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Inventory of sites that are potentially

impacted by HCH in EU Member States


List of sites in Romania
January 20, 2022
Final

Environment
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PDF ISBN 978-92-76-49608-3 doi:10.2779/315387 KH-07-22-164-EN-N

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Our reference R044-1272383SAR-V03-beb-NL

Responsibility
Title Inventory of sites that are potentially impacted by HCH in EU Member
States
List of sites in Romania
Client European Commission, DIRECTORATE-GENERAL ENVIRONMENT,
Directorate D - Natural Capital Unit D1 - Land Use & Management
Project Manager Boudewijn Fokke (TAUW)
Author(s) Javier Sancho
Second reader Boudewijn Fokke
Confidentiality level Public
Project number 1272383
Number of pages 80
Date January 20, 2022
Signature This document was released with the explicit approval of authorized project
management.

Colophon
Consortium of HCH in EU
(TAUW bv (the Netherlands), CDM Smith Europe GmbH (Germany) and SARGA; Sociedad Aragonesa de gestión
Agroambiental S.L.U. (Spain))
Handelskade 37
P.O. Box 133
7400 AC Deventer
Final

The Netherlands
E hchineu@tauw.com

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Table of contents
List of Abbreviations ......................................................................................................................... 4

Terminology used ............................................................................................................................. 5

0 Executive Summary................................................................................................................... 6

1 Introduction ................................................................................................................................ 7

1.1 The HCH in EU project ....................................................................................................... 7

1.2 Structure of the report ........................................................................................................ 7

2 Inventory approach .................................................................................................................... 7

3 List of Sites ................................................................................................................................ 8

3.1 Sites that are potentially impacted by HCH and Lindane ................................................... 8

3.1.1 Overview ..................................................................................................................... 8

3.1.2 Production sites......................................................................................................... 19

3.1.3 Processing sites ........................................................................................................ 20

3.1.4 Waste deposits.......................................................................................................... 21

3.1.5 Landfills ..................................................................................................................... 21

3.1.6 Treatment centres ..................................................................................................... 21

3.1.7 Storage facilities ........................................................................................................ 21

3.1.8 Other sites ................................................................................................................. 21

3.2 Disclaimer......................................................................................................................... 22

3.3 Uncertainties in the inventory ........................................................................................... 22

4 Conclusions and recommendations ........................................................................................ 22

Appendix 1 Inventory Approach ................................................................................................... 23

Appendix 2 Source Overview ....................................................................................................... 31

Appendix 3 Document Overview .................................................................................................. 33

Appendix 4 Country Gross List .................................................................................................... 37

Appendix 5 Site Characterization ................................................................................................. 52


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List of Abbreviations
AVAS Authority for State Assets Recovery
CSM Conceptual Site Model
EU European Union
GIM Geographic Information Model
HCH Hexachlorocyclohexane
HCH in EU Pilot project to evaluate and address the presence of Lindane and
HCH in the EU (ENV.D.1/ETU/2019/0023)
ICSM Initial Conceptual Site Model
IHPA International HCH & Pesticides Association
NEPA National Environmental Policy Act
NIP National Implementation Plan for the Stockholm Convention
POP Persistent Organic Pollutants
SARGA Sociedad Aragonesa de Gestión Agroambiental
SC Stockholm Convention
UIP Union Implementation plan for the Stockholm Convention
UTC Turda Chemical Plant

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Terminology used
• Commission: European Commission - Directorate General Environment.
• Consortium: The TAUW bv (the Netherlands), CDM Smith Europe GmbH (Germany) and
SARGA; Sociedad Aragonesa de Gestión Agroambiental S.L.U. (Spain) Consortium.
• Filler: Additive to pesticides to enhance application and dilute the active ingredient (i.e.,
Lindane). Most fillers are inactive products not of environmental concern (lime, clay).
• HCH: C6H6Cl6, is any of several polyhalogenated organic compounds consisting of a six-
carbon ring with one chlorine and one hydrogen attached to each carbon. It is produced
through chlorination of benzene.
• Landfills: Sites specifically intended for chemical waste including Lindane and HCH-isomers
(alpha, beta, and delta) and its degradation products where disposal took place with some
level of containment measures.
• Lindane: Enriched HCH containing 99 % or more of γ-HCH. This product does not have the
distinctive smell of Technical HCH and has the best pesticidal properties.
• POP: Persistent Organic Pollutants.
• Production sites: These are sites where Technical HCH and/or Lindane were produced.
• Processing sites: Sites where Technical HCH and/or Lindane were processed / formulated
into market ready pesticides. These sites did not produce the base HCH but rather mixed with
fillers or other pesticides to produce a market ready product.
• Stockholm Convention: Stockholm Convention on Persistent Organic Pollutants is an
international environmental treaty, signed in 2001 and effective from May 2004, that aims to
eliminate or restrict the production and use of persistent organic pollutants including HCH.
• Storage facilities: Sites with storage facilities where obsolete stocks of POP-pesticides
including Lindane and HCH and its degradation products are stored awaiting final disposal.
• Technical HCH: The original mixture produced through chlorination of benzene. It consists of
5 isomers of HCH. Technical HCH contains about 14 % γ-HCH, 65-70 % α-HCH, 7-10 % β-
HCH, approximately 7 % δ-HCH, 1-2 % ε-HCH, and 1-2 % other components.
• Treatment centres: Sites where Technical HCH and its degradation products and Lindane
were treated and/ or destroyed in the scope of projects mitigating the related environmental
risks.
• Waste deposits: Sites where HCH-isomers (alpha, beta, and delta) and its degradation
products and Lindane are dumped without any proper containment.
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0 Executive Summary
This report provides an overview of sites in Romania that are potentially impacted by HCH and
that were identified in the context of the inventory of the HCH in EU project. The list could be used
for the planning of the management of contaminated sites and the fulfilment of the obligations in
the context of the Stockholm Convention on POPs and the EU POPs Regulation, more specifically
Article 6e of the Stockholm Convention that requires states to “Endeavour to develop appropriate
strategies for identifying sites contaminated by chemicals listed in Annex A, B or C; if remediation
of those sites is undertaken it shall be performed in an environmentally sound manner”. For the
inventory, a distinction between sites with high (priority 1), medium (priority 2), and low (priority 3)
environmental risks is made. This distinction is made to be able to address the limited project
resources to the high-risk sites. The inventory demonstrates that Romania has the following
15 sites which potentially have been impacted by HCH and Lindane. From these sites:
• Three former production sites which have the highest priority concerning the environmental
risk and they are:
- Turda Chemical Plants
- Oltchim site
- Chimcomplex Borzesti
• One site is a processing site and Associated with the activity of Oltchim site
• Seven are waste deposits
- Five waste deposits with Lindane production waste of the Turda Chemical Plants
- One waste deposit with Lindane production of the Oltchim site
- One waste deposit with Lindane production of the Chimcomplex
• Four are storage facilities, in the Constata County

There are no landfills with HCH waste and/or Lindane and there are also no HCH treatment
centres in Romania.

As HCH is a POP under Part A of Annex III of the REGULATION (EU) 2019/1021 OF THE
EUROPEAN PARLIAMENT AND OF THE COUNCIL on persistent organic pollutants (June 20th,
2019), under article 10 of this regulation the Commission, supported by the Agency, and the
Member States shall establish or maintain, as appropriate, in close cooperation, appropriate
programmes and mechanisms, consistent with the state of the art, for the regular provision of
comparable monitoring data on the presence of substances as listed in Part A of Annex III in the
environment.
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1 Introduction
1.1 The HCH in EU project
The European Parliament has tasked the European Commission with the management of a
project to evaluate and address the presence of Lindane and HCH in the EU. The Commission
has selected a consortium consisting of TAUW bv from the Netherlands, CDM Smith Europe
GmbH from Germany and Sociedad Aragonesa de Gestión Agroambiental (SARGA) S.L.U. from
Spain to deliver this project.

