27 Unsatisfactory Moderately 4 12/28/2012 Moderately Satisfactory 1.55 Unsatisfactory 5 06/27/2013 Moderately Satisfactory Moderately Satisfactory 1.98 6 03/18/2014 Moderately Satisfactory Moderately Satisfactory 2.71 Moderately Moderately 7 12/15/2014 3.54 Unsatisfactory Unsatisfactory 8 02/10/2015 Moderately Satisfactory Moderately Satisfactory 4.27 9 06/28/2015 Moderately Satisfactory Moderately Satisfactory 5.64 H. Restructuring (if any) ISR Ratings at Amount Board Restructuring Disbursed at Restructuring Reason for Restructuring & Approved Restructuring Date(s) Key Changes Made GEO Change GEO IP in USD millions Extension of the closing date by 12/16/2014 MU MU 3.54 6 months. I. Disbursement Profile 1. Project Context, Global Environment Objectives and Design 1.1 Context at Appraisal 1. The Stockholm Convention on Persistent Organic Pollutants: Persistent organic pollutants (POPs) are a class of toxic chemicals that, as their name suggests, persist in the environment for long periods of time, are able to travel long distances from their points of origin, carried by natural soil, water and air processes, and accumulate in the fatty tissue of living organisms. Exposure to POPs can lead to serious health effects, such as reproductive or development disorders, nervous system damage, and immune system diseases. 2. Given their toxicity, persistence and trans-boundary properties, in 2004 the global community adopted a multilateral environmental agreement to address the challenge. The Stockholm Convention on POPs 1 requires Parties to take measures to eliminate or reduce the release of POPs into the environment. At the time of project appraisal, the Stockholm Convention addressed twelve distinct POPs divided across three broad categories: pesticides, unintended by- products and industrial chemicals2 . The Stockholm Convention requires its parties to submit a National Implementation Plan (NIP) to the Conference of the Parties within two years after ratification of the Convention by the country. For Polychlorinated Biphenyl (PCBs) - one of the POPs - it requires all Parties to eliminate the use of PCB-containing equipment by 2025 and to make determined efforts to have liquid PCBs and equipment contaminated with PCBs subject to environmentally sound waste management as soon as possible, but no later than 2028. Before 2025, the Convention does allow all Parties to continue use existing equipment containing PCBs in intact and non-leaking equipment in areas where the risk from environmental release can be minimized and quickly remedied. However, no PCB-containing equipment should be used in areas close to human food or animal feed production and processing facilities. Special measures apply for any use of PCB-containing equipment in populated areas, including near schools and hospitals. 3. Sector and country contexts: Vietnam signed the Stockholm Convention on May 23, 2001, ratified it on July 22, 2002, and submitted its NIP to the Stockholm Convention Secretariat in September 2007. Fifteen areas of action were identified as a priority for Vietnam in meeting its obligations. PCB management was listed in Priorities No. 5 (remediation of PCB-contaminated sites) and No. 6 (elimination of PCBs in industrial uses, in particular in electrical equipment). Vietnam has never produced PCBs but imported about 27,000 to 30,000 metric tons (MT) of PCB- containing oils from about the end of the 1940s to 1985. Significant amounts of PCBs were deemed to exist in Vietnam at the time of project preparation, primarily in oils used in electrical transformers and capacitors. 4. Two preliminary inventories of electrical equipment containing PCBs were carried out in 2004 and 2006 under the NIP and they found an estimated 9,600 MT of PCB-containing oils in Vietnam, primarily in about 9,000 transformers and 1,800 capacitors. The inventory report cautioned that this was underestimation, as the surveys covered only 70 percent of the facilities of 1 The Stockholm Convention became effective on May 17, 2004. For more information, visit the Convention’s website at: http://chm.pops.int/Convention/tabid/54/Default.aspx 2 PCBs are one group of compounds listed in the Stockholm Convention’s initial ‘dirty dozen’, which also included a range of pesticides, industrial chemicals and by-products. In 2009, the Stockholm Convention amended its Annexes A, B and C to include 9 new POPs, and in 2011 was further expanded to include the insecticide endosulphan. 1 Vietnam Electricity (EVN) that owned only about 70 percent of oil-containing electrical equipment in Vietnam. On the other hand, it was based on document screening and some application of quick tests rather than laboratory testing, and as such could have also been an overestimation. 1.2 Original Global Environment Objectives (GEO) and Key Indicators 5. The development objective of the project as set in the GEF Grant Agreement (GA) was to: (i) develop national capacity in Vietnam to manage all PCBs; and (ii) on a pilot basis in Participating Provinces safely store significant amounts of PCBs in anticipation of future disposal3. 6. The GEO achievement was to be measured by the following key performance indicators: a) Risks of contamination from all inventoried PCBs are monitored by government authorities; b) Inventoried PCBs in 9 demonstration sites are safely stored, preventing risks to human health and environment caused by PCBs; and c) Sufficient capacity in the country will be in place by end of project to proceed to choice of a national disposal option for PCBs. 1.3 Revised GEO (as approved by original approving authority) and Key Indicators, and reasons/justification 7. Neither GEO nor key indicators were revised during project implementation. 1.4 Main Beneficiaries 8. The project’s main beneficiaries included Government of Vietnam, and specifically officials from the Ministry of Natural Resources and Environment (MONRE), Ministry of Industry and Trade (MOIT) and MONRE’s Vietnam Environment Administration (VEA), the agencies responsible for overseeing implementation of activities to ensure that the country meets its obligations under the Stockholm Convention. The Vietnam Electricity (EVN) would benefit from activities carried out in its subsidiaries, including PCB inventory and construction of safe PCB- containing equipment and waste storages. Pha Lai Power Company was identified as one of the pilot beneficiaries at project appraisal. The Departments of Natural Resources and Environment (DONRE) in selected provinces would benefit from increase of institutional capacity of PCB management and public awareness, as well as piloting of safe storage of PCBs. Various stakeholders involved in PCB and hazardous waste management in Vietnam, including customs officers, laboratory technicians of DONREs, research institutions, power companies, electrical equipment manufacturers and service workshops, hazardous waste management facilities, and oil/equipment recyclers, hazardous waste transporters, hazardous waste disposal facilities, the Ministry of Labor, Invalids and Social Affairs and mass media would benefit from specifically targeted training and public awareness activities. Finally, public at large would benefit from improved knowledge on the health and environmental impacts of PCBs and potentially reduced health risk due to improved PCB management infrastructure, particularly people living in 11 cities and provinces in the Northern, Central, and Southern focal socio-economic zones, which were the proposed locations for demonstration of sound PCB management system. 3 The PAD version of the GEO was the same as in GA, except for clearly separating the two objectives (i.e., ‘Develop national capacity in Vietnam to manage all PCBs and on a pilot basis in selected provinces safely store significant amounts of PCBs in anticipation of future disposal’) 2 1.5 Original Components 9. The project objectives were to be achieved by the following activities grouped in the components: Component 1: PCB management framework and action plan (total cost: US$ 4,163,980, of which GEF US$ 1,989,338, other sources US$ 2,174,642). This component aimed to establish a sound policy and legal framework for every aspect of management of PCBs. This would include addressing such issues as definition of PCBs and legal requirement for each step of PCB management. It would also review and update at least four regulations on hazardous waste management, and assist Vietnam to develop at least seven technical and administrative guidelines with clear procedures defining roles and responsibilities of concerned government agencies and industry. In addition, this component was to carry out the third national PCB inventory investigation in 53 provinces of Vietnam based on actual sampling and laboratory analysis of suspected electrical oils to devise a realistic national PCB management action plan. Component 2: PCB management demonstration (total cost: US$ 4,977,600, of which GEF US$ 2,097,600, other sources US$ 2,880,000). The objectives of this component were to demonstrate sound PCB management activities at 15 demonstration facilities and to replicate experience at these facilities to others within the selected provinces where these demonstration facilities are located. The demonstration activities would include site investigations, development of site-specific PCB management plans, voluntary retirement of PCB-equipment in some of the facilities, infrastructure improvements, including upgrade of storage facilities and laboratories, and purchase of oil recycling units and servicing tools, with an objective to ultimately demonstrate the process of proper PCB handling from identification to temporary storage. The demonstration would take place in four EVN facilities with works to be financed by the project and six others EVN sites with PCB management plans prepared, and five non-EVN sites. For EVN sites, the site selection would focus on workshops that service oil-containing electrical equipment and have ongoing activities of handling electrical oils, either production, servicing or storage of oil- containing electrical equipment. For non-EVN sites, the selection would focus on oil recyclers, service workshops of oil-containing electrical equipment and hazardous waste management facilities with active waste oil management and disposal activities. This demonstration would cover activities, such as identification of stored PCBs and their temporary safe storage. The project would not include any site remediation activities. Among the 15 demonstration facilities selected, only the Pha Lai Power Company (a subsidiary of EVN) had confirmed its participation in the project at appraisal. Component 3: Institutional strengthening (total cost: US$ 3,787,300, of which GEF US$ 1,759,822, other sources US$ 2,027,478). This component would support: (i) capacity building for stakeholders involved in PCB management activities; and (ii) public awareness campaigns to mobilize public support for sound PCB management. Specific activities would include recruitment of international expert, PCB management training of at least 250 technicians, public outreach activities, including training of at least 150 journalists, media coverage, development of occupational health education program, organization of national and international workshops and development of a PCB website. Component 4: Monitoring and evaluation (total cost: US$ 2,274,700, of which GEF US$ 392,500, other sources US$ 1,882,200). This component would support activities to monitor progress of project implementation and to evaluate effectiveness of project activities. Monitoring and 3 evaluation results were to be used by stakeholders to identify actions needed to strengthen the effectiveness of the project during project implementation. Monitoring tools developed under the project, particularly the Management Information System (MIS), were expected to be institutionalized for the management of all PCBs in Vietnam. The component among other would also support organization of project launch and completion workshops, as well as Project Steering Committee meetings. Component 5: Project management (total cost: US$ 1,744,400, of which GEF US$ 699,400, other sources US$ 1,045,000). This component would finance costs related to establishment of two Project Management Units (PMUs) and incremental operating costs of the PMUs. One PMU would support project management activities to be carried out by the Ministry of Natural Resources and Environment (MONRE) and the Ministry of Industry and Trade (MOIT), and another would support activities to be carried out by EVN. 1.6 Revised Components 10. There were no significant revisions in the scope of components, although in December 2014 it became evident that given the circumstances outside of the project influence (changes in land use plan and local population objections) the project would accomplish construction of seven demonstration facilities instead of nine. The decrease of number of demonstration facilities however did not significantly reduce the demonstration effect that the project was to achieve. Hence, and in the absence of the government’s request to formally restructure this target, it was not changed in the Results Framework. The savings resulting from this decision were reallocated to carry out testing and analysis of additional PCB samples and purchase of laboratory equipment. In the course of the project, few additional technical guidelines, as described in Annexes 2 and 7, were developed, as their necessity was identified during project implementation after more sector information was collected. 1.7 Other significant changes 11. The project was restructured once, on December 16, 2014 to extend the closing date by six months, from December 31, 2014 to June 30, 2015. This was to allow completion of the national PCB inventory, which was both a significant activity in terms of disbursements and would also contribute significantly to the sustainability of project’s outcomes. The extension would also allow the completion of Component 2, PCB Management Demonstration, activities, particularly the storage facilities, construction of which was delayed both due to delay in PCB inventory activity as well as finding proper locations acceptable by local residents. 2. Key Factors Affecting Implementation and Outcomes 2.1 Project Preparation, Design and Quality at Entry 12. Overall, the design of project components is considered to have been sound. The project’s aims and structure were appropriately responsive to Vietnam’s interest in addressing the policy, regulatory and information challenges of PCB management so as to meet Stockholm Convention requirements. While lessons of other countries tackling PCB phase-out were diligently studied and considered, the project design was also based on a pragmatic decisions taking into account the unique and complex country situation. 4 13. Project background analysis that informed design: The background analysis that informed project preparation was comprehensive and commensurate with the complexity of the issue to be addressed. The project benefitted and was directly informed by the NIP preparation process, which took place in parallel with project preparation. Specifically, the project benefitted from: (i) initial national inventory and assessment of PCB usage; (ii) assessment of national infrastructure for POPs analysis and monitoring; and (iii) assessment of the existing institutional, policy and regulatory framework for POPs management in Vietnam. Further detailed studies were carried out using US$ 350,000 project preparation grant (GEF PDF-B grant) and US$ 250,000 Canadian POPs trust fund. Project preparation identified and confirmed the key issues that were required to be addressed most urgently, namely: (i) incomplete PCB inventory; (ii) poor practice of storage of retired electrical equipment and PCB oils that are prone to create cross-contamination; (iii) no or ambiguous policies or regulations targeting PCBs that allowed mixing and cross- contamination of PCB oils, recycling and reuse of PCBs and ultimately release into the environment; (iv) lack of guidelines for clean-up of contaminated sites, storage and transportation of PCB waste; and (v) limited professional capacity for PCB management in line ministries and industrial sectors. 