The objectives are to get a view of the presence of Lindane and HCH impacted sites in the EU
and to help authorities dealing with the legacy of these Persistent Organic Pollutants (POP) in
six pilot projects. Despite the prohibition on the production and use of Lindane and HCH in the EU
its presence and persistence in the environment remains a significant threat for human health and
our ecosystem.

The HCH in EU project has the following two tasks:


1. Inventory of the HCH contaminated sites in all the EU member states (Task 1)
2. Consultancy service for selected six projects/cases of the HCH contaminated sites (Task 2)

1.2 Structure of the report


This report provides an overview of the sites that are potentially impacted by HCH and/or Lindane
in Romania and that were found in the context of this inventory. The list could be used for the
planning of the management of contaminated sites and the implementation of the obligations of
the Stockholm Convention on POPs of Romania. This introduction is followed by Chapter 2
providing an overview of the inventory approach. For more details on the approach reference is
made to Appendix 1. Details of the sites identified are provided in Chapter 3, with a
characterisation of the individual sites. Appendix 4 is the Country Gross list of sites providing the
Current Site name, the former site name, the site address, the site X and Y coordinates, the site
use label, the site description, if relevant the years of operation, the site status related to the HCH
contamination, and the references used. The characterisation of nine priority sites is provided in
Appendix 5. Appendix 2 gives an overview the sources consulted for this inventory process.
Appendix 3 lists the documents used. The final chapter, Chapter 4, contains conclusions and
recommendations for the competent authorities.

2 Inventory approach
To identify the sites that are potentially impacted by HCH and Lindane in Romania (Task 1 of this
HCH in EU project), the Consortium followed ten steps to ensure that no sources were
overlooked, and that maximum input was gathered. The ten Steps of Task 1 are:
• Step 1.1 Initial check of available international data
• Step 1.2 Initial country inventory of HCH/Lindane sites
• Step 1.3 Informing relevant stakeholders of the identified sites and requesting their input.
Final

• Step 1.4 Updating the inventory with input from external stakeholders

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• Step 1.5 Further investigation of identified sites


• Step 1.6 Outreach to national and international stakeholders on identified sites
• Step 1.7 Public actions (workshops, webinars, meeting) to involve main stakeholders
• Step 1.8 Further characterisation of priority sites
• Step 1.9 Classification of Sites according to their environmental management levels
• Step 1.10 Final list of HCH and Lindane contaminated sites the EU

Each of these steps consists of a top down and bottom-up approach. The top-down approach is to
gather data from public and international sources relating to known sites. The bottom-up approach
mostly relates to the collection of circumstantial data to try and trace back to hitherto unknown
sites. More details on the mentioned steps are provided in Appendix 1 - Inventory Approach.

3 List of Sites
3.1 Sites that are potentially impacted by HCH and Lindane

3.1.1 Overview
During the inventory phase in Romania several sites have been reviewed and assessed for the
potential presence of HCH and/or Lindane. In Appendix 4 the gross-list of these sites, i.e., all sites
the Consortium looked at, is presented including the reference documents used to assess their
status. The following table (Table 3.1) contains all sites that are confirmed to have handled HCH.
This overview provides for each site: the Site Code; the Location Code; the Use Label (production
site, landfill, waste deposit, treatment centre, storage facility, processing site or others); the current
address; a short site description; the environmental setting (nature, urban area, industrial area
etc.); the site history and the current site use.

The Site Code uses the Country Code (for Romania RO) the first two letters of the town or region
the site is located and a number, as more sites can be present in the town or region, (for the site in
Turda the site code RO-TU-01). As a site can have more locations, a Location Code is used to
identify these. The Location Code is made by the Site Code with a number (for the site in Turda
RO-TU-01-01). Besides this the overview gives a satellite or aerial photograph with the site
indicate. All these site information is also in a Geographic Information Model (GIM). The GIM is
used to store all site data in a structured way.
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Table 3.1 Overview of HCH suspected sites in Romania


Assigned Location Use label Current address Short description Environmental History Current use Aerial overview
site code code setting
RO-TU-01 RO-TU- Production 22 December 1998, The site is in Turda City, Cluj County, on the right Urban area The site belonged before to the Chemical SC Sadachit Procom
01-01 site nr.12C, Turda bank of Arieș River. The site is known as the Turda Plants of Turda. Between 1911 and 1948, the SA - organic salts
Chemical Plants Industrial Platform. In 1954, Turda Chemical Plants Solvay Soda Factory (Solvay Plant Group) production activity
(UTC) began to produce HCH (1,2,3,4,5,6 - the Gamma operated on the site. This company was (from 2002)
isomer, known as Lindane or Hexachlorane). The nationalized and transformed in June 1948 Saint Gobain Weber
production of Hexachlorane is achieved by chemical into the Turda Chemical Plants. In 1954, România - plaster RO-TU-
chlorination of benzene followed by a purification step Turda Chemical Plants began to produce production 01-01
to enrich the active gamma isomer and to remove the HCH. The production of HCH stopped in 1983. CDS Performance
inactive part, which was disposed of as waste, with no In 1998, UCT definitively ceased its activity. Chiptuning Cluj -
possibility of recovery. This waste has been deposited Turda Chemical Plants were included in the optimization of car
over the years on various sites in Turda City and in the recent National Contaminated Sites Inventory engine software
vicinity. It is estimated that approximately 60,000 tons (2019) prepared by the NEPA. AIRBAG Turda - Car
of waste are deposited. The production of HCH Service
stopped in 1983. In 1998, UCT definitively ceased its Rewa Turda -
activity and entered the legal liquidation procedure Commercial centre
through bankruptcy, according to Law 64/1995 (law Peluci Service Doctor
that was later repealed by Law 85/2206). In October Auto - Car Service
1999, the assets of UCT were transferred by AVAS to Modulo Decorative
several legal entities without establishing or Solutions SRL -
transferring environmental obligations upon cessation Manufacture of
of the activity of production and sale of assets. It is plaster products for
known that some of the assets were taken over by SC construction purpose
Nuha Traiding SRL, SC Sadachit Procom SA, SC (from 2004)
Reicon Consulting SRL, but the current situation is not
fully clarified due to repeated sales or winding-up
procedures. It is known that in the period 2001-2002
UCTs were demolished. Also, the situation is not
clear. Turda Chemical Plants were included in the
recent National Contaminated Sites Inventory (2019)
prepared by the NEPA. On the site of Turda Chemical
Plats there are 3 contaminated areas. The official site
codes from national inventory are: RO6APMCJ00037,
RO06AMPCJ0029, RO6APMCJ00025. Outside of
Turda Chemical Plants there are other 5 contaminated
areas (former waste deposits). The official codes from
national inventory for these sites are:
RO6APMCJ00020, RO6APMCJ00021,
RO6APMMCJ00023, RO6APMCJ00024,
RO6APMCJ00028.

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Assigned Location Use label Current address Short description Environmental History Current use Aerial overview
site code code setting
RO-TU-01 RO-TU- Waste Chimistilor Street, The waste deposit is a satellite site of RO-TU-01-01 Fallow Considering the period of Lindane There is currently no
01-02 deposit Turda Chemical and know as the Aries waste deposit. The site is manufacturing in Turda Chemical Plants activity on this site
Plants situated on the right side of the River Aries (built-up (1954-1983), it is assumed that the waste
area) between the boundary of the Chemical Plant storage activity took place during this period.
and the dam on the right side of the river. The nearest
resident area is in the southern part about 100-120 m
of the site boundary. It is assumed that the waste is
dumped during the period Lindane was produced
(1954-1983). The waste deposit has a surface area of
0,4 ha. The common practise was to store the
technical HCH at the back of the site in open depots.
No information is available on how HCH waste was
stored. It is assumed that the waste was deposited
directly on the ground and was covered with soil. It is
estimated that the amount of waste stored is approx.
14,800 tons. The volume of the contaminated soil is
8,000 m3. The maximum HCH concentration in the soil
is 472,914 mg/kg. Due to the location of the site, near
Aries River and near residential areas, the site
represents a risk to human health and the aquatic
ecosystem. There is currently no activity on this site.
The site was included in the recent National
contaminated Sites Inventory (2019) prepared by the
NEPA. The official code is: RO6APMCJ00020.

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Assigned Location Use label Current address Short description Environmental History Current use Aerial overview
site code code setting
RO-TU-01 RO-TU- Waste Petru Maior Street, This waste deposit is a satellite site of RO-TU-01-01. Fallow It is assumed that the waste was dumped The current owner of
01-03 deposit Turda The site is known as Posta Rât and is situated outside during the Lindane production period 1954- the site is Turda
the town of Turda, on the left bank of the Aries River. 1983. A remediation project was proposed Municipality
The nearest houses (Petru Maior Street) are at about and had to be implemented by the end of
10 m from the site. The distance to the nearest water 2015. Unfortunately, Turda City Hall failed to
well is 650 m. It is assumed that the dumping took sign the contract for awarding the
place during this Lindane production period (1954- decontamination works. The auction was
1983). Waste was brought to the site and mixed with started in 2012 and in 2015, after numerous
soil. The site occupies an area of 4 ha., the volume of appeals and lawsuits, the members of the
wastes is around 10,000 m3. The quantity of deposited auction commission decided to cancel the
white powder + debris wastes is around 18,500 tons. entire procedure. Subsequently, the tender
The maximum HCH concentration in soil is 345.366 was resumed but the winner was not
mg/kg. Due to the location of the site, near Aries River announced. In this context, the funding was
and the residential areas, the site represents human lost, and the Turda City Hall tried to save the
health and aquatic ecosystem risks. The site was project by phasing it. The project was
included in the recent National contaminated Sites resumed in 2019. The land is being
Inventory (2019) prepared by the NEPA. The official rehabilitated. The project is financed by
site code is: RO6APMMCJ00023. European Funds through the POIM
Programme. The current site owner is Turda
Municipality.
RO-TU-01 RO-TU- Waste Situated in the This waste deposit is a satellite site of RO-TU-01-01. Natural terrain Considering the period of Lindane The current owner of
01-04 deposit proximity of the The site is situated outside the town of Turda, on the manufacturing in Turda Chemical Plants the site is Mihai
Transylvania left bank of the Aries River. It is assumed that the (1954-1983), it is assumed that the waste Viteazu Commune.
Highway (Brasov- waste was dumped during Lindane manufacturing storage activity took place during this period.
Borș) period (1954-1983). Deposit surface is 5,000 m2..The The situation of this deposit is special since it
volume of deposited wastes is around 7,500 m . The
3
is situated in the proximity of the Transylvania
maximum HCH concentration in soil is 815.734 mg/kg. Highway (Brasov-Borș). The site was partially
The current site owner is the Mihai Viteazu Commune. decontaminated during the construction of the
The site was partially decontaminated during the highway in 2010.
construction of the Transylvania Highway (Brasov-
Borș). The site was partially remediated by a
Consortium of SC Euro construct Trading 98 SRL
Bucureşti and I&C Transylvania Construcţii SRL Turda
- according to Environmental Permit no. 117
NV6/18.10.2010. The site was included in the recent
National contaminated Sites Inventory (2019)
prepared by the NEPA prepared by the NEPA. The
official code is: RO6APMCJ00024.

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Assigned Location Use label Current address Short description Environmental History Current use Aerial overview
site code code setting
RO-TU-01 RO-TU- Waste Stadionului Street, This waste deposit is a satellite site of RO-TU-01-01. Fallow Considering the period of Lindane There is currently no
01-05 deposit Turda no FN The site is situated on the right bank of the Aries manufacturing in Turda Chemical Plants activity on this site.
River. The site borders in the south with the Turda (1954-1983), it is assumed that the waste
Stadium and the Turda Sports Complex and in the storage activity took place during this period.
southwest with the headquarters of the Aries-Turda There is currently no activity on this site.
Water Authority and the Pelican Tourist Complex. The
nearest houses are in the south, at 400 m from the
site. The waste was brought tis waste deposit in the
period of Lindane manufacturing in Turda Chemical
Plants (1954-1983). The area and the contaminated
level are unknown. It was assumed that the waste
products were brought to this landfill and are mixed
with soil. Given the shallow groundwater level it is
assumed that the groundwater is contaminated. In
2004, soil and groundwater were investigated by
Minesa - the Institute of Mining Research and Design
for the ecological reconstruction. No information is
available on the results of the investigation. Due to the
location of the site, near Aries River and near
residential areas, the site represents human health
and the aquatic ecosystem risks. There are no wells
for groundwater monitoring on the site. The site was
included in the recent National contaminated Sites
Inventory (2019) prepared by the NEPA. The official
code is: RO6APMCJ00028.
RO-TU-01 RO-TU- Waste Cluj-Napoca This waste deposit is a satellite site of RO-TU-01 01 Fallow Considering the period of Lindane It was not possible to
01-06 deposit Industriala Vest and known as the Constructorul SCCA Cluj-Napoca manufacturing in Turda Chemical Plants identify what types of
deposit, Turda. The site is enclosed and in the vicinity (1954-1883), it is assumed that the waste activities are currently
of the Chemical Plant. The site belongs to SC storage activity took place during this period. being carried out on
Constructorul SA. It is assumed that the dumping took the site because its
place during the Lindane production period 1954- exact location is not
1883. Waste was brought to the site and mixed with known.
soil. The site occupies 0,24 ha. The site was included
in the recent National contaminated Sites Inventory
(2019) prepared by the NEPA. The official code is:
RO6APMCJ00021.