14. Given the limited initial GEF and counterpart budget available for this first project aiming to address PCB phase-out in the country, after thorough considerations, it was decided that the crucially important PCB disposal capacity development would be addressed by a follow-up project. The decision was pragmatic and based on consideration that disposal capacity development requires rational planning and needs to be based on accurate and complete PCB inventory data. The lesson from cases in developed countries that POPs specialized disposal facilities were closed due to reduced volume of wastes and uncompetitive economic performance was fully taken into account. 15. Government commitment and support for design: On the national level, the project would support implementation of the NIP, Vietnam’s National Strategy for Environmental Protection and the Five Year Plan 2006-2010 of the MONRE. It would contribute to Vietnam’s efforts to reduce the risks to human health and ecosystem integrity from industrial pollution and improve its capacity and performance in hazardous waste management. The government, through MONRE, MOIT and provincial governments, provided adequate financing to carry out preparation activities, and set up an institutional structure via inter-ministerial Project Steering Committee to oversee project implementation. The government had also established the National Steering Committee (NSC) consisting of high level ministry officials for the implementation of the Stockholm Convention, which oversaw preparation of NIP and would provide overall project implementation guidance. While the government was ready to fully support project preparation and implementation through its institutional setups, it also stood ready to provide adequate co-financing during implementation. In the midst of project preparation (December 2006) when the GEF requested that matching co- financing be provided, as GEF was to only provide grant to finance the agreed incremental costs, MONRE assured that such financing would be provided, given the priority status of the project. 16. Possible critical project risks and risk mitigation measures were overall, adequately identified, however potential impacts of a few were somewhat underestimated. The overall risk was rated as Moderate, given the moderate rating for most of the underlying risks. While fiduciary risks were adequately identified, the implementation capacity, rated Moderate at appraisal, appeared to be a significant cause of project implementation delays, particularly in relation to carrying out procurement of complex contracts. Similarly, while the team identified a risk of poor coordination among MOIT, VEA and EVN as Moderate, coordination issues, particularly at the beginning of the project appeared to be a bottleneck. Finally, the PAD correctly identified a delay in preparing 5 the follow-up project addressing disposal options as a risk with a residual rating after mitigation of Low. While the follow-up project is likely, the timeframe and scope of it are yet unknown. 2.2 Implementation 17. Project implementation period: Project effectiveness was delayed due to delay in finalization of the Project Implementation Manual (PIM) and establishing PMUs at VEA and EVN. While project implementation started nine months after it was approved by the Board, its closing date was extended only once - by six months. Beyond this project extension there were no other restructurings. 18. Project at risk status: While for most of the project duration the project implementation progress and progress towards achievement of GEO were assessed as Moderately Satisfactory (MS), its implementation progress rating was downgraded to Moderately Unsatisfactory first in May 2012 due to delays in hiring consultants for the key contracts – PCB inventories at EVN and non-EVN facilities. This affected both the start of implementing other activities as well as disbursement rate, which at mid-term review (MTR) reached only 22 percent for VEA activities and 1.54 percent for EVN. No restructuring of the project was proposed during MTR, as at the time the newly agreed implementation schedule would still allow the project to fully achieve its objectives before the original closing date. The project was upgraded to Moderately Satisfactory in December 2012 when the two inventory contracts were signed. Implementation of inventory work however continued to experience hurdles and the projects ratings were again downgraded in December 2014. At the time it was evident that neither inventory nor the next larger contract, storage construction can be completed within project period. The ratings were upgraded to MS in the last Implementation Status and Results Report (ISR) in June 2015 given the progress with implementation of the two contracts and the rest of activities. 19. PCB inventory of EVN and non-EVN enterprises was one of the important project activities in terms of its volume and also crucial as a background information to initiate other activities, such as preparation of the National PCB Action Plan, selection of storage sites in pilot provinces and preparation of the individual PCB management plans. The inventory results were also to be key for decision making on the preferred PCB disposal option to be addressed by a follow-up project. There were numerous factors that affected poor implementation of the contracts, among them: (i) difficulties to reach an agreement between MOIT and EVN on the methodology to be used in EVN and non-EVN inventories; (ii) lack of experience of PMU procurement staff/procurement unit in carrying out more complex consultant selection (quality- and cost-based selection, QCBS), which resulted in delays of finalization of the terms of reference (TORs) and evaluation of technical proposals; (iii) lack of experience in PCB (and POPs in general) area and Bank procurement process by local consultancy market; (iv) changes of key technical staff in selected contractor teams, particularly at the start of contract implementation; (v) difficulties in carrying out sampling due to non-cooperation of some facilities and timing for sampling that had to be coordinated with power cut schedules; and (vi) weak quality of equipment database used for selecting equipment for inventory, particularly in EVN case. This all resulted in both delay of implementation and at times substandard outputs. While VEA/MOIT’s first stage inventory with the persistence of the VEA’s PMU and support of the Bank’s task team was successfully completed, EVN was not able to fully complete the inventory until this completion report was finalized. 20. Storage demonstrations: The PCB inventory results were to feed into site selection for PCB storage demonstrations that would be closest to the major PCB equipment retiring facilities. With inventory delays, the process of storage construction stalled, however at MTR the Bank team and the client agreed that it will start the process using the limited existing data. This was a 6 pragmatic decision. While non-ENV sites were easier to determine given that most would be located in the territories of existing larger PCB equipment producing, waste management and oil recycling facilities, site selection appeared to be more complex in EVN subsidiaries/small PCB equipment servicing workshops, which at times were located nearby or in the middle of highly populated areas. As such, proposals to build hazardous material storages either faced local population objections, or were objected to by the local governments given that such facilities were not foreseen in their land use masterplans. As a result, EVN was able to only construct one new PCB safe storage facility, however it has also upgraded 83 of its storages and built 78 new storages using their own financing sources. 21. While these two important contracts affected other decisions, including those related to the National PCB Action Plan completion, nevertheless good progress was achieved and the draft plan was completed. Also, other activities such as MIS, training, capacity building and shaping of regulatory framework, all successfully completed, were essential to achieve project results, and ensure sustainability of project outcomes. 2.3 Monitoring and Evaluation (M&E) Design, Implementation and Utilization 22. Design: The project design included a sound project monitoring and results framework with three PDO (outcome) level indicators and eleven intermediate outcome (results by component) indicators covering most aspects of the GEO and components. While most of the indicators were well defined, some of them would have benefitted from being more specific (see sub-section on Implementation below). Also, annual progress targets were, as usual in GEF operations designed at the time, translated as a percentage of achievement of the total, which did not allow for an accurate assessment of the progress and could lead to misinterpretation. The project supported a Management Information System (MIS) establishment, which was to be central to project management and monitoring and track progress towards project implementation milestones and achievements. The MIS was to be an important tool to also house the national inventory data. 23. Implementation: Results framework indicators were used to measure project progress throughout implementation in the semi-annual PMU progress reports and Bank’s Implementation Status and Results Reports (ISRs). As mentioned above, some outcome indicators were not defined in a straightforward manner and assessment of their achievement was subject to interpretation. For example, the outcome indicator ‘sufficient capacity in the country will be in place to proceed to choice of a national disposal option for PCBs (% referring to a qualitative assessment of capacity)’. First, qualitative assessment of capacity, not defined whether it refers to the human, regulatory or decision-making, is difficult. Second, while this would have been an appropriate indicator in the absence of implementation delays, in reality it appeared to be difficult to measure given that disposal option decision was largely dependent on the results of the national inventory, which was completed only at the closure of the project. On the other hand, capacity building activities were fully implemented and clearly there was now capacity and basis in the country to make such decisions. The MIS, while it was already designed at preparation, was not consistently used to track project progress towards its Results Framework indicators. However, VEA/MOIT PMU’s project plans and activities were developed and monitored using MIS. It was also gradually expanded to accommodate inputs of the national PCB inventory, which in fact was the key utility of the MIS. 24. Utilization: The MIS was upgraded in April 2012, and allowed the entry of national inventory data as well as linking to the GIS system of VEA. By the end of project, all available inventory data of MOIT had been transferred to MIS, and EVN was working on data input. The MIS system is housed at VEA and administered by its Pollution Control Department (PCD), it is used for PCB as well as other POPs management activities in Vietnam. It is planned to link the 7 MIS with the PCD/VEA Pollution map system. Annual budget for MIS use and update is allocated from MONRE’s VEA budget. 2.4 Safeguard and Fiduciary Compliance 25. Safeguard compliance: During preparation, it was determined that the project triggers OP4.01 Environmental Assessment and is classified as Category B. The Project’s potential adverse environmental impacts were assessed as not substantial and easily managed and mitigated. The project was expected to improve the management system of PCB oils and equipment throughout their life cycle, which would result in lowering risks to humans and the environment. At the earlier stages of preparation the project was classified as a Category A project, but the category was lowered to B because of the decision not to finance the PCB disposal facilities’ construction. An Environmental Assessment Framework (the EA Framework) was prepared based on two rounds of stakeholder consultations. Based on the EA Framework, an environmental assessment (EA) report was prepared for the Pha Lai Thermal Power Generation Company – the only identified and confirmed facility before appraisal. 26. The safeguards reviews conducted during implementation confirmed consistent compliance with OP 4.01 safeguard policy. The Environmental Management Plans (EMPs) of the storage site constructions were reviewed and accepted by the Bank, adopted by the local governments and complied with during the construction period. The draft EMPs were discussed during public consultations (as a result of due public consultation process, decisions to halt moving forward with construction of several EVN storages were made). In addition, site-specific PCB management plans were developed under the project to monitor proper management of PCBs at five EVN facilities without the introduction of construction work. 27. The overall safeguard implementation of the project is assessed as Satisfactory. 28. Financial Management: Financial management throughout the project was generally Satisfactory. The two PMUs had adequate financial management arrangements for project implementation. The audited financial statements were delivered on time and the auditors have issued unqualified audit opinions. The project management recommendation letters issued by the auditors did not contain any internal controls deficiencies or accounting issues. The quarterly Interim Unaudited Financial Reports were submitted on time with acceptable quality. While there were a few internal control and contract management issues identified during the Bank implementation support missions, the PMUs have fully implemented the Bank mission recommendations. 29. Procurement: Generally the Bank’s procurement guidelines were complied with. The project procurement experienced implementation delays in part due to inadequate procurement capacity in the PMUs, particularly in EVN, and their unfamiliarity with QCBS procedures in the beginning. The procurement rating was downgraded to Moderately Satisfactory a year after effectiveness, and further to Moderately Unsatisfactory in May 2012, mainly due to slow selection of consultants for PCB inventory of EVN and non-EVN sites. Additional capacity building, training and daily hands-on support were secured since then. The procurement approval authority has been decentralized to departmental level, instead of ministerial level. As a result, implementation of procurement activities following the Mid-term Review was back on track. In the last year of the project, the procurement rating was upgraded to Satisfactory, and all procurement activities were assessed to be performed in a professional manner, and in full compliance with the World Bank Procurement Policies/Guidelines and the procurement plans. This assessment remained effective until project closing. 