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Assigned Location Use label Current address Short description Environmental History Current use Aerial overview
site code code setting
RO-VL-01 RO-VL- Production Uzinei Street, No.1, The site is 10 km from the national road DN 64 Industrial Oltchim Râmnicu Vâlcea was founded in 1966 Starting in 2019, the
01-01 site Râmnicu Vâlcea (Râmnicu Vâlcea - Dragasani), on the right bank of the under the name of Ramnicu Vâlcea Chemical owner of the site
City, Vâlcea County River Olt. The installation was at the organic section Plant. The HCH-Lindane plant was built activity is
between the V road (northeast), the IV road between 1967-1968 and was put into Chimcomplex
(southeast) and the power station (southwest). The operation in 1969. Oltchim produced Lindane Borzesti - Ramnicu
production capacity was 800 tons/year. The HCH- between 1969-1998. In 1990, Oltchim SA was Valcea Branch
Lindane section produced Lindane (γ-HCH) which was establish as a joint stock company through the (Decision for the
marketed, and the other the isomers were stored in restructuring of the former exclusively state- transfer of integrated
the hazardous waste deposit, located in the southern owned company Chemical Plant Ramnicu environmental
part of the Oltchim site. 4 storage cells for the deposit Valcea (RO: "Combinatul Chimic Ramnicu authorization no. 79 /
of hazardous were built in1979 - 1980. 250 tons/year Valcea"). In 1998, after an economic 18.02.2019).
chlorinated residues from the vinyl chloride plant and assessment, measures were taken to close They manufacture
6,150 tons/year inactive isomers of Lindane plant were the HCH-Lindane installation and the basic organic
stored in these 4 storage cells. No information is pesticides unit. In 2012, Oltchim was (Polyether plants)
available on how the waste was stored prior to the privatized to become a joint stock company. and inorganic
construction of these cells. It is assumed that it was Between 2013-2018, when insolvency was chemicals. The
stored in at or in the vicinity of this location, as the soil declared, the Company was under the activities are
was already heavily contaminated with both organic administration of Romsolv and BDO Business regulated from the
waste from Oltchim and inorganic waste from the Restructuring Companies. The HCH environmental point
Govora Sodium Plants at the time of construction. installation and the pesticides unit have been of view by the
Formulation of pesticides using Lindane (manufacture removed, and a polyether plant was built at Integrated
of suspensions) took place in the pesticide Unit I-II. this site in 2013. Environmental
Soil investigations were performed on the site. The Authorization no. 6 /
results of those studies showed that the site is 25.05.2015 issued by
contaminated with mercury and HCH. The following APM Valcea. The
areas are contaminated with HCH: regulation is valid
• The off-site hazardous waste deposit of 12 ha until 25.05.2025.
located in the southeast part of the Oltchim site
on the right bank of the Olt River.
• The former on-site Pesticide Unit I-II of 0.05 ha,
located in the north part of the Oltchim site
• The former on-site HCH installation of 0.1 ha,
located in the south part of the site
The site was included in the National Register
Inventory of Contaminated/ Potentially Contaminated
Sites in 2013. Detailed site information is not available
as the National Inventory is not publicly available. No
specific actions have been requested in relation to the
listing. According to the Annual Environmental Report
of 2019 (prepared by the new administrator of the

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Oltchim site) the 4 storage cells were covered with

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Assigned Location Use label Current address Short description Environmental History Current use Aerial overview
site code code setting
tailings (sterile). The groundwater around the waste
deposit is contaminated. Inorganic chemical
contamination is also caused by the nearby sludge
landfill as well as propenoxide waste (the owner is
CIECH Soda Romania S.A. Ramnicu Vâlcea). In
2019, the soil was sampled for analyses on HCH
isomers (α-HCH, ß-HCH, γ-HCH, δ-HCH and total
HCH). The samples were taken from level I: 0- 10 cm;
level II: 30-40 cm; level III 60-80 cm from the
hazardous waste deposit, the former HCH installation
area and the former pesticide unit’s area. The results
are:
• The soil samples from the former pesticide unit
had elevated HCH concentrations but were
below the Alert Threshold for industrial land
• The soil samples from the former HCH-Lindane
Plant at the three are significantly contaminated
with HCH isomers
• The soil samples from the Hazardous Waste
Deposit in the vicinity of Cell no. 3 had HCH
concentration exceeding the intervention
threshold for industrial land
• The groundwater at the hazardous waste deposit
area is also contaminated with HCH
In 2019, Valcea EPA issued the Environmental
Approval for supplementary safety measures and
ecological reconstruction of the site. Since 2019, the
administrator of Oltchim is Chimcomplex Borzesti -
Ramnicul Valcea Branch. The land on which the HCH,
pesticide and hazardous waste facilities were located
is the property of the Romanian state (according to the
information transmitted by NEPA). There is no
information available regarding the environmental
obligations for these land at the sale of assets to
Chimcomplex Borzesti.
There are no records of previous events (spills,
releases, leaks etc) from the period between 1966-
2018 reported by the Company management to
Valcea LEPA (Local Environmental Protection
Agency). Olthim was included in the recent National

Final
Contaminated Sites Inventory (2019) prepared by the

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Assigned Location Use label Current address Short description Environmental History Current use Aerial overview
site code code setting
NEPA. The official codes are:
• APMVL00022 - pesticide unit I-II
• APMVL00023 - HCH Installation
• APMVL00001 - hazardous waste deposit.
RO-VL-01 RO-VL- Waste Situated in the This waste deposit is as satellite site of RO-VL-01-01. Natural protected The hazardous waste deposit was built The current owner of
01-02 deposit southeast part of The hazardous Waste Deposit has a surface of 12 ha. area between 1979 and 1980. The owner was the land (according to
the Oltchim site, on The closest residential property is approximately 80- Oltchim. The activities were ceased on the NEPA letter) is
the right bank of the 100 m north. The hazardous waste deposit had four 31.12.2006, except for cell no 4. According to the Romanian State
Olt River in storage cells. The following production residues were the newsletter of the general meeting of
Ramnicu Valcea. stored were: shareholders the execution works for closing
The site is at the • 250 tons/ year chlorinated residues from the vinyl the hazardous waste deposit have started
boundary of the chloride plant since 2014. In 2019, LEPA Vâlcea issued the
protected area • 6150 tons/ year inactive isomers of HCH from the Environmental Agreement for supplementary
Natura 2000 HCH - Lindane plant. safety measures and ecological reconstruction
ROSPA0106 Valea There is not available information related to the waste of the waste deposit The current owner of the
Oltului Inferior storage process. In total, 386,050 tons of organic land (according to the NEPA letter) is the
waste were storage, of which approx. 51% are inactive Romanian State
isomers of HCH and approximately 939,968 tons of
inorganic residues. The site was included in the recent
National Contaminated Sites Inventory (2019)
prepared by the NEPA. The official code is:
APMVL00001.
RO-VL-01 RO-VL- Processing Uzinei Steet, This processing site a satellite site of RO-VL-01-01. Industrial Industrial
01-03 site Râmnicu Vâlcea The area of the former Pesticide Unit I-II is in the north
City, Vâlcea County part of the Oltchim site. The soil from this area is
contaminated with HCH. The contaminated area has a
surface of 0,05 ha. According to the NEPA letter the
owner of the land is the Romanian State. The soil was
sampled on three levels (I: 0- 10 cm; II: 30-40 cm; III
60-80 cm) and the samples were analyses for HCH
isomers (α-HCH, ß-HCH, γ-HCH, δ-HCH and total
HCH isomers) in 2019, The results showed that:
• The HCH concentration of is below to Alert
Threshold for industrial land
This processing site was included in the recent
National Contaminated Sites Inventory (2019)
prepared by the NEPA. The official code is:
APMVL00022

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Assigned Location Use label Current address Short description Environmental History Current use Aerial overview
site code code setting
RO-BC-01 RO-BC- Production Industriilor no. 3 This production site is situated on the right bank of the Industrial Borzesti Chemical Plants was founded in Industrial
01-01 site Vâlcea County Trotuş River, about 8 km downstream of Oneşti City, 1954. In 1959 the first installation, the oxygen
Bacau County. Chimcomplex produced of lime factory, came into operation, which provided
chloride and Hexachlorane (Lindane). The nearest the oxygen necessary for the construction
houses are at about 100 m southeast of the site works on the industrial platform and on the
boundary. There is no information available on the construction sites in Onești. The Chimcomplex
period in which Lindane was produced. There is no plant was put into operation in 1960.
information available related to the capacity of the Chimcomplex was founded under Government
Lindane installation or to the production waste. Decision no. 200 / 12.11.1990, by the
Chimcomplex was included in the National Site detachment and full takeover of the patrimony
Contaminated Inventory in 2019. The site is afferent to the Borzeşti Chemical Plants,
contaminated with organic and inorganic compounds. within the Borzeşti Petrochemical.
According to the NEPA Letter no.1/2480/15.06.2020,
the source of contamination was the hazardous waste
storage. A soil and groundwater investigations
reported in the Site Reference Report, underlying the
issuance of the Integrated Environmental Permit
(2012), showed that the groundwater is contaminated
with HCH (α-HCH, β-HCH, γ-HCH), and that HCH
concentration in the soil is below the alert threshold for
less sensitive (industrial) use.