8 2.5 Post-completion Operation/Next Phase 30. One of the key project’s outputs was improved institutional capacity of the government agencies, EVN and the private sector in management of PCB-containing retired equipment and waste. The project produced the National PCB Action Plan that is submitted to MOIT and is expected to be formally issued shortly, while in fact its implementation is already ongoing. The objective of the plan is to ensure integrated PCB management in order to minimize PCB emission to the environment, implement use of PCB in equipment and materials phase-out by 2025, ensure safe destruction of PCB contaminated equipment, oil and waste by 2028 and remediate PCB contaminated sites. As such, the plan foresees in the period of 2015-2017 to: (i) complete legal framework related to PCB management; (ii) continue building human resources for PCB management; (iii) completing inventory of PCB-containing equipment, materials and waste, and detecting sites and sediments suspected of having PCB contamination; (iv) carry out a pilot scale study on PCB treatment technologies; (v) conduct studies to find out appropriate technologies, which can be applied to recovery, recycling, and treatment of PCB-containing equipment and materials as well as for remediating PCB-contaminated soils and sediments; (vi) identify alternatives for storage, collection, transportation and treatment of PCB over the country; and (vii) complete infrastructure and legal formalities for PCB collection, transportation, storage and treatment service units. As described in the below sections, many of the activities are ongoing and their finalization is essential to design well informed future sector interventions. 31. A concept of the Industrial Hazardous Waste Management project that aims to implement environmentally sound management and treatment of PCBs has been developed by the Environmental Technology Center and submitted to VEA/MONRE, relevant authorities and donors in June 2015. This follow-up project would continue to support the environmental management of toxic chemical waste in Vietnam in general and implementation of the Stockholm Convention in particular. 32. In parallel, the World Bank has initiated two analytical studies on solid waste and air quality management that will be completed in early CY2016. The outcome of this work will inform the design and scope of the new investment project/program and also potentially including follow- up work on PCB phase-out. 3. Assessment of Outcomes 3.1 Relevance of Objectives, Design and Implementation 33. Relevance of Objectives: The project’s objectives were relevant to the Country Partnership Strategy (CPS) 2007-2011, and remain so under the current CPS FY 2012-2016, as well as to both Vietnam’s country level and global environmental priorities. Under the key pillar of the CPS 2007- 2011, which addressed strengthening of natural resource and environmental management, the project supported the aim of mitigating the environmental impacts of human activities and, more directly, the Government’s desire to observe international environmental conventions by establishing a basis for phase-out of PCBs. The current CPS FY 2012-2016 explicitly maintains this focus by recognizing that Vietnam’s economic growth has generated environmental risks and decline of natural habitats. Its pillar 2 on sustainability focuses on, among others, land management and pollution control. The PCB project also has remained a key project in Vietnam for the fulfillment of the country’s commitment towards the Stockholm Convention. The project has laid 9 the foundation for a national program of PCB elimination in Vietnam. Hence, relevance of project objectives is assessed as High. 34. Relevance of Design: The project’s design was relevant to the stated objectives, including its activities, components and the results framework. The project components encompassed all key activities that were necessary to achieve the objective. For capacity enhancement these included extensive human capacity building through training and public awareness campaigns. The project also clearly defined the scope of regulatory framework development which was essential for country’s capacity to address PCBs issues. In addition, the choice to include national PCB inventory and MIS development as important activities was needed to inform project sustainability. Similarly, demonstration activities targeted to selected locations were essential to show impact of safe management of chemicals. The statement of the objectives was clear and adequately linked to the proposed outcome and intermediary indicators in the results framework. Hence, relevance of project design is assessed as Substantial. 3.2 Achievement of Global Environmental Objectives 35. The GEO to “develop national capacity in Vietnam to manage all PCBs” was substantially achieved. Vietnam’s capacity to make decisions on the PCB management with an ultimate objective of compliance with the country’s obligations under the Stockholm Convention is now in place, which was to be the key outcome of this first intervention in the country’s attempt to eventually phase-out PCBs completely. The country has established a monitoring system of the PCB users, and regular monitoring has commenced. Within the framework of the project, a Circular on management of PCBs and the PCB-containing equipment, materials and waste – the key regulatory document, has been prepared and is undergoing approval process within the government. It is expected that the Circular will be approved by early 2016. The National PCB Action Plan that includes implementation plan of all steps of PCB management, including initial analysis of the final treatment and disposal options has been finalized and pending enactment. In addition, nine technical guidelines, six technical regulations, five national standards, three administrative guidelines have been developed, issued or are in the process of adoption. Several national technical regulations and environmental standards have also been revised to include PCBs. 36. On PCB disposal option decision, a notable achievement is development of the Technical Guideline for Decontamination of PCB containing equipment, materials and wastes that has analyzed a variety of disposal options 4 and selected two technologies as suitable to available technology conditions in Vietnam at present. These technologies (i.e., cement kiln co-incineration and hazardous waste incineration) could be applied in the short-term future while investment in other more modern disposal options, if warranted by inventory analysis, is being made. The analysis has identified one of the cement kiln facilities in Vietnam, Holcim Vietnam Ltd. Co., as the facility that has capacity to treat PCB-contaminated oil, however further analysis on the impacts of the final inventoried and non-inventoried PCB amounts, transportation distances, treatment cost, outcomes of the complicated procedure of PCB-contaminated oil collection from the equipment, remains to be carried out. As a demonstration activity, about 38t of PCB oil have already been incinerated in the cement kiln with satisfactory results. Vietnam has also established a close international cooperation (with companies in Italy, Korea, Japan and France) on potential PCB disposal options. 4 Including (1) incineration in non-slagging incinerators; (2) pyrolysis; (3) alkalized metal reduction at atmospheric pressure and temperatures in the range of 60°C - 180°C; (4) base-catalyzed decomposition (BCD); (5) plasma technology; (6) cement kiln co-incineration; and (7) incineration in hazardous waste incinerators. 10 37. In terms of human capacity and public outreach, the project has provided training on PCB management and policy, PCB technical, emergency response, and occupational health education to 1,565 sector participants, trained 200 journalists, developed at least 37 media coverage outputs, organized or participated in six international workshops, and developed a PCB management website (for details see Annex 2). In addition, the project ensured good inter-agency coordination through regular Project Steering Committee and inter-ministerial meetings. 38. A stable PCB accounting system, MIS, has been developed and is in use, and the available national PCB inventory data are being transferred to the system. The national PCB inventory, however has not been fully completed at the time of ICR preparation. 39. The objective “on a pilot basis in Participating Provinces safely store significant amounts of PCBs in anticipation of future disposal” has been achieved to a comparatively more modest extent, despite demonstrating notable outcomes. The outcome indicator of number of inventoried PCBs in 9 demonstration sites that are safely stored, preventing risks to human health and environment caused by PCBs, was partially achieved. At the end of the project, construction and equipping of seven storage facilities has been completed. As this activity has been delayed due to the reasons explained in the section 2.2 above, the timing until project closing only allowed to demonstrate transportation and actual storage of PCB-containing equipment in one storage5. On the other hand, as foreseen at appraisal, PCB management plans have been developed for all of the seven demonstration sites, in addition to six EVN non-demonstration sites. Several environmental and waste treatment facility laboratories are now equipped with testing tools and oil recycling units have also been purchased. Voluntary PCB equipment retirement has been demonstrated by the Pha Lai Power Company. 40. The project has made acknowledged improvements to the development of the national capacity to manage PCBs and demonstrating proper PCB management process step by step, and partially achieved its objective of completing the national PCB inventory, as well as demonstration activities. 3.3. Efficiency Rating: Substantial 41. The project was designed to contribute to both local and global public goods by reducing the risk of the release of PCBs into the environment. Due to the lack of reliable baseline data and difficulties associated in measuring the impact of the overall environmental, health and related socio-economic impacts, the project preparation team concluded that it was not possible to conduct a traditional economic or financial cost-benefit analysis for the project. However, a cost- effectiveness analysis of four alternative technical solutions was carried out, which also included a business as usual, full disposal and transportation, and pilot (partial) disposal options. 42. Quantification of indirect impacts of safe PCB storage on human and environmental health was not done at completion due to the following reasons, some of which were similar to those at preparation, including: (i) assumptions of human health impacts would be impossible to attribute to safe storage only; (ii) there was no health analysis data collected during the project; (iii) only 521 PCB-containing transformers (with oil) and 2 PCB-containing oil tanks have been transferred to EVN storage (Pha Lai site) 11 smaller amounts of PCB-containing equipment were actually transferred to the safe storage facilities, thus cutting the pathway of the risk of potential exposure, within project period. 43. As mentioned above, the project strategy, based on a thorough cost effectiveness analysis at the time of appraisal, opted for a strategy that does not focus on environmentally sound disposal of PCBs at this stage, but rather to build capacity for the long-term, and demonstrate containment and safe storage of PCB wastes. As a short-term measure until domestic PCB treatment capacity is developed, storage cost, at an average of around US$ 1,215 per ton, has indeed proven to be much less costly than the cost of transport and shipping to a high temperature hazardous waste facility overseas, which was the only readily available option at the time, and would have come at a cost of at least US$ 4,000-5,000 per ton or more. The disposal option would also result in additional costs that is related to early retirement of equipment. Thus, if all GEF grant available had been used to ship and destroy PCB-containing equipment/oil, it would only be able to address part of the issue, i.e., around 1,400 tons of PCB oil, while leaving no framework, capacity, the way forward at the end of the project to address the remaining amounts of the PCB oil, with no system in place to prevent environmental releases of the remaining amounts. The actual costs of storage facilities were in line with the projections at the appraisal. 44. Therefore, the entire project has been carried out in a cost-effective manner. Additional information is provided in Annex 3. 3.4 Justification of Overall Outcome Rating Rating: Moderately Satisfactory 45. The project largely achieved its GEOs. Evident improvements to the development of the national capacity to manage PCBs and piloting of model of safe storage of PCB waste were achieved. Institutional capacity was strengthened, which enabled the development of targeted policy and regulatory arrangements for the long-term control of PCBs within the context of broader national chemicals and waste management objectives. Awareness of those involved in PCB management and broader public on PCBs and hazardous waste was increased. Finally, a system of PCB inventory accounting (Management Information System) was put in place, which will make the decision-making on PCB phase-out more informed. The project’s concept and design remains highly relevant to Vietnam’s obligations under the Stockholm Convention and to its national priorities with respect to pollution and hazardous waste management and environmental protection. Project results were overall achieved in a cost-effective manner with the costs involved in achieving project objectives being reasonable in comparison with the benefits it generated, and the initial estimates. It is clear that overall the project has generated value, however it is not possible to overlook the delays experienced during implementation, which ultimately did not allow time to complete the full spectrum of planned outcomes within the project timeframe. Because (a) relevance is high, (b) efficiency is substantial, and (c) one objective was substantially achieved but the other objective was only modestly achieved, the overall rating is Moderately Satisfactory in accordance with the guidance of the Independent Evaluation Group’s Guidelines for Reviewing World Bank Implementation Completion and Results Reports, A Manual for Evaluators. 