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Assigned Location Use label Current address Short description Environmental History Current use Aerial overview
site code code setting
RO-BC-01 RO-BC- Waste Industriilor no. 3 This waste deposit is a satellite site of RO-BC-01-01. Natural terrain The inactive part resulting from the Lindane None
01-02 deposit Vâlcea County The waste resulting from the Lindane production of the production of the Oltchim was disposed of as
Oltchim was disposed on this deposit. There is no waste on this deposit.
available information about location of the deposit. According to satellite images, this deposit
From the google maps photos it is assumed that this seems rehabilitated and covered with a vegetal
deposit was situated in the northern part outside the layer.
Chimcomplex site. Also, according to satellite images,
this deposit seems rehabilitated and covered with
vegetation. The site is contaminated with organic and
inorganic compounds. According to the NEPA Letter
no.1/2480/15.06.2020, the source of contamination
was hazardous waste storage. According to the
Integrated Environmental Permit no.1/10.01.2013
revised in 28.08.2015 for Chimcomplex Borzești
issued by Bacau EPA all the former hazardous waste
deposits have been closed since 2012. Post-closure
monitoring of soil and groundwater quality around
deposits must be carried out for a period of 30 years
according to national legislation (GD 349/2005). The
results of the monitoring carried out so far have not
been available for consultation. The waste deposit
was included in the National Site Contaminated
Inventory in 2019 (Code: RO1AMOBC 00108)
RO-CT-01 RO-CT- Storage Cogealac This storage facility was used to store HCH-based There is not enough No information is available on the site history The owner of the land There is not enough information to locate this facility.
01-01 facilities Commune, pesticides. These pesticides were used in agriculture information to locate is Constanta Council.
Constanta County, to protect plants. No information is available about site this facility.
on Mare Street and quantity of chemical waste stored.
RO-CT-01 RO-CT- Storage Plantelor Street, This storage facility was used to store HCH-based There is not enough No information is available on the site history The owner of the land There is not enough information to locate this facility
01-02 facilities Remus Opreanu pesticides. These pesticides were used in agriculture information to locate is Constanta Council.
Village, Constanta to protect plants. No information is available about site this facility.
County and quantity of chemical waste stored.
RO-CT-01 RO-CT- Storage Caseriei Street no This storage facility was used to store HCH-based Urban No information is available on the site history The owner of the land
01-03 facilities 1, Harsova City, pesticides. These pesticides were used in agriculture is Constanta Council.
Constanta County to protect plants. No information is available about site
and quantity of chemical waste stored. The site was
included in the National Site Contaminated Inventory
in 2019 The soil is potentially contaminated with HCH-
based pesticides

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Assigned Location Use label Current address Short description Environmental History Current use Aerial overview
site code code setting
RO-CT-01 RO-CT- Storage Sos. Tulcei, km 2, This storage facility was used to store HCH-based There is not enough No are available information about site history The owner of the land There is not enough information to locate this facility.
01-04 facilities Constanta City, pesticides. These pesticides were used in agriculture information to locate is Constanta Council.
Constanta County to protect plants. No information is available about the this facility.
chemical quantity stored. The site was included in the
National Site Contaminated Inventory in 2019 The soil
is potentially contaminated with HCH-based pesticides

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Figure 3.1 is a country map with the locations of the identified sites that are potentially impacted
by HCH and Lindane in Romania.

Figure 3.1 Map of Romania (Country Code RO) from the GIM with the sites that are potentially impacted by HCH and

Based on the available data it is concluded that there are sites that are potentially impacted by
HCH and Lindane in Romania. Table 3.1 contains an overview of the sites found. A review of the
sites in Romania based on the seven use types, used in this HCH in EU project, is given below.

3.1.2 Production sites


Three production sites have been identified in Romania.

RO-TU-01-01 - Turda Chemical Plants. The site is situated in Turda City, Cluj County, on the
right bank of Arieș River. The site is known as the Turda Industrial Platform. Previous on the site
was Chemical Plants of Turda. Between 1911 and 1948, the Solvay Soda Factory (Solvay Plant
Group) operated on the site. This company was nationalized and transformed in June 1948 into
the Turda Chemical Plants. In 1954, Turda Chemical Plants began to produce HCH (1,2,3,4,5,6 -
the Gamma isomer, known as Lindane or Hexachloran). The production of Hexachlorane is
achieved by chemical chlorination of benzene followed by a purification step to enrich the active
gamma isomer and to remove the inactive part, which was disposed of as waste, with no
possibility of recovery. These wastes have been deposited over the years on various lands around
Turda City and in the vicinity (7 waste deposits have been officially inventoried). It is estimated
that approximately 60,000 tons of waste from Lindane production were stored on various lands
around Turda. The production of HCH stopped in 1983. Turda Chemical Plants were included in
the recent National contaminated Sites Inventory (2019) prepared by the NEPA with
8 contaminated sites with HCH.
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The official sites code from national inventory are: RO6APMCJ00037, RO06AMPCJ0029,
RO6APMCJ00025. Outside of Turda Chemical Plants there are five other contaminated areas
(former waste deposits). The official sites cod from national inventory are: RO6APMCJ00020),
RO6APMCJ00021, RO6APMMCJ00023, RO6APMCJ00024 RO6APMCJ00028. Due to the
location of the site, near Aries River and near residential areas, the site represents a risk to human
health and the aquatic ecosystem.

RO-VL-01-01 - Oltchim site. The site is situated on Uzinei Street, No.1, Râmnicu Vâlcea City,
Vâlcea County, at 10 km on the national road DN 64 (Râmnicu Vâlcea - Dragasani), on the right
bank of Olt River. Oltchim Râmnicu Vâlcea was founded in 1966 under the name of Ramnicu
Vâlcea Chemical Plant. The HCH-Lindane plant was built between 1967-1968 and was put into
operation in 1969. The production capacity of the plant was 800 tons / year. The HCH-Lindane
section produced Lindane (γ-HCH) which was marketed, and the rest of the isomers resulting from
the manufacturing process were stored in the hazardous waste deposit, located in the southern
part of the Oltchim site. The production of HCH stopped in 1983. The site was included in the
recent National Contaminated Sites Inventory (2019) prepared by the NEPA (the official sites code
from national inventory is APMVL00023). Olthim was included in the recent National
Contaminated Sites Inventory (2019) prepared by the NEPA for the former HCH Installation site,
the former pesticide unit I-II and the hazardous waste deposit area. The official codes are:
APMVL00022 - pesticide unit I-II; APMVL00023 - HCH Installation, APMVL00001 - hazardous
waste deposit). Due to the location of the site, near Olt River, protected area and near residential
areas, the site could present a potential risk to human health and the aquatic ecosystem

RO-BC-01-01 - Chimcomplex Borzesti site. The site is situated on the right bank of the river
Trotuş, about 8 km downstream of Oneşti Cityu, Bacau County. Chimcomplex was founded under
Government Decision no. 200 / 12.11.1990, by the detachment and full takeover of the patrimony
afferent to the Borzeşti Chemical Plants, within the Borzeşti Petrochemical Plant. Borzesti
Chemical Plants was founded in 1954. In 1960 the facility put into operation installations for the
manufacture of Hexachlorane (Lindane). There is no information available on the period in which
Lindane was produced. Chimcomplex was included in the National Site Contaminated Inventory in
2019 (Code: RO1AMOBC 00108) for the waste deposit. The site is contaminated with organic and
inorganic compounds. Due to the location of the site, near Trotus Ricer, protected area and near
residential areas, the site could present a potential risk to human health and aquatic ecosystem.

3.1.3 Processing sites


One processing sites have been identified in Romania.