3.5 Overarching Themes, Other Outcomes and Impacts (a) Poverty Impacts, Gender Aspects, and Social Development 46. N/A 12 (b) Institutional Change/Strengthening 47. As a result of project implementation, institutional capacity was built and strengthened at several levels. At the level of government, capacity within MONRE, MOIT, as well as their local department (DONRE, DOIT), Customs and Environmental Police was strengthened with respect to technical aspects associated with the development of PCB regulations and PCB management policy, environmental and technical standards, import and export control of PCB materials through workshops, seminars and training. Implementation of the project also strengthened VEA’s, MOIT’s and EVN’s coordination capacity with respect to other ministries within the NLG, with provincial government agencies, and through partnership with various research and scientific institutions that generated valuable research, all of which can now positively contribute to replication of a PCB management strategy at the national level. Training was also provided to the research institutes, laboratories, EVN and enterprises to increase their capacity in sampling, quick and advanced analysis of PCBs, inter-laboratory cross-checks for PCB analysis in transformer oil, emergency response, evaluating prevention, response and recovery of chemical and PCBs incidents. Overall, results achieved were internalized by project partners at all levels, such that they can be drawn upon in future, as required. (c) Other Unintended Outcomes and Impacts 48. The project launched a successful public outreach campaign for public awareness on PCB management through articles in press, radio and TV reports, the participation in international seminars for project activities dissemination, preparation of POPs and PCB newsletters, pamphlets and handbooks. Also, the web portal “pops.org.vn” and a specific PCB website in both English and Vietnamese have been developed and updated periodically during project implementation to provide the general public with information on PCB/POPs policies and regulations and technical information and guidelines pertaining to sound PCB management. The POPs portal and PCB website have been linked to the VEA website and have been recently upgraded with a number of relevant news in English, for which almost 8 million accesses have been made. 3.6 Summary of Findings of Beneficiary Survey and/or Stakeholder Workshops 49. N/A 4. Assessment of Risk to Development Outcome Rating: Moderate 50. The risk to development outcome is assessed as Moderate mainly due to risks related to stakeholders. While the project activities provided for a good regulatory basis, it mostly regulates management of dangerous goods, hazardous chemicals, chemicals restricted from production or trading, including PCBs. While this is a great achievement, detailed provisions in the regulations on the responsibilities of stakeholders involved in management of PCB life cycle are still missing, according to the assessment provided in the draft PCB NAP. For example, the draft of the MONRE’s Circular on the management of hazardous wastes, includes procedures for management of used PCB-containing equipment and parts; hydraulic oil waste; thermal oil and PCB- insulated waste; PCB-containing transformers and capacitors; PCB-containing or contaminated electrical equipment; PCB-containing construction waste and demolition. However, it does not specifically stipulate responsibilities of owners of PCB-containing equipment and material in managing each step of PCB phase-out. In addition, responsibility for environmental handling and remediation of PCB-contaminated areas has also not been decided. These responsibilities need to be specified as 13 soon as possible and/or other incentives for PCB phase-out identified, if Vietnam wants to achieve its Stockholm Convention commitments. 51. One of the risk mitigation measures that was already embodied in the project was involvement of the Vietnam Electricity (EVN), the biggest owner of PCB-containing equipment in Vietnam, in project demonstration activities. While implementation performance of EVN was uneven at the beginning of project in terms of carrying out project activities, it nevertheless showed great understanding and commitment to the PCB phase-out towards latter part of project, as evidenced by its own resource allocation for the upgrade of existing PCB storage facilities, keen interest in leading dialogue on PCB disposal options, as well as increased human resource capacity through activities provided under the training. 5. Assessment of Bank and Borrower Performance 5.1 Bank (a) Bank Performance in Ensuring Quality at Entry Rating: Satisfactory 52. The project preparation took almost four years. While it took about a year from the PCN review until the first preparation mission, the Bank was committed and persistent in delivering this complex project. Most of the preparation delays were due to reasons that would be difficult for the Bank to directly resolve. These included changes in co-financing requirements by GEF, reduction of initially planned GEF grant amount by almost half and initial removal of the project from the pipeline entry by the GEF CEO. In spite of these difficulties, the Bank team and management worked tirelessly with the counterparts to move ahead with project preparation, including securing adequate funding for preparation from the GEF project preparation grant and Canadian POPs trust fund. Additional delays emerged at the time of preparation of environmental safeguards documents. Nevertheless, the design of the project and its strategic relevance was based on detailed analysis and studies. The M&E system, particularly inclusion of MIS development as part of project activities was the right approach. Also, the team’s efforts to obtain thorough data to carry out project’s cost-effectiveness analysis is commendable. While the risk levels for few of the risks was somewhat underestimated, the overall performance of the Bank during preparation was Satisfactory. (b) Quality of Supervision Rating: Moderately Satisfactory 53. The Bank provided the Government and other project counterparts with consistent, timely and best available policy and technical advice, including guidance on financial management, procurement and environmental safeguard issues, through regular supervision missions, including frequent site visits, as evidenced by thorough Aide Memoires. As the Aide Memoires demonstrate, the Bank maintained a constructive dialogue with both PMUs to address the various complex implementation issues that arose. The Bank was particularly proactive and worked on the basis of newly agreed action plans and milestones during project implementation delays. Specific FM and procurement training was provided for PMU staff in order to ensure that the project’s fiduciary and procurement requirements were respected. Despite this close implementation support, the Bank could have provided more guidance on the quality aspects of the national PCB inventory implementation. The quality of supervision is consequently rated Moderately Satisfactory. (c) Justification of Rating for Overall Bank Performance Rating: Moderately Satisfactory 14 54. Given the combination of ratings for quality at entry and supervision, the overall Bank performance rating is Moderately Satisfactory. 5.2 Borrower (a) Government Performance Rating: Satisfactory 55. Government performance, rated across the spectrum of the project’s full implementation is considered to have been Satisfactory. The Government was and remains a strong advocate for action in support of the Stockholm Convention. Agencies involved through the Project Leading Group and NLG, and at the provincial level, all played a role, to varying degrees, in ensuring the development of comprehensive policy frameworks at the national and provincial levels, advancing a diverse national capacity base to address the issue into the future, and promoting awareness about the importance of sustainable hazardous waste management. 56. The project benefited from political will and commitment, witnessed by actual counterpart funding that was in line with the commitment at preparation, from both the national and provincial governments and EVN, which contributed to project team operations, to the development of a sound policy and regulatory framework, as well as to the design of the National PCB Action Plan, as well as discussions on moving forward to a choice of a proper disposal option. (b) Implementing Agency or Agencies Performance Rating: Moderately Satisfactory 57. The two PMUs’ performance, particularly in the earlier stages of the project and particularly related to EVN activities resulted in delays, which is a reason for rating the overall performance less than satisfactory. In the later part however, the PMUs managed to make up for some of the lost time, and implementation proceeded at a satisfactory pace, with quality of procurement documents and technical specifications increasing and disbursements accelerating. Collaboration between the two PMUs could have been stronger in terms of reporting lines and cooperation. In spite of these difficulties, the project was almost fully disbursed and many of the project activities originally planned were executed, which would not have been possible without overall good performance of the implementing agencies. (c) Justification of Rating for Overall Borrower Performance Rating: Moderately Satisfactory 58. Overall, Borrower performance is considered to have been Moderately Satisfactory. Commitment to achieving the GEO, in accordance with obligations under the Stockholm Convention, was manifested throughout project implementation teams that were committed to managing and monitoring for results, despite certain difficulties with respect to management capacity, as noted above. Also, the government support and commitment throughout both project preparation and implementation phase was excellent. 6. Lessons Learned - Final hazardous waste disposal options need to be based on good baseline inventory data, on the other hand, decisions on disposal should not be delayed – The project preparation team and the client made a pragmatic decision to halt the decision on investment in disposal facility(ies) until sufficient data on the amounts and locations of PCBs become available. Given the limited 15 initial financing available, it is important to have a cost-effectiveness analysis to compare the cost of different disposal options. While construction of temporary storages is not a long-term solution, it is warranted in situations when benefits overweight costs and risks. - Inventory design needs to take into account actual availability and quality of data – While the national inventory methodology under the project was well designed, selection of samples for testing faced unexpected challenges, given the quality of equipment databases that at times lacked some of the key features, e.g., age of the equipment. As a result, the test data do not provide accurate information that would allow an estimate on the overall PCB amounts and require further tests. - Establishment of a regulatory framework is a priority – It is important to not only ensure phase-out of the existing amounts of hazardous waste and PCBs, but also to avoid cross- contamination and increase of PCBs in the environment. One of the critical issues that Vietnam faced at the onset were related to the storage of retired electrical equipment and PCB oils that are prone to create cross-contamination due to lack of proper regulations and technical guidelines. Adoption of the necessary regulations was key to start adoption of good environmental practices. Technical guidelines, training and demonstration activities enhanced these results. - Public outreach activities need to be carefully designed, tailored to the right audiences and appropriately timed – While the public outreach activities under the project were successfully implemented and increased public awareness, the upgrade of EVN PCB storages, which were located next to populated areas, had difficulties receiving approval from the local planning authorities. Communication with the stakeholders and affected beneficiaries to explain the benefits of upgrading hazardous waste facilities to safer standards, thus securing safer environment could have possibly avoided this. - Project interventions targeting biggest owner of PCB equipment need to be carefully designed in order to achieve intended impacts – While EVN is the biggest owner of the PCB equipment, the project interventions in terms of number of activities and costs were mostly targeted to non-EVN enterprises. While this was a pragmatic decision, given the financial capacity of the EVN and presumption that limited demonstration activities would enable EVN to scale them up, EVN’s commitment to project activities appeared to be uneven, particularly in the early stages of the project. - Flexibility of sequencing project interventions is crucial in projects that involve data collection and planning phase – As the PCB inventory that was to feed into decisions on the follow-up activities was delayed, these activities were also delayed. The implementation teams took the right decision to start the follow-up activities despite unavailability of full inventory data. Such flexibility in staging the activities is a pragmatic solution when project implementation delays are experienced. - Consultant selection criteria should be carefully thought through, particularly for the key activities - Contract management may appear to be a complex issue. The TORs and qualification criteria should be properly designed to attract qualified and reputable companies that are interested to commit the initially proposed teams as well as provide quality and timely outputs. Cancelling of the contract due to poor performance and re-bidding is complicated and time- consuming and might not always be an option given the sequence of activities and project closing dates. 16 - Collaboration between implementing agencies is crucial to avoid implementation delays and achieve best results – When two implementing agencies are involved, particularly in carrying out joint activities, collaboration between them is essential, as in the project case evidenced by the decision-making process related to the PCB inventory methodology between EVN and VEA/MOIT PMUs. 7. Comments on Issues Raised by Borrower/Implementing Agencies/Partners (a) Borrower/implementing agencies 59. The first draft Project Completion Report prepared by the PMUs was sent to the Bank on October 28, 2015. In evaluating project design and achievements, the report indicates satisfaction with project outcomes. The impact that the project’s implementation had with respect to raising consciousness and building capacity with regard to PCB management issues at all levels of society is considered to be key to the sustainability of efforts. A summary of Recipient’s completion report can be found in Annex 7. 