RO-VL-01-03 associated with the activity of Oltchim. Oltchim produced Lindane between 1969-
1998. Between 1998, following economic analyses, measures were taken to close the HCH-Lindane
plant and the pesticide unit. The area of the former Pesticide Unit I-II, located in the north part of the
Oltchim site.
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The site was included in the recent National Contaminated Sites Inventory (2019) prepared by the
NEPA (the official code from national inventory: APMVL00001). Due to the location of the site, near
Olt River, protected area and near residential areas, the site could present a potential risk to human
health and the aquatic ecosystem

3.1.4 Waste deposits


Nine waste deposits have been identified in Romania.

5 waste deposits (RO-TU-01-02, RO-TU-01-03, RO-TU-01-04, RO-TU-01-05, RO-TU-01-06)


identified as associated with Lindane production activity on Turda Chemical Plants
(RO-TU-01-01). The waste from Turda Chemical Plants has been deposited over the years on
various lands on the Turda Chemical Plant site or in its vicinity. Due to the location of those sites,
in the vicinity of Aries River and in the vicinity of the residential areas, the sites could present a
risk to human health and the aquatic ecosystem.

1 waste deposit (RO-VL-01-02) identified as associated with Lindane production activity on Oltchim
site (RO-VL-01-01). Due to the location of the site, in the vicinity of the Olt River, of the natural
protected area and of residential areas, the site represents a risk to human health and the aquatic
ecosystem.

1 waste deposit (RO-BC-01-02) as associated with Lindane production activity in Chimcomplex


HCH installation. The site is situated on right bank of Trotuș River.

All these waste deposits were included in the recent National Contaminated Sites Inventory (2019)
prepared by the NEPA. Due to the location of the site, on the rivers bank, near protected area and
near residential areas, the sites could present a potential risk to human health and the aquatic
ecosystem

3.1.5 Landfills
No landfills have been identified in Romania.

3.1.6 Treatment centres


No treatment centres have been identified in Romania.

3.1.7 Storage facilities


The following four storage facilities have been identified in the Constanta County (RO-CT-01-01,
RO-CT-01-02, RO-CT-01-03, RO-CT-01-04). Pesticides (containing HCH) used for plant
protection in agricultural activities were stored on those facilities. All those sites were included in
the recent National Contaminated Sites Inventory (2019) prepared by the NEPA.

3.1.8 Other sites


No other sites that are potentially impacted by HCH have been identified in Romania.
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3.2 Disclaimer
The above list of sites that are potentially impacted by HCH and Lindane is based on the sources
mentioned in appendix 2. The consortium does not claim that the mentioned list is complete. Sites
on the above list have a high suspicion of having been involved with HCH storage, handling, or
processing in the past. The level to which the mentioned sites are posing human health risks, risks
for the ecology and or risks of spreading HCH / Lindane in the environment have not been
established in this phase of the project.

3.3 Uncertainties in the inventory


The current inventory is based on available data provided by the different administrations. With the
information available, there are sites such as RO-CT-01-01, RO-CT-01-02 or RO-CT-01-04 whose
location cannot be determined.

There is also no information about the storage capacity of the aforementioned sites, nor from site
RO-BC-01-01, which prevents an adequate risk assessment.

Finally, an adequate correlation cannot be made between waste from production or processing
sites and waste deposits and storage facilities, so there is the possibility that there are other sites
where HCH waste may be found.

4 Conclusions and recommendations


The inventory demonstrates that Romania has 15 sites (three production, one processing site,
seven waste deposits and four storage facilities) where HCH was handled. The situation caused
by HCH contamination is very different at the sites investigated, both due to the volume affected,
the dispersion of the contaminants and the degree of remediation achieved:
• At the RO-TU-01-01 site, there are seven companies developing their activity, which
represent an added problem for decision-making regarding the remediation of the site. It is
necessary to carry out an important work of coordination and awareness to analyze the
situation of the site.
• On other occasions, such as RO-TU-01-05 and RO-BC-01-02-, the results of the tests carried
out are not available, and in general, the analyzes have been carried out with little depth.
Greater depth can help provide more accurate information on the location of the waste.
• The National Registry Inventory is not public in nature, which may represent an obstacle for
the expansion of research work from other sites

A greater concretion of the situation of each of the sites contemplated is required, so that a more
precise assessment of them can be made with a view to proposing and implementing solutions.
Said concretion could be achieved through greater technical collaboration with the different
authorities, either online or in situ, which would allow an objective knowledge of the different
situations to be achieved.
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Appendix 1 Inventory Approach

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The 10 steps of the EU-wide inventory, Task 1, the Inventory of the HCH
contaminated sites in EU member states

Step 1.1 - Initial check on available international data


The first step was an updated list of countries in the European Union that have sites that are
potentially impacted by HCH and Lindane. From earlier reports it is concluded, that Lindane and
technical HCH was produced in at least the following 12 member states: Austria; Croatia; Czech
Republic; France; Germany; Hungary; Italy; Netherlands; Poland; Romania; Slovakia and Spain.

For this step, the Union Implementation plan (UIP) for the Stockholm Convention (SC) including
the comments on this UIP provided by John Vijgen, consult from the International HCH and
Pesticides Association (IHPA) and Dr Roland Weber were reviewed. After this, all available
National Implementation Plans (NIPs) for the SC of all 27 member states were reviewed on this
issue.

In addition to the information documented in the scope of the obligation from the SC, the following
information resources were consulted to verify the list of EU countries with HCH contaminated
sites:
• Databases of companies involved in waste collection/ treatment
• Databases of companies taking care of contaminated sites, hazardous waste shipment
• National databases with information on environmental enforcement, notifications of illegal
activities or incidents, and soil or water measurements by environmental authorities
• Databases on (obsolete) chemical industries specific production of agrochemicals

Available surface and groundwater monitoring data was also used to verify whether HCH is
detectable outside the catchment areas of known sites. If elevated levels of HCH were detected in
surface and groundwater outside catchment areas with known sites, then these areas were
investigated in more detail. The goal of a more detailed investigation is to determine the origin of
the detected HCH and identify sites that are potentially impacted by HCH and Lindane but that
were previously unknown.

The initial review concluded that there are HCH/Lindane contaminated sites in Romania.

The background data on this step is available in report R003-1272383BAG-V02-los-NL Step 1.1
Final List of Countries with HCH impacted sites (July 22, 2020).

Step 1.2 - Initial Country Inventory of HCH/Lindane sites


For Step 1.2, a desktop study is carried out for Romania to identify potential HCH impacted sites.
The European Union Implementation Plan of the Stockholm Convention from 2007 provides a
rough estimate of the volume produced in the EU region between 1950 and 2000 but not the
specific site location information necessary for the site list.
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In Romania, the main instrument for the implementation of the Convention provisions is the
National Implementation Plan (NIP) elaborated in accordance with the provisions of art. 7 of the
Convention. The first version of the NIP was transmitted to the Secretariat of the Convention in
April 2006 and adopted at national level by Government Decision no. 1497/2008. The NIP
establishes the action plans, measures and related costs necessary for the implementation of the
provisions of the Convention. The NIP was modified in 2013, the modified version was approved
by GD 1021/2013.

The Ministry of Environment, Water and Forests is the authority responsible for implementing any
amendments to the Convention and takes the necessary measures to update the National Plan for
the implementation of the Convention provisions.

Every 4 years, the National Agency for Environmental Protection prepare the report on the state of
implementation of the provisions of the Convention and sends it to the Ministry of Environment,
Water and Forests for approval. The Ministry, through the designated National Focal Point,
forwards the report to the Secretariat of the Stockholm Convention.
The Stockholm Convention National Implementation Plan of Romania is not providing the
information in relation to presence of potential HCH impacted sites, also lacks specific site
information on potential HCH impacted sites.
The Stockholm Convention National Implementation Plan of Romania mentioned only a specific
objective related to stopping the production and use of POPs (from Appendix A of Stockholm
Convention).