60. The draft ICR was shared with VEA, MOIT and EVN, and their comments and concurrence received on December 18, 22 and 23. While the implementing agencies generally concurred with the proposed ratings, VEA suggested to upgrade the Bank’s quality of supervision rating to Satisfactory due to supervision team’s efforts, support and close monitoring, particularly at the end of the project. In addition, VEA commented that they do not see the stakeholder risk to development objective, given the vast regulatory framework developed with clear assignment of responsibilities of the PCB owners, including in identification, analysis, monitoring, removal, storage, disposal and reporting. The biggest risk to the development objective would, on the other hand, be late action on PCB treatment/disposal, and lack of understanding of health risks related to PCB exposure in some enterprises/people. This would be mitigated by immediate actions to address these issues. Full set of comments are available in project files. (b) Cofinanciers 61. N/A (c) Other partners and stakeholders (e.g. NGOs/private sector/civil society) 62. N/A 17 Annex 1. Project Costs and Financing (a) Project Cost by Component (in USD Million equivalent) Actual/Latest Appraisal Estimate Percentage of Components Estimate (USD (USD millions) Appraisal millions) 1. PCB management framework 4.164 5.892 141.5 and action plan 2. PCB management 4.978 6.211 124.8 demonstration 3. Institutional strengthening 3.787 1.770 46.7 4. Monitoring and evaluation 2.275 0.316 13.9 5. Project management 1.744 3.539 202.9 Total Baseline Cost 16.948 17.726 104.6 Contingencies 0.552 Total Project Costs 17.500 17.726 101.3 Project Preparation Facility (PPF) 0.350 0.347 99.1 Total Financing Required 17.850 18.073 101.4 (b) Financing Appraisal Actual/Latest Type of Estimate Estimate Percentage of Source of Funds Cofinancing (USD (USD Appraisal millions) millions) Counterpart Borrower 6.34 7.29 114.9 financing Global Environment Facility (GEF) Grant 7.00 6.83 97.5 Local Sources of Borrowing Country In-kind 3.15 2.60 82.5 SWITZERLAND: Swiss Agency for In-kind 1.01 1.00 99.0 Dev. & Coop. (SDC) TOTAL 17.50 17.73 101.3 18 Annex 2. Outputs by Component PAD output Actual output Component 1: PCB Management Framework and Action Plan Sub-component 1.1 : Development of a comprehensive set of PCB regulations Legal definition of PCBs Definitions provided in the below listed regulations Definitions of PCB-contaminated wastes National Technical Regulation QCVN 41/2011/BTNMT on co-processing of hazardous waste in cement kilns National Technical Regulation QCVN 40:/2011/BTNMT on industrial wastewater National Technical Regulation QCVN 43:2012/BTNMT on sediment quality Draft6 National Technical Regulations on the permissible limit of PCBs in soil Draft Vietnam standards on analysis of PCBs, incl. (i) Standard on instruction for grid sampling of PCBs contaminated soil; (ii) Standard on analysis of PCBs in non-porous solid material surface; (iii) Standard on analysis of PCBs in biological sample; (iv) Standards on analysis of PCBs in insulating oils; (v) Standards on analysis of PCBs in soil/sediments Draft Guideline for control of toxic releases, incl. PCB in ship dismantlement and industrial zone activities Retirement schedule of PCB-containing Legal document7 on ‘Retirement schedule of equipment for various applications, if any PCB-containing equipment; Restriction on re- use and recycle of PCB-containing oil’ Restriction on reuse and recycle of PCB- National Technical Regulations QCVN containing oils 56:2013/BTNMT on Waste Oil Recycling (MONRE; Dec 31, 2013) 6 All Draft documents mentioned in output section have been prepared and submitted to the relevant authorities for adoption, expected in late 2015/2016 7 Legal documents serve as background analysis documents and have been incorporated in (1) Circular on PCB management; (2) NIP; and (3) National PCB Action Plan 19 PAD output Actual output Draft Circular on management of PCB- containing equipment, products and materials8 Legal document on ‘Retirement schedule of PCB-containing equipment; Restriction on re- use and recycle of PCB-containing oil’ Requirements for labeling, packaging and on- Draft Circular on management of PCB- site storage facilities containing equipment, products, and materials Methods for transport and disposal of PCB- Draft Circular on management of PCB- containing oils and wastes containing equipment, products, and materials8 Requirements for contingency/emergency Draft Circular on management of PCB- response plans containing equipment, products, and materials Registration and reporting of PCB-containing Draft Circular on management of PCB- oils, equipment and wastes containing equipment, products, and materials8 Roles and responsibilities of government Legal document on ‘Roles and responsibilities agencies on inspection and enforcement of government agencies on inspection and law enforcement; and Liability-based cost recovery system to support implementation of sound PCB management’ Draft Circular on management of PCB- containing equipment, products, and materials Draft National PCB Action Plan NIP update Liability-based cost recovery system to Legal document on ‘Roles and responsibilities support implementation of sound PCB of government agencies on inspection and law Management enforcement; and Liability-based cost recovery system to support implementation of sound PCB management’ Draft Circular on management of PCB- containing equipment, products, and materials Amendments of Decision 155/1999 on Circular No.12/2011/TT-BTNMT of April 14, hazardous wastes management taking into 2011 of MONRE stipulating hazardous waste account provisions of Decision 23/2006 and management Circular 12/2006 8 Based on analysis and recommendations from the project financed report ‘Requirements and guidelines for registrations, labelling, packaging, on-site storage, on-site storage facilities, and reporting with respect to PCB oil, equipment and hazardous waste, applicable to PCB waste generation, PCB owners; Method of transport and disposal of PCB oils and hazardous waste’ 20 PAD output Actual output Circular No.36/2015/TT-BTNMT of MONRE stipulating hazardous waste management (Revision of Circular No.12/2011/TT- BTNMT) QCVN 07:2009/BTNMT on technical regulations for hazardous waste threshold9 Update of occupational health and safety Report on ‘Legal definition of PCBs; revision legislation and regulations under the Ministry and update of policies and regulations with of Labor, War Invalids and Social Affairs to respect to PCBs’ cover PCBs Report on ‘Assessment and recommendation for environmental health management related to toxic chemicals (PCB, PTS, mercury, etc.)’ Revision of TCVN 5507 - 2002 to reclassify Revision completed PCBs as toxic chemical, instead of flammable material Update of provincial policies and regulations Report on ‘Legal definition of PCBs; revision in the demonstration provinces covered by the and update of policies and regulations with project respect to PCBs’ Sub-component 1.2: Technical and administrative guidelines Review and revision of technical guidelines Draft National Technical Regulation QCVN for land-filling of hazardous wastes (Decision xx:2015/BTNMT on landfilling of hazardous 60, 2002, MOSTE) waste Review and revision of the design standards Review completed by project financed report, for construction of hazardous waste landfills, submitted to VEA/MONRE TCXDVN320-2004 Review and revision of the guidelines for the National Technical Regulation QCVN use of cement kilns for disposal of hazardous 41:2011/BTNMT on co-processing of wastes hazardous waste in cement kilns (MONRE; Dec 26, 2011) Guidelines for identification, management, Guidelines on identification of PCB- repair and retro-fitting of PCB-containing containing oil, equipment, materials, and equipment waste (VEA; Nov 20, 2014) Guidelines for the registration process for Guidelines on registration of PCB-containing PCB waste generators and PCB owners oil, equipment, materials, and waste (VEA; Nov 20, 2014) Guidelines for labeling, packaging, transport, Guidelines on packaging and labelling of and storage of hazardous wastes, including PCB-containing oil, equipment, materials, and PCBs waste (VEA; Nov 20, 2014) Guidelines for decontamination of PCB- Guidelines on decontamination and disposal containing transformers of PCB-containing oil, equipment, materials, and waste (VEA; Nov 20, 2014) 9 These documents were partly supported by the project by involving project hired PCB expert from MONRE 21 PAD output Actual output Guidelines for on-site storage of PCB- Guidelines on storage of PCB-containing oil, containing equipment and materials equipment, materials, and waste (VEA; Nov 20, 2014) Guidelines on transportation of PCB- containing oil, equipment, materials, and waste (VEA; Nov 20, 2014) Guidelines for emergency response Guidelines on response and contingency plan development on PCBs (VEA; Nov 20, 2014) Guidelines on prevention and response of PCB incidents (VEA; Nov 20, 2014) Guidelines/Protocols for inspection officers Guidelines on inspection of PCB management (VEA; Nov 20, 2014)   Collaborative Code of Practice – 01QCLN- TCMT=TCHQ between VEA and General Department of Customs in environment protection during export and import of some articles, including PCBs/POPs Sub-component 1.3: National PCB management action plan Inventory methodology Completed National PCB inventory Completed first state for non-EVN; almost completed first stage for EVN National PCB Management Action Plan Draft Completed and submitted to MOIT for enacting Component 2: PCB Management Demonstration Sub-component 2.1 : Site-specific investigations Site investigations at 15 selected facilities in Completed in 7 sites in 7 provinces 10 demonstration provinces Sub-component 2.2: Site-specific PCB management plans Site-specific PCB management plans in 7 management plans in demonstration sites demonstration facilities Sub-component 2.3: Voluntary retirement 21 PCB-containing transformers in Pha Lai of PCB-containing equipment at some Power Company retired facilities in Pha Lai Power Company etc. Sub-component 2.4: Proper handling of PCB-containing oils and equipment Implementation of the site-specific PCB Implementation started in 7 demonstration management plans developed under sub- sites completed under sub-component 2.210 component 2.2 10 For non-EVN sites: 17 containers of 20ft have been installed in 6 sites 22 PAD output Actual output Identification, inspection, labeling, Temporary storage completed in 1 storage site maintenance, packaging, transportation, and temporary storage of PCBs at the 15 sites Sub-component 2.5: Infrastructure improvement Improvement of existing storage facilities at New storage facilities constructed in 7 the demonstration sites demonstration sites; several additional EVN facilities upgraded Laboratory upgrade - PCB test kits or 2 PCB analyzers for 2 EVN subsidiaries; analyzers for the 15 sites PCB analyzers and quick tests took kits for 6 non-EVN sites and VEA laboratories Oil recycling units and servicing tools in 15 2 oil recycling units for 2 EVN subsidiaries; sites 3 oil recycling units, 5 PCB analyzers and quick tests took kits for 6 non-EVN sites Sub-component 2.6: Demonstration of administrative measures for PCB management Inspection officers of relevant authorities will 44 facilities based in 15 provinces/cities conduct inspections of at least 25 sites inspected by inspection officers of VEA (including the 15 demonstration sites) per year VEA to undertake at least 5 inspections per 80 sites (in 5 years) visited and inspected by year at other sites in the selected provinces DONREs and VEA During site inspections, sampling and 151 samples of PCB-containing oils as well as screening of at least 20 PCB-containing oils soil samples collected and analyzed and wastes at each site; On average about 10 soil samples per site sent for detailed chemical analyses by gas chromatography technique at the certified laboratories Selected customs offices implement protocols NinhBinh Custom Office implemented pilot to be developed under this project to carry out protocol import/export inspection Brief reports summarizing findings at each All reports and information on VEA inspected sites processed by the MIS for supervision activities of PCB management at future evaluation Quang Ninh Port were uploaded to the MIS Component 3: Institutional Strengthening Sub-component 3.1 : PCB management capacity development International PCB expert recruited 3 international PCB experts recruited Training on export/import control of PCB- 2 trainings with 180 participants containing materials PCB screening and sampling training 3 trainings with 180 participants PCB testing and analysis training 4 trainings with 160 participants PCB management technical training 4 trainings with 220 participants Emergency response training 5 trainings with 345 participants PCB management policy training 5 trainings with 400 participants Sub-component 3.2: Public outreach Training of journalists. 4 trainings with 200 participants 23 PAD output Actual output Media coverage of PCB issues and project Media outputs include: (i) 6 articles for gov officials; (ii) 6 articles for enterprise management; (iii) 15 articles for workers and general public; (iv) 4 in-depth technical articles; (v) 5 radio reports; (vi) 6 video/TV trainings; (vii) leaflets for enterprises, and action leaflets; (viii) posters; (ix) newsletter Advertisements in national and local See above newspapers and professional journals Occupational health education program 2 trainings with 120 participants Production and distribution of public See above awareness materials National and international workshops 1 international workshop organized in Vietnam with 132 delegates Participation in 5 international workshops (25 participants from Vietnam) Component 4: Monitoring and evaluation Sub-component 4.1: PCB management MIS completed and operational information system (MIS) Sub-component 4.2: Project launch Project launch workshop carried out in March workshop 2010 with 200 participants Sub-component 4.3: Project monitoring and evaluation Project Steering Committee annual meetings 5 annual meetings Annual review workshops 5 ministerial meetings to collect comments and improve cooperation between stakeholders Mid-term and project completion review Mid-term progress report submitted; Draft completion report submitted on October 28, 2015 Sub-component 4.4: Implementation Completion workshop carried out in June completion workshop 2015 with almost 100 participants PCB Inventory Results: Summary of PCB sources in Vietnam: PCBs have not been directly produced in Vietnam, however they existed in the country through imports of industrial oils (hydraulic oil, gas turbine oils, lubricants and plastic additives) and PCB- containing equipment from the 1940s to 1985. Two preliminary inventories of electrical equipment containing PCBs were carried out in 2004 and 2006 under the NIP and found an estimated 9,600 tons of PCB-containing oils in Vietnam. However, the inventory report cautioned that this was an underestimation, as the surveys covered only 70 percent of the facilities of Vietnam Electricity (EVN). Furthermore, it was estimated that EVN owns only about 70 percent of oil-containing electrical equipment in Vietnam. 24 PCB containing equipment and materials in Vietnam include: - Electrical equipment that use insulation oil such as transformers; breakers, capacitors that are used for protecting, switching off the circuits and improving the grid quality. Such equipment is widely used in the electricity and other industries, at power transmission systems, electric distribution and consumption systems. - Industrial equipment suspected of containing PCBs, such as hydraulic equipment, heat transfer manufactured before 1995 and less than 3 times of oil replacement11, especially in the fields of mechanics, cement, chemical, metallurgy, food processing, water supply plants, etc. - All types of used and stored oils, including insulation oils (including transformer oil, capacitor oil and electrical cable oils), special lubricants for industrial use (air-compressor oil, refrigerating compressor oil, vacuum pump oil, hydraulic oil). - All types of PCB-suspected wastes, such as PCB-polluted land areas, materials or waste generated from using additives in the plastic industry, sealants in construction building, etc. The biggest owner of PCB-containing equipment in Vietnam is Vietnam Electricity (EVN), which includes power transmission units, power plants, power distribution, production and electrical equipment repairing units. EVN has: - 3 power generation corporations (EVNGENCO1, EVNGENCO2, EVNGENCO3), which manage 46 thermal and hydro power plants; - 7 power generation companies with 7 large power plants that are directly managed by EVN; - 5 power distributions corporations for customer services, including Hanoi Power Corporations (EVNHANOI). Hochiminh City Power Corporation (EVNHCMC), Northern, Southern and Central Power Corporations (EVNNPC, EVNSPC, EVNCPC respectively). Under these 5 Corporations there are 118 Power Companies that directly manage and operate approximately 190,000 distribution transformers (as of 2015) at voltage levels 6 – 35kV; - National Power Transmission (NPT), which was established by reorganizing 4 Power Transmission Companies (PTCs) and 3 project management committees (PMUs of North, Central and South electric projects). NPT manages 265 power transformers at voltage levels from 110 – 500kV. Besides, owners of PCB containing equipment and materials that belong to non-EVN include: (i) 47 independent power plants (non-EVN). These plants are concentrated in 23 provinces; (ii) 58 companies, enterprises and factories, which use transformers, generators, compressors, breakers, capacitors, devices using hydraulic oil, lubricating oil etc., manufactured before 1995. Besides, the transformers’ manufacturers and maintenance workshops, and oil suppliers and manufactures use transformers, electrical equipment, industrial equipment used lubricating oil, hydraulic oil manufactured before 1995 and hazardous waste treatment plants may receive waste- oil potentially contaminated with PCB for treatment or reuse. 11 Referred from EPRO Consulting JSC (2011). Development of PCB Inventory Methodology. 25 Inventory results EVN Transformers EVN Inventory was mainly conducted under CS1/EVN contract. The implementation was a joint effort of both the consultants and EVN. After contract signing, a preliminary statistical database (as of 2012) of EVN transformers from EVN subsidiaries was provided to the consultant. This database consisted of approximately 180,000 devices. As noted in the contract, only maximum 50,000 units would be sampled and screened (quick-tested) by L2000DX to determine total Chlorine content, among which no more than 2,500 will be analyzed for PCB with GC if the Chlorine level is above 50ppm. The consultant proposed to select transformers for sampling / testing based on the manufacturing date and conduct training sessions on sampling for EVN staff who then sampled the transformers. To reach the 50,000 targeted amount, the manufacturing date of selected transformers was extended to include 2010 in some EVN subsidiaries. As almost all transformers were connected to the power grids, the work experienced technical constraints, including safety precaution (availability of cutting power before sampling) and actual condition of draining valve. While the consultant provided sampling tools and received oil samples for analysis, all sampling tasks were conducted by EVN and were very time-consuming. Some screened oil samples (with Chlorine content below 50ppm) have also been analyzed with GC under Non-CS11/EVN package using saved GEF budget from other activities. As noted in the CS1 Final Report (June 2015), a total of 47,300 quick-test results were made, among which: a. 18,065 samples (38%) are found with total Chlorine not exceeding 5ppm; b. 29,235 samples (62%) contained more than 5ppm of Chlorine After completion of both CS1 and Non-CS11 contracts, a total of 4,939 separate GC results were recorded (after excluding some duplicated results in these packages). These include: c. 3,994 samples (~8% of total 47,300) with PCB content not exceeding 5ppm; d. 574 samples (~1%) with PCB from 5 – 50ppm; e. 371 samples (~0.7%) with PCB above 50ppm Because PCB standard in Vietnam is currently 5ppm, the above analysis results can be classified as follows: - Group 1, including known-PCB results, which consists of 22,059 PCB-free devices (=18,065 + 3,994) and 945 PCB-contaminated ones (= 574 + 371). Group 2, including unknown-PCB results which consists of 24,296 devices with Chlorine contents from 5 – 50ppm (= 47,300 – 22,059 – 945) and have not been analyzed with GC to define PCB content. Capacitors Based on data provided by EVN’s companies, there are 30,298 capacitors were managed. Among 30,298 inventoried capacitors, 26,537 capacitors (equivalent to 87.6 percent) do not have information about types of oil or liquid used and as such were classified as PCB suspected capacitors. In the remaining 3,761 capacitors (equivalent to 12.4 percent), most of them (3,690 26 capacitors) were classified as non-PCB and 71 capacitors as PCB “Therminol” (equivalent to 0.2 percent). Non-EVN Transformers, electric equipment Results of the inventory report (June 2015) indicated that related information on 93,846 equipment (including 91,755 electrical equipment and 2,091 industrial equipment) of non-EVN units in 63 provinces in the country has been gathered12. Among these equipment, 36,152 were suspected as PCB-contaminated (equivalent to 38.52 percent), including: - 5,911 electric equipment manufactured before 1995; - 8,765 electric equipment manufactured during the period of 1996-2000; - 21,120 electric equipment that lack information; - 204 capacitors manufactured before 1995; - 152 industrial equipment manufactured before 1995 Of the total of 36,152 PCB-suspected equipment, there were only 152 industrial equipment (equivalent to 0.42 percent). As such, the focus of inventory was on electric equipment with the priority as follows: - Equipment that contains original oil produced from 1995 and earlier and including those with unknown year of production; - Equipment that used non-original oil; - Equipment that used original oil but was manufactured domestically after 1995 The priority areas of inventory included: (1) large central cities that have higher industrial and services development such as Ha Noi, Ho Chi Minh City, Hai phong, Da Nang and Can Tho because these areas housed highest amount of electrical equipment and industrial equipment and (2) the provinces that have industrial sectors developed before 1980 as Quang Ninh, Bac Giang, Bac Ninh, Thai Nguyen, Phu tho since they use several old generation electric equipment. A screening study showed that no PCB-suspected equipment was found in the following provinces: Bac Kan, Dien Bien, Lai Chau and Vinh Phuc (Northern); Quang Binh, Quang Tri, Thua Thien- Hue, Quang Nam, Kon Tum and Gia Lai (Central); Binh Thuan, Bac lieu, Ca Mau, Kien Giang and An Giang Province (Southern). Therefore, sampling was conducted at the other 48/63 provinces, including 21/25 Northern provinces; 12/18 provinces into the Central and 15/20 Southern provinces. By May 2015, 9,006 oil samples taken from non-EVN units (including 8.747 oil samples taken from equipment, 60 samples for QC and 199 on-site waste oil samples) of 48/63 provinces in the country were analyzed by GC/MS. The results revealed that 5.2 percent of samples taken from equipment had PCB concentration > 5 ppm and 1.94 percent - concentration > 50 ppm. Capacitors The inventory report also shows that from statistical data of 23/63 provinces/cities in Vietnam (equivalent to 36.5 percent), number of PCB suspected capacitors are 5,612, of which, 204 capacitors were manufactured before 1995; 2,413 capacitors were manufactured in the period of 12 Presentation of Nguyen Ngoc Vinh (Ph.D.) about National Inventory of PCB in oil and equipment of non-EVN units at the Workshop on PCB inventory for non-EVN, hold by Ministry of Industry and Trade on 5/6/2015. 27 1996-2000 and 2,995 capacitors do not have related information. So far, the amount of oil contained in these capacitors has still not been determined yet. In addition, currently, companies, enterprises, businesses of major corporations such as Vietnam Oil and Gas Group; Vietnam National Chemical Group; Vietnam National Coal – Mineral Industries Group; Vietnam National Textile and Garment Group; Vietnam Steel Corporation; and Vietnam Paper Corporation are also operating and storing 702 PCB suspected equipment (including transformers, generators, compressors, breakers, capacitors, devices used hydraulic oil, lubricating oil, etc.) that were manufactured before 1995 and 70 equipment were manufactured in the period of 1996 – 2000. Among these equipment, 648 pieces of equipment (equivalent to 83.9 percent) have indicated the amount of oil contained in the unit. Total amount of oil from 648 equipment are 458.1 tons. As of May 2015, data on concentration of PCB of oil in these equipment was not available yet. Therefore it is not possible to conclude about PCB suspected oil from inventoried equipment of these corporations yet. Besides, the number of circuit breakers (produced before 1995, and undergone oil change less than 3 times); number of TU/TI (using original oil, with no indication of the year of manufacture or were manufactured before 1995, and equipment that did not use original oil); amount of on-site stored oil include recycled oil, recovered and wasted oil from electrical equipment (in the case of (1) storage place far from schools, hospitals, buildings, parks, markets less than 500 m; (2) oil storage of recycling companies; (3) oil storage from electrical equipment reparation and manufacture companies and (4) oil storage of equipment owners), all do not have inventory data yet. Estimated amount of PCB suspected oil EVN The inventory identification of oil samples analyzed with QT and GC has been linked to that of sampled transformers. Subsequently oil weight of sampled transformers can be found in the database. Among 945 PCB-contaminated transformers the oil weight has been known for 525 devices with total weight of 260 tons. Consequently it can be estimated that total PCB oil in 945 devices would be 468 tons (= 260 tons x 945 / 525). Among 371 PCB transformers with contamination above 50ppm, the oil weight was recorded for 217 devices with total 94 tons. Estimated total oil weight for all 371 high-PCB transformers would be 160 tons (= 94 tons x 371 / 217) and for transformers with PCB level of 5 – 50ppmwould be 308 tons (= 468 tons – 160 tons) Out of 24,296 transformers with Chlorine content from 5 - 50 ppm that have not been analyzed with GC for PCB level, there are 14,720 devices verified with oil weight, which would amount to 8,761 tons. Estimated total oil with Chlorine from 5 – 50ppm would be 14,460 tons (= 8,761 tons x 24,296 / 14,720). Non-EVN Transformers, industrial equipment Among 35,796 PCB-suspected equipment, 8,747 were taken oil samples for PCB analyzing by GC/MS (equivalent to 24.4%). Non-EVN PCB inventory results (May 2015) are as follows: 28 PCB range 5-50ppm PCB above 50ppm Number of Total oil mass Number of Total oil mass equipment (tons) equipment (tons) 289 125.61 170 90.99 Rate: 3.3% Rate: 1.94% *Rate = Number equipment identified PCB/ Total inventoried equipment (accounting for 8.747 equipment) According to the rate of PCB identified equipment, total oil mass for non-EVN can be calculated as follows. ‐ Total oil with PCB range 5-50ppm = 35,796 * 3.3% * (125.61/289) = 513.42 tons ‐ Total oil with PCB above 50ppm = 35,796 * 1.94% * (90.99/170) = 371.69 tons Capacitors Based on inventoried results as of May 2015, it is possible to estimate approximately the amount of PCB containing oil capacitors of non - EVN as follows: 204 PCB- suspected capacitors/0.36513 x 7 kg/capacitor = 3,912 kg = 3.91 tons (1) Percentage of cities/provinces carrying out capacitor inventory So far it is impossible to identify the amount of PCB-containing oil from capacitors as GC/MS analysis data are not available yet. Thus, total amount of PCB-suspected oil of EVN and non-EVN units is estimated from in-complete inventoried results and summarized in Table 1. - Transformer oil has the highest ratio in total amount of PCB suspected oil needed to be handled. In the other words, the first priority is to concentrate on the replacement, stop the use, and treatment of PCB contaminated oil from transformers. - High percentage of transformer oil needed to be handled is from EVN’s transformers (about 468 tons of 584.96 tons, equivalent to 80 percent)14. Table 1: PCB oil Type Unit EVN units Non-EVN units Industrial Total groups Transformer oil Tons 468.0 885.11 1353.11 PCB ≥ 5-50 ppm Tons 308.0 513.42 821.42 PCB ≥ 50 - 500 ppm Tons 160.0 371.69 531.69 Capacitor oil Tons No data 3.91 3.91 Breaker oil Tons No data No data TU/TI oil Tons No data No data Stored oil Tons No data No data Industrial oil Tons No data Total Tons 468.0 930.28 1398.28 13 Percentage of cities/provinces carrying out capacitor inventory 14 Update as of December 2015 29 Annex 3. Economic and Financial Analysis 1. The project was designed to contribute to both local and global public good by reducing the risk of the release of PCBs into the environment. Due to the lack of reliable baseline data and difficulties associated in measuring the impact of the overall environmental, health and related socio-economic impacts, the Bank concluded that it was not possible to conduct a traditional economic or financial cost-benefit analysis for the project. However, a cost-effectiveness analysis of four alternative technical solutions was carried out, which also included a business as usual, full disposal and transportation, and pilot (partial) disposal options. 2. Most of the project investments were consultancy assignments - necessary to establish the regulatory and institutional basis for PCB management and phase-out. In addition to smaller purchases of laboratory testing and monitoring equipment, and MIS software, the key investment related to the construction of PCB storage facilities. There was no clean-up or remediation of PCB- contaminated sites or PCB treatment/disposal carried out as part of the project. Quantification of indirect impacts of safe PCB storage on human and environmental health was not done at completion due to these reasons, some of which were similar to those at preparation, including: (i) assumptions of human health impacts would be impossible to attribute to safe storage only; (ii) there was no health analysis data collected during the project; (iii) only smaller amounts of PCB- containing equipment was actually transferred to the safe storage facilities, thus cutting the pathway of the risk of potential exposure, within project period. The actual costs of storage facilities (US$ 303,691 for the six non-EVN sites) was in line with the projections at the appraisal. The storage capacity of these facilities sites is about 250t of PCB-containing equipment and waste, thus the storage cost for 1 ton of PCB is around US$ 1,215. This cost has indeed proven to be much less costly than the cost of transport and shipping to a high temperature hazardous waste facility overseas, which was the only readily available option at the time, and would have come at a cost of at least US$ 4,000-5,000 per ton or more. Disposal option would also result in additional cost that is related to early retirement of equipment. Thus, if all GEF grant available had been used to ship and destroy PCB-containing equipment/oil, it would only be able to address part of the issue, i.e., around 1,400 tons of PCB oil, while leaving no framework, capacity, way forward at the end of the project to address the remaining amounts of the PCB oil, with no system in place to prevent environmental releases of the remaining amounts. The approach selected was more cost effective in containing and limiting the hazard quickly that this only other option available at the time of shipping and incinerating. In time local incineration options will become available that will achieve the same long-term outcome at an overall lower cost. 30 Annex 4. Bank Lending and Implementation Support/Supervision Processes (a) Task Team members Responsibility/ Names Title Unit Specialty Lending Douglas J. Graham Sr. Environmental Specialist EASVS TTL/ Environment Jiang Ru Operations Officer EASOP Co-TTL TTL during Helen Chan Sr. Operations Officer EASRE preparation Viraj Vithoontien Sr. Regional Coordinator ENVMP Environment Hoang Xuan Nguyen Procurement Analyst EAPCO Procurement Sr. Financial Management Hung Viet Le EAPCO FM Specialist Cung Van Pham Financial Management Specialist EAPCO FM Hoi-Chan Nguyen Sr. Counsel LEGES Legal Mei Wang Sr. Counsel LEGES Legal Quang Ngoc Bui Social Specialist EASVS Social Trang Thi Phuong Nguyen Environmental Specialist EASVS Environment Toan Huy Ngo Environmental Specialist EASVS Environment Giang Thanh Huong Le Program Assistant EACVF Administrative Evelyn Bautista Laguidao Program Assistant EASRE Administrative Nina Queen Sr. Program Assistant EASRE Administrative Supervision/ICR Douglas J. Graham Sr. Environmental Specialist GENDR TTL Jiang Ru Sr. Environmental Specialist GENDR Co-TTL Hisham A. Abdo Kahin Lead Counsel LEGES Legal Giang Thanh Huong Le Program Assistant GTIDR Administrative EASVS - Huy Toan Ngo Environmental Specialist Environment HIS Hoang Xuan Nguyen Procurement Specialist GGODR Procurement Ba Liu Nguyen Procurement Specialist GGODR Procurement Ha Thuy Tran Financial Management Specialist GGODR FM Ruxandra Maria Floroiu Sr. Environmental Engineer GENDR TTL at ICR Thuy Cam Duong Environmental Specialist GENDR Co-TTL at ICR Solvita Klapare Sr. Environmental Economist GENDR ICR author Quyen Thuy Dinh Program Assistant EACVF Administrative 31 (b) Staff Time and Cost Staff Time and Cost (Bank Budget Only) Stage of Project USD (including travel Note Cycle No. of staff weeks and consultant costs) Lending FY2007 14.38 60,726.01 BBGEF FY2008 28.19 113,835.65 BBGEF FY2009 21.81 109,998.64 BBGEF Total 284,560.30 Supervision/ICR FY2010 9.59 36,392.20 BBGEF FY2011 10.31 54,547.64 BBGEF FY2012 9.05 52,297.19 BBGEF FY2013 8.90 49,121.50 BBGEF FY2014 14.36 50,799.55 BBGEF FY2015 18.42 71,200.56 TF018171 TF018171 FY2016 5.18 22,763.27 Total 316,358.64 32 Annex 5. Beneficiary Survey Results N/A 33 Annex 6. Stakeholder Workshop Report and Results 1. The project completion workshop took place in June 2015. The following paragraphs summarize the results of the workshop. 