To compile a comprehensive country specific list of potential HCH impacted sites, the desktop
study has drawn on various sources of information. This includes publicly available literature and
contacting relevant authorities.
The Consortium has attempted to contact former in country HCH producers, chemical waste
management companies and pesticide formulators. Historical records, books etc. on chemical
production in states have been reviewed to trace potential producers.

Thirdly, HCH and chemical waste shipment data have been collected from public sources to
assess the cross-border movement of HCH.

The following reports and sources have been assessed to identify sources of HCH and Lindane at
locations with increased concentrations of HCH-isomers in the surface water:
• Fresenius Environmental Bulletins (FEB), Volume 14 - No 6 -2005, page 444-462, Persistent
Chlorinated Hydrocarbons (PCHC), source-oriented monitoring in aquatic media 3
• Isomers of hexachlorocyclohexane, Emanuel Heinisch - Antonius Kettrup- Werner Bergheim-
Dieter Martens- Sabine Wenzell, and FEB Volume 18 - No 8 -2009 pp 1396 - 1406
• FEB, Persistent Chlorinated Hydrocarbons (PCHCS), source-oriented monitoring in aquatic
media 7
• European Pollutant Release and Transfer Register (E-PRTR) https://prtr.eea.europa.eu/
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• EEA (2018). Chemicals in European Waters

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• EEA (2018). European Water Assessment of Status and Pressures


https://water.europa.eu/freshwater/data-and-topics
• The Land Use and Coverage Area frame Survey (LUCAS) data
• https://www.eea.europa.eu/themes/water/european-waters/water-quality-and-water-
assessment/water-assessments/chemical-status-of-surface-water-bodies

The specific approach to identify potential HCH impacted sites in Romania was:
• Review of the National Implementation Plan of the Stockholm Convention
• Review of publicly available resources including but not limited to:
- Review of pesticide producers between 1945 and 2006 when HCH was banned in
Romania
- Review of pesticides marketed between 1945 and 2006 when HCH was banned in
Romania

In addition, specifically to Romania the following sources have been consulted:


• National Contaminated Sites Inventory, 2019 - resume provided by National Environmental
Protection Agency (NEPA)
• Annual National Environmental Report 2010-2018 (2018 is the last year with available data),
prepared by National Environmental Protection Agency, http://www.anpm.ro/raport-de-mediu
• List of the economic operators authorized to produce and to put on market chemicals with
HCH - National Phytosanitary Authority
• National Implementation Plan of conventional provisions on persistent organic pollutants,
adopted in Stockholm on 22 May 2001 - version 2008 approved by Governmental Decision
no.1497/2008 with all amendments
• Annual County Environmental Report 2010-2018, prepared by Local Environmental Protection
Agency
• National Water Management Plan 2016-2020 prepared by National Water Authority -
https://www.rowater.ro
• National Strategy for the Rehabilitation of Historically Contaminated Sites approved by GD
683/2015

Appendix 2 contains an overview of all sources consulted. In Appendix 3 all documents used for
this country specific inventory of potential HCH impacted sites are listed.

Step 1.3 - Informing relevant stakeholders of the identified sites and requesting their input
In this case, communication with the different stakeholders involved has been very complicated, in
a first approach, we only received feedback indicating that it was due to the situation created by
Covid 19, they were not available.
As a result of the subcontracting of a local company, we managed to obtain information from the
following stakeholders.
• National Environmental Protection Agency (NEPA)
• Vâlcea Local Environmental Protection Agency (Vâlcea LEPA)
Final

• Cluj Local Environmental Protection Agency (Cluj LEPA)

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• Constanta Local Environmental Protection Agency (Constanta LEPA)


• Bacau Local Environmental Protection Agency (Bacau LEPA)
• Mihael Claudia Pan (former Stockholm convention local point)

Step 1.4 - Updating the inventory with input from external stakeholders
All input from stakeholders, approached during step 1.3 of the project has been gathered and
processed into the Country Specific Reports.

Step 1.5 - Further investigation into identified sites


For selected sites historical aerial photographs/satellite images taken of the direct vicinity of the
HCH and Lindane contaminated site during production and distribution period have been
purchased and analysed. The images have been interpreted to identify:
• The extent of the production facility
• Dumping activities in the direct surrounding of the waste deposit
• Signs of landfilling HCH waste at the landfill
• Sign of outdoor storage of HCH waste in treatment centre
• Signs of spills around storage facility
All images have been studied to identify signs of potential contamination of soil, groundwater, and
waterbodies. The outcomes of the aerial photograph review are included in the site
characterisation appendix.

Step 1.6 - Outreach to national and international stakeholders on identified sites


During this step, the updated Country Inventory report has been shared with the relevant
stakeholders identified during Step 1.3. In addition, access to the GIM has been provided for
external parties. For Romania, the following stakeholders have responded:
• National Environmental Protection Agency (NEPA)
• Vâlcea Local Environmental Protection Agency (Vâlcea LEPA)
• Cluj Local Environmental Protection Agency (Cluj LEPA)
• Constanta Local Environmental Protection Agency (Constanta LEPA)
• Bacau Local Environmental Protection Agency (Bacau LEPA)

The following relevant information was gathered from the [Name of Organisation that has
responded]:
• National Environmental Protection Agency (NEPA)
• Vâlcea Local Environmental Protection Agency (Vâlcea LEPA)
• Cluj Local Environmental Protection Agency (Cluj LEPA)
• Constanta Local Environmental Protection Agency (Constanta LEPA)
• Bacau Local Environmental Protection Agency (Bacau LEPA)

This information has been included in the Final List of sites in Romania.
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Step 1.7 - Public actions (workshops, webinars, meeting) to involve main stakeholders
All relevant data has been made public and shared through the following means:
• Public webinar - organized on the 26th of November and 1st of December 2020 with the topic:
Webinar HCH in EU
• Phone calls through the local subcontracted companyZoom meetings on [date of meeting]
with the following stakeholders attending:
• Project video shared via:
- Mail
- Linkedin
- Social networks

Through this outreach the following additional information came to light:


• Chimicomplex S.A. Borzesti
• Waste deposit Chimicomplex S.A. Borzesti
• Plaforme Turda

Step 1.8 - Further characterisation of main sites


The Sites in the EU-member states will differ in the degree of management. For the identified sites
in Romania the following actions will be executed to further characterize the sites.

Table A1.4.1 Additional actions


Site code Site name Use label Reference Additional actions
RU-CT-01-03 Storage facilities Section 3.1.1 None
RU-BC-01-01 Chimcomplex Production site Appendix 5 Larger site summary (2 days)
SA Borzesti Aerial photographs (2 days)
Site visit (3 days)
CSM and Tier 1 (3 days)
RU-BC-01-02 Waste deposit Waste deposit Section 3.1.1 None
Chimcomplex
RU-VL-01-01 Chimcomplex Production site Appendix 5 Larger site summary (2 days)
SA Borzesti - Aerial photographs (2 days)
Sucursala Site visit (3 days)
Ramnicu Valcea CSM and Tier 1 (3 days)
RU-VL-01-02 Waste deposit Waste deposit Section 3.1.1 None
Oltchim
RU-VL-01-03 Processing site Processing site Section 3.1.1 None
chimcomplex RV
RU-TU-01-05 Waste deposit Waste deposit Section 3.1.1 None
Turda 05
RU-TU-01-03 Waste deposit Waste deposit Section 3.1.1 None
Turda 03
RU-TU-01-04 Waste deposit Waste deposit Section 3.1.1 None
Final

Turda 04

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Site code Site name Use label Reference Additional actions


RU-TU-01-02 Waste deposit Waste deposit Section 3.1.1 None
Turda 02
RO-TU-01-01 Industrial Production site Appendix 5 Larger site summary (2 days)
Platforme Turda Aerial photographs (2 days)
Site visit (3 days)
Larger site summary (2 days)
CSM and Tier 1 (3 days)

The outputs of the site characterization of the three priority sites (RU-BC-01-01, RU-VL-01-01 and
RO-TU-01-01) are included in Appendix 5 of this report.