2. The project results and activities have been appreciated by many organizations, government agencies, including MONRE and DONREs, MOIT and DOITs, Ministry of Health, Ministry of Agriculture and Rural Development, Ministry of Construction, Ministry of Labour, Invalids and Social Affairs, General Administration of Customs, the local Customs Departments, Market Management Agencies, Police Department of the environmental crime prevention (EP) and provincial Police Divisions of environmental crime prevention, Provincial People's Committees, etc. These institutions concluded that the following are the key contributions of the project:  The agencies have benefited from the capacity building activities, such as staff training, information provision; equipment for environment monitoring, inspection and supervision activities on PCBs, POPs and hazardous chemicals.  Several agencies were provided office equipment, computers, servers, cars to support project implementation, and implementation of governmental programs related to PCB management.  Government officials from several agencies have participated in overseas research, training activities, international conferences, and have visited laboratories, waste treatment facilities, etc. Thereby, their capacity and knowledge have been strengthened in PCBs, POPs and chemicals management.  Domestic workshops and training activities served as forums for stakeholders to exchange information, provide consultations, share experiences on the government management for PCBs, hazardous waste, toxic chemicals, and prevention and control of environmental incidents.  In general, management capacity of government agencies has been strengthened through the expanded regulatory framework, technical guidelines and mechanisms for inter-sectoral collaboration; channels built to exchange information and share experiences and coordinate inter-sectoral management and monitoring.  The project has also contributed to the development of mechanisms for exchange and cooperation between government agencies, enterprises and media units, dissemination of information and awareness raising on the risks of PCBs and hazardous chemicals, and benefits of safe management of these chemicals.  State and private enterprises, as well as corporations, such as EVN, Vinachem, trading and manufacturing facilities owning electrical equipment, also appreciated project interventions, including the benefits of increased information, awareness raising about the PCBs and environmental protection and investment in infrastructure. Namely: o EVN has benefitted from awareness and knowledge about PCBs; has implemented the internal PCB inventory, focusing on equipment with the highest risk of PCB contamination; collection of information about PCBs to enable the future suitable management of PCB-containing materials, including basis for informed decisions on the storage, disposal and treatment strategies. Besides, some units in EVN have received investment in infrastructure and equipment, such as PCB storage, quick test took kits, filters, packaging materials etc. o In the project framework, many units in EVN have been trained in developing PCB management plans, environmental incident prevention and response plans, dissemination of updated regulations on hazardous waste management etc. 34 o Non-EVN enterprises have also benefitted from significant improvement in the level of awareness about the risks and safe management of PCBs, toxic chemicals and hazardous waste management, through training, communications and performed inspection, and testing activities, such as water supply and sewerage companies, paper, engineering mechanic, brick manufacturers, poultry farms, minerals enterprises, etc. o Staff and management of PCB and hazardous waste storage facilities and treatment units have benefitted from the training and communication activities; waste management processes and plans development; some units received equipment, upgraded infrastructure, received information/training on PCBs and other hazardous chemical containing wastes. o Management Boards of industrial zones/industrial parks increased their awareness level about PCBs, POPs, strengthened capacity on prevention and response to environmental incidents, improved their knowledge about general pollution prevention and control.  Research Centers and Institutes and laboratories were provided with information, additionally trained on analysis, monitoring, risk assessment, safe management of PCBs and similar toxic chemicals. These units also benefited from the provision of advisory services; some were equipped with analysis equipment and consumable material.  Through the project, Inter-Laboratories Inspection activities have created a sharing experience channel on methods, processes of analyzing, monitoring of POPs in Vietnam as well as quality control process, coordination mechanism, strengthening cooperation, building a network between laboratories.  Universities were provided with updated/state of art information, syllabi, technical documentation on the safe management of POPs, PCBs.  Other social organizations benefitted from information, awareness raising, and access to brochures, manuals.  The press, media agencies and journalists received training, and latest comprehensive information. Through the activities of the project, experts in the field of management and science shared expert information with journalists to enable delivering the messages to a broader audience in easy to understand and accurate information. They also participated in the survey group, business meetings to raise awareness of the fact to have the right view of environmental, health risks and business activities; trained and supported for communication and professional development activities through training of trainers, communicators. 35 Annex 7. Summary of Borrower's ICR and/or Comments on Draft ICR ASSESSMENT OF OUTCOMES 1. Relevance of Objectives, Design, and Implementation 1. In order to achieve country’s as well as global objectives on environment protection and safe management of PCBs, the project established two Project Development Objectives, including: (i) to develop national capacity in Vietnam to manage all PCBs and (ii) on a pilot basis in selected provinces safely store significant amounts of PCBs in anticipation of future disposal, towards the final goals of safety management and reduce releases of PCBs into environment at national scale. 2. The specific objectives of the project were also set properly, including: (i) development of legal and institutional framework for PCB management; development of National Action Plan on PCB management and safe disposal; (ii) demonstration of PCB management in major sectors that use PCB and in 10 selected provinces; and (iii) capacity building for all stakeholders on sound management of PCBs; awareness raising for the public. The rationale of those objectives has been confirmed at the end of the project through implemented activities and achieved results. 3. Regarding project design, components and activities of the project were developed adequately and were feasible for the Vietnam’s country situation, including the institutional mechanisms and coordination among relating organizations, agencies and enterprises. 4. Original budget allocations for components and activities were also appropriate. However, regarding EVN storage improvement, the selection of location faced some difficulties, and therefore, the number of facilities did not meet the original target. The saving were used to purchase more analytical equipment for identification of additional PCBs containing materials and equipment, as well as packaging materials. 5. Achieved outcomes and outputs proved that project’s specific objectives have been achieved and scope of some activities has even exceeded the original expectations. Furthermore, some new activities have been added to the scope of the project with approval from the Government and the WB, but still consistent with the initial objectives, in order to support the long-term results and ensure sustainability of the project. 6. The design of 2 PMUs in different agencies with separated and specific responsibilities has increased the responsibility of 3 project owners namely MONRE, MOIT and EVN, led to the increase of human resources mobilized for the project and facilitated the parallel implementation of the project activities. Active involvement of 3 project owners also led to increase in mobilization of co-financing sources. The coordination and information exchange between MONRE and MOIT was close and effective. 2. Achievement of Project Development Objectives 7. As mentioned above, the project has been designed with 2 PDOs, towards the ultimate goal of sound management and reduction of PCB release to environment and human exposure in Vietnam. 8. The first PDO “to develop national capacity in Vietnam to manage all PCBs” - after the implementation and completion of project activities, the PCB management capacity in Vietnam in general has been strengthened considerably, including on a national scale, covering institutional capacity increase, development of policies and inter-ministerial coordination mechanisms, 36 increasing awareness, and improving state of science and technology, etc. In terms of awareness, public awareness campaigns were highly successful in raising knowledge and awareness, which resulted in change of behavior and attitudes, especially in governmental management authorities and enterprises. Regarding training, the project has provided with a lot of related training courses and workshops; those training courses and workshops were highly appreciated by relevant departments and agencies, customs agencies, environmental police, and enterprises, etc. Development of legal framework, building institutional capacity and public awareness raising have contributed significantly to prevention of PCB and POPs in general further contamination. 9. The second PDO has also been successfully achieved and storage capacity has been enhanced. Specifically, EVN’s PCB safe demonstration storage was completed at Pha Lai, and also upgraded in Quang Ninh, Dong Anh, Hanoi, Da Nang, Dong Nai, Hochiminh City, etc. For non-EVN sites, storage facilities are also ready to store PCB-containing equipment and materials. Procedures on safe storage and operation and EIAs were developed appropriately for each specific site, the staff were trained ensuring human capacity to operate the facility safely; plans on prevention and emergency response were developed completely and trainings for each site were implemented; quick test kits to identify materials and wastes containing PCB, oil filters to reduce risks of cross contamination, safety equipment and personal protective equipment were also purchased. 10. At some sites, a number of PCB-containing waste is kept safely, such as 7 tons of PCBs contaminated waste at Cai Lan Port (then was transported and safely disposed), equipment containing PCB is stored at Pha Lai storage, waste oils and PCB equipment also safely stored in multiple storage facilities under subsidiaries of EVN, such as Electricity of Dong Nai, Hochiminh City, Hanoi, Quang Ninh. 11. Six PCB storage facilities were improved at waste management and waste oil recycling facilities. These storages meet legal requirements to store PCBs as soon as PCBs are detected. 3. Efficiency 12. Implementing costs at the moments of deploying project activities and PCB management: 1. Project cost: 7,000,000 USD and co-financing to implement following activities: 1. Cost to develop PCBS management policy 2. EVN and non-EVN inventory 3. Build EVN storage 4. Build and improve non-EVN storages 5. Materials, equipments for sites 6. Public awareness campaign, training, raising knowledge and awareness 7. Expanded activities: analysis equipments, environmental health 2. Costs of deploying and applying new policies, regulations: 1. Dissemination and guide implementation of new regulations, guidelines 2. Analysis and disposal applying Vietnam standards, National technical regulations, and regulations 3. Replacement of transformers, electrical equipment 4. Storing cost of equipments, wastes containing PCBs 5. Disposal of oils, wastes containing PCBs 6. Analysis, environmental monitoring related to PCBs pollution 37 3. Results obtained in terms of economy and society: 1. Environmental benefits: reduced pollution of soil, water, sediment; tourism environmental protection (e.g., handling PCBs in Halong Bay, Quang Ninh) 2. Protect export market of seafood and agricultural produce: prevention of pollution in aquaculture, controlling the spread of PCBs in exported products chain 3. Safe management of PCBs thus reducing the cost of monitoring and risk assessment for contaminated sites, in environment in general and in food chain 4. Health benefits: reduced exposure of workers, reduced accumulation in food chain, and reduced illness in community; reduced risks to health of the people in consumer society. 5. Demonstrating responsibility of Vietnam to the international community on protection of the environment and health. 4. Justification of Overall Outcome Rating 13. Above sections summarized main results of the project. Regarding the first objective, the project completed legal framework on POPs in general and PCBs in particular, and the capacity of offices and the cooperation between functional agencies of MONRE, MOIT, General Department of Customs, MOH, EVN, Environmental Police, etc. have been strengthen. These results also increased the cooperation mechanisms between central authorities and local authorities regarding sound management of PCBs and control of toxic chemicals in general. As a result, it could be concluded that the project archived the first objective, results are sustainable, and therefore can be rated Satisfactory. 14. For the second objective, the project cooperated with functional agencies to conduct activities on monitoring, inspection, guidance on PCB management at number of facilities from the north to the south of Vietnam. These activities were implemented based on requirements and technical guidelines developed in framework of the project. These activities effectively contributed to the sound management of PCBs as well hazardous waste in general; awareness and activities on safe management and disposal of equipment and materials containing PCB have also been increased. The periodic monitoring and inspection resulted in the facilities to understand the risks and requirements on PCBs management, implement suitable activities, and create an effective information exchange channels with relevant authorities. 15. In conjunction with the increase in PCB management capacity, the project completed the construction/improvement of facilities for safe storage of PCB. In this activity, the project investigated 14 facilities that store, recycle, maintain transformers; store, dispose hazardous waste in order to select the sites that require improvement in compliance with requirements regarding PCBs. Six non-EVN PCB storage sites and one EVN site were then constructed/improved for storage as part of project activities. In addition, these storing sites were equipped with necessary equipment and materials, such as quick test tool kits, oil filters, packaging and labelling materials etc. for safe operation and avoidance of cross-contamination. These seven storage sites are located in different seven provinces along Vietnam for safe transportation and storage of PCBs. 16. Before project start, there were only two laboratories having capacity on providing accurate analysis of PCBs; however, at that time, relevant authorities had not yet officially certified the capacity of those laboratories. The project implemented number of activities on investigation of capacity of laboratories in Vietnam on POPs/PCBs analysis; training on POPs/PCBs analysis using quick test tool kits and advanced analytical instruments (Gas chromatography – GC) in different sample matrix, such as insulating oils, sediments, soils, wastewater, etc. for technical staff from 38 laboratories, institutions, Government offices of VEA, DONRE, DOIT, Departments of Customs, environmental offices, etc. In addition to this technical training, two inter-laboratory crosscheck campaigns were organized for up to 25 Vietnam laboratories and two international laboratories. Until now, based on training activities and results from cross check campaigns, six Vietnam laboratories have capacity of PCBs analysis; and four among them have been certified by VEA (following Decree No. 127/2014/NĐ-CP). 17. While not originally planned, the project also carried out environmental risk assessments, environmental health aspect analysis regarding PCBs/toxic chemicals, control of PCBs and toxic chemicals pollution in ship dismantlement and industrial zone. Those activities have created a close integration between PCBs management and pollution control activities, environmental protection in general, and the sustainability of the project. 18. Strengthened capacity is an important component of the Vietnam PCB Management Project not only in attracting the participation of communities in the management of PCBs through knowledge of hazards of PCBs to health and environment but also in helping with compliance with PCB management plan developed by the Government of Vietnam. With the objectives of: (i) strengthen capacity of relevant stakeholders in management of PCBs and (ii) mobilize public support for sound PCBs management, the Vietnam PCB Management Project has implemented capacity building activities on many aspects, including activities to strengthen the transfer of technical knowledge, which have been done through the activities of the awarded consultant service contracts, trainings/workshops, etc. More than 45 workshops/training courses for approximately 4,300 participants nationwide from local units, including DONRE, DOIT, DOLISA, Customs, Environmental Police, research institutes, laboratories, enterprises, etc. have been organized during last five years of the project. Followings are few typical activities: Training workshops on import and export control of PCB materials; Training workshops on sampling, quick analysis of PCBs, and advanced analysis of PCBs; Inter-laboratory crosschecks for PCB analysis in transformer oil; Training workshops on emergency response; Workshops on evaluating prevention, response and recovery of chemical and PCBs incidents; Training workshops on PCB management policy; Training workshops on environmental technical standards, regulations on PCBs. 19. Furthermore, the project launched a successful public outreach campaign (in three years, from October 2011) for public awareness on PCB management through articles in press, radio and TV reports, participation in international seminars for project activities dissemination, preparation of POPs and PCB newsletters, pamphlets and other relevant handbooks. 20. Also, the web portal “pops.org.vn” and a specific PCB website in both English and Vietnamese have been developed and updated periodically during project implementation to provide general audience with information on PCBs/POPs policies and regulations and technical information and guidelines pertaining to sound PCBs management. The POPs portal and PCBs website have been linked to the VEA website and recently have been upgraded with a number of relevant news in English language for which up to 8 million accesses have been recognized. ASSESSMENT OF RISK TO DEVELOPMENT OUTCOME * Risks not anticipated during project preparation: 21. The initial design of the project did not include activities related to supporting treatment of PCB (as assessment of treatment technologies, or pilot treatment technology). Therefore, when the project implemented PCB management activities at the facilities, the facilities and waste generators 39 would like to thoroughly handle or store PCBs on sites instead of long-term storage of PCBs at the sites selected by the project in order to eliminate environmental and regulatory risks soon. 22. At the beginning of the project, the facilities repairing transformers which were expected to join the project did no longer manufacture, or involved in business related to transformers and old electrical equipment, so they did not participate in the project. Therefore, the project actively surveyed, sought other facilities and cooperated with hazardous waste treatment and waste oil recycling facilities. The survey, assessment, selection and achievement of the cooperation agreement has prolonged the duration of building PCBs storage warehouses and also affected other activities of the project. 23. Difficulties in sampling and inventory of transformer oil: For EVN, many transformers are still being operated in the grids and the large number of samples that needed to be analyzed led to PCBs inventory process delay. For non-EVN facilities, the variety of owner facilities also increased time of PCB inventory. This also affected other activities of the project, such as updating data on management information system, development of national action plan on PCBs management, strengthen inspection of PCB management at the facilities. * During implementation of the project, the risks mentioned above were mitigated as follows: 24. For PCB treatment, authorized management agencies, EVN and the project has encouraged the facilities handling PCBs when they have eligibility; developed next phase project related to treatment of hazardous waste, including PCBs; actively sought for the international partners to transfer PCB treatment technologies to Vietnam. 25. For change in the PCB storage sites, the project surveyed, identified and built new PCBs storage warehouses to ensure technical and legal requirements for long-term storage of PCBs. 26. For difficulties in PCB sampling and inventory: EVN and MOIT have actively coordinated, enhanced experts, supplemented counterpart resources, shared power cut schedules, sampling and analysis plans, ... and promoted of inventory progress keeping initially expected sample numbers. 27. In the future, after the project completion, VEA, EVN, MOIT and related agencies also have plans to actively implement measures to ensure the sustainability of the project, and minimize risks, including: 28. Continuously promote implementation of regulations and guidelines on sound PCB management and treatment; strengthen inter-sectoral coordination. 29. Continuously maintain communication activities, dissemination of information related to the risks caused by POPs/PCBs. 30. Combine and promote PCB management and treatment activities in the general activities of hazardous waste management. ASSESSMENT OF BANK AND BORROWER PERFORMANCE 1. Bank Performance 31. The Bank - as a Global Environment Facility (GEF) Implementing Agency – has a responsibility to assist its client countries to achieve global environment objectives that are supported by the GEF. The GEF is the interim financial mechanism of the Stockholm Convention. This PCB Management Project would contribute significantly to achieving the objectives of the corresponding GEF Operational Program for Reducing and Eliminating Releases of Persistent Organic Pollutants. The Bank has technical knowledge on POPs management and experience in 40 the design and implementation of GEF investment projects. The Bank’s long-standing and broad involvement in the power sector in Vietnam allowed for synergies to be developed. 32. The project was designed with the components and activities that are distinct to ensure the feasibility for achieving the goals of the project as well as the disbursement plan. During implementation, the Bank has supported the project on building procurement plan and workplan very actively. Also, the Bank has provided technical support on procurement management, financial management, managing the implementation of the consultancy contracts, especially in the final stages of the project after it was restructured and to ensure project progress. 33. Through the missions, the Bank and PMUs have monitored the results of the project, provided technical comments, ensuring the process of project accordance to the provisions of the WB and Vietnamese government, and ensure the goals of the project are achieved. Through fieldwork, the Bank has helped to resolve technical issues, reviewed the environmental documents that helped to choose the most suitable locations for the PCB storage sites. 2. Borrower Performance 34. During the project implementation, the PMUs made efforts in building and completing policy framework on PCB management, prevention and response to emergency incidents, pollution control and health protection. Besides, the PMUs were active in the propaganda, dissemination and awareness-raising for different audiences from the state authorities, the business sector, institute and research centers, universities, the Industrial Management Board and social organizations. The PMUs also directed the implementation of activities to ensure the sustainability of project and developing the plan of activities for the next phase of the project. 35. For organization, proper arrangements related to PMU members were put in place to enable solving problems during project implementation. The project offices were equipped, the staff had professional and technical capacity necessary to achieve the objectives. 36. Regarding the method of implementation, the project has shown flexibility during the implementation; for example, mechanisms and policies were developed to meet the actual demand (standards, technical guidance notes, additional to those initially planned). The project has actively arranged personnel, time and financial resources for performing investigations and surveys to choose locations for storing PCBs with many different establishments, from north to south of the country (about 14 sites). 37. About administration, finance, procurement, in addition to the supervision of the World Bank, all project activities were under the strict control of many government units, the Department of Planning and Finance of VEA, the leadership of the VEA and the Departments of MONRE: the Department of Finance, Department of International Cooperation, the Organization Department and other departments, such as: Hanoi Tax Department, State Treasury, Ministry of Planning and Investment, the Independent Auditor. Through the inspections of these units, financial activities, bidding procurement of project were considered compliant with the provisions of CPVN and donors. In addition, the project also performed compliance reporting by weekly reports to the PCD, VEA; monthly reports for the ICD and MOST; monthly tax report, quarterly report for the ICD, MOST, Financial Planning Department of the VEA and General Department of Environment, Planning Department of the MONRE and the Ministry of Natural Resources and Environment; quarterly reports to the World Bank; disbursement reports, annual reports for the ICD and Science and Technology Department, Financial Planning Department of VEA; annual reports to the Planning Department, Ministry of Natural Resources and Environment; the annual audit report, and other 41 reports, including 6-month report to the Ministry of Natural Resources and Environment, Report on the inspection schedule of the World Bank, Ministry of Finance Report (aid certification). LESSONS LEARNED Advantages 38. In terms of implementation, the project was split in 2 PMUs, one under the management of VEA/MOIT, and the other under EVN, which created independence for each party in procurement activities, implementation of EVN and non-EVN inventory and disbursements. Disadvantages 39. Regarding reporting mechanism, splitting implementation between 2 PMUs showed advantages, however, the responsibility to submit reports and sharing information was not regulated initially, causing problems with sharing of information, especially information on storage construction, inventory data. In addition, regulations and deadlines for submitting reports were not clear, resulting in delays and efforts in collecting and reviewing data. 40. Regarding cost norm, the PAD anticipated inflation, fluctuations of market prices, however, as prescribed in PIM, all expenditures had to comply with MOF requirements, which were usually lower than the market price, causing difficulties for disbursement. Besides, going through long periods of development, approval and implementation of the project, cost estimates for some packages of goods, civil works, such as purchasing oil filters, construction of storage/warehouse were lower than real-time prices, causing difficulties to select suppliers while ensuring quality. 42 Annex 8. Comments of Cofinanciers and Other Partners/Stakeholders N/A 43 Annex 9. List of Supporting Documents 1. Project Concept Note 2. Project Appraisal Document 3. Project Grant Agreement 4. Environmental Impact Assessment 5 Country Partnership Strategy (CPS) for Vietnam 2007-2011 6. Country Partnership Strategy (CPS) for Vietnam 2012-2016 7. Aide Memoires for Supervision Missions 8. Implementation Status Reports (ISRs) 9. Mid-Term Review Report 10. Draft National PCB Action Plan, May 2015 11. Project (Restructuring) Paper 14. Project Progress Reports prepared by PMUs 14. Completion Report prepared by PMUs 44 MAP 45