Step 1.9 - Classification of Sites according to their environmental management levels


With the information provided in the ICSM and the results of the Tier 1 Risk Assessment in the
GIM a site can be classified. The proposed method to classify is explained in the article “From
uncontrolled to controlled final sink 1“ The objectives to classify the contaminated sites is to direct
the site responsible entity to the hurdles that obstruct the implementation of risk reduction
measures. This will allow for efficient use of the limited recourses and avoid that the site enters the
infinitive site assessment circle (modified from Harmsen et al, 2009).
The site classification will assess for each site the:
• Risk control
• Availability of funds
• Awareness profile
• Availability of technique

Based on this the sites will be categorized in one of five classes:


• Completely controlled - level 4 class of control
• Controlled - level 3 of control
• Semi controlled - level 2 of control
• Minimum controlled - level 1 of control
• Uncontrolled - level 0 of control

To help entities starting the sustainable management of HCH - Lindane contaminated sites, the
main hurdles that obstruct the implementation of risk reduction measures for the sites will be
highlighted. In table 4.1 the classification of sites in Romania is included. In appendix 5 the
detailed classification itself is reported.
Final

1
From uncontrolled to controlled final sink. M. Langevoort, I.J.C. Rijk, B.F.H. Fokke, M. van der Wijk

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Step 1.10 - Final list of HCH and Lindane contaminated sites in Europe
This final step concerns the current report. This report will contain, in addition to the detailed
inventory of the sites, an overview of the situation in and actions of Romania and suggestions for
Romania to review and improve their NIPs with respect to HCH and Lindane contaminated sites.

Final

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Appendix 2 Source Overview

Final

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Table A2.1 Contacted sources for Romania


Organization Website Address Date
contacted
National Phytosanitary Authority https://www.anfdf.ro/ Blvd.Voluntari 11, VOLUNTARI 25.05.2020
Town, ILFOV County,
National Environmental http://www.anpm.ro/ Splaiul Independenței, no. 294, Bild 25.05.2030
Protection Agency (NEPA) B, Bucharest, District 6
email: office@anpm.ro
Vâlcea Local Environmental http://apmvl.anpm.ro/ Petru Rareș Street, nr. 1, Ramnicu 23.06.2020
Protection Agency (Vâlcea Valcea City, Valcea Town
LEPA) email: office@apmdj.anpm.ro
Cluj Local Environmental http://apmcj.anpm.ro/ Calea Dorobanților, no 99, Cluj- 23.06.2020
Protection Agency (Cluj LEPA) Napoca Town, Cluj County
office@apmcj.anpm.ro
Constanta Local Environmental http://apmct.anpm.ro/ Unirii Street, no 23, Constanța City, 23.06.2020
Protection Agency (Constanta Constanta County
LEPA) email: office@apmct.anpm.ro
Bacau Local Environmental http://apmbc.anpm.ro/ro Oituz Street, no 23, Bacau Town, 23.06.2020
Protection Agency (Bacau Bacau County
LEPA) email: office@apmbc.anpm.ro

Final

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Appendix 3 Document Overview

Final

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Table A3.1 Overview of sources used for Romania


Document Title Publicat Author Source Releva
Type ion date nt
pages
National National Strategy for 2015 Ministry of the Official Monitor
Strategy the Rehabilitation of Environment
Historically
Contaminated Sites
Research Study Research and 2010 National Research https://www.incdecoi
Development of and Development nd.ro/
methods for the Institute for Industrial
removal of persistent Ecology (ECOIND)
organic pollutants -
Insolvency Report on the causes 2012 Oltchim http://www.oltchim.ro
Report that generated the /uploaded/2016/Plan
state of Insolvency ul%20de%20reorga
nizare%20al%20Oltc
him%20SA.pdf
Environmental Site Reference Report 2012 Oltchim http://apmdj-
Documentation for Integrated old.anpm.ro/upload/
Environmental Permit - 62369_RAPORT%2
Oltchim Site 0DE%20AMPLASA
MENT%202012_SC
%20Oltchim%20SA.
pdf
Annual Report Environmental Report 2019 Chimcomplex https://www.chimco 12-27
for Oltchim Borzești - mplex.ro/
RamniculVâlcea
Branch
Environmental Integrated 2015 Bacau Local https.apmvl.anpm.ro 47-48
Permit Environmental Permit Environmental 66-67
no 1/10.01.2013 Protection Agency 74-77
revised on 28.08.2015
Notification Notification issued by 2008 Ministry of Chamber of
the Ministry of Environment Deputies
Environment http://www.cdep.ro
no.10439/LAV/
Notification Notification issued by 2013 Ministry of Senate,
the Ministry of Environment http://www.senat.ro
Environment
no.952/RP/28.03.2013
Research study Study on Soil Quality 2011 PRODAN Calin ww.proenvironment.r 259 -
Final

Status in Area of the Vasile et al. - o 263

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Document Title Publicat Author Source Releva


Type ion date nt
pages
Former Chemical Plant Technical University,
from Turda and Faculty of Materials
Remediation Proposal Science and
Engineering
Research study Remediation Measures 2010 SIMULE Codruta ww.proenvironment.r
for Posta Rat-Turda Violeta, M. DOBRIN, o
Contaminated Site Universitatea Babeş-
Bolyai, Faculty of
Biology and Geology
Research study Soil quality research 2012 Vasile C. Prodan, Ecoterra Journal of www.e
around the chemical Valer Micle, Environmental coterra
landfill Posta Rat - Georgiana Research and -
Turda Plopeanu, Maria Protection, 2012, online.r
Szanto (Prodan) - no.21 o
Technical University,
Faculty of Materials
and Environmental
Engineering, Cluj-
Napoca, Romania; 2
National Research-
Development
Institute for
Pedology,
Agrochemistry and
Environmental
Protection - ICPA
Bucharest
Annual Report Annual Environmental 2010 LEPA Cluj County http://apmcj- chapter
Report for Cluj County old.anpm.ro/upload/ IV -
37628_04- Land
Utilizrea%20terenuril use
or%202010.pdf
Environmental Integrated 2010 LEPA Cluj County http: apmcj.anpm.ro
Permit Environmental Permit -
Landfill for temporary
storage of hazardous
waste, Moldovenești
Commune, Cluj County
Final

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Document Title Publicat Author Source Releva


Type ion date nt
pages
Implementation IMPLEMENTATION 2004 Mures Water Basin http://www.rowater.r 28
Plan PLAN - for DIRECTIVE Administration o/Documente%20Re
NO.76 / 464 / EEC pository/Directive%2
and the “subsequent 0substante%20peric
directives” on pollution uloase/ANEXAP1.P
caused by certain DF
hazardous substances
discharged into the
aquatic environment of
the Community

Final

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Appendix 4 Country Gross List

Final

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Table A4.1 Gross list for Romania


Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
Industrial Turda 22 December 46°33'24.34"N Production In 1954, they started producing 1954-1983 The HCH Letter no.
Platform Chemical 1998, nr.12C, 23°46'50.14"E site HCH (1,2,3,4,5,6 - the Gamma (manufactured Installation was 1/2840/VT/15.06.2020
Turda Plants of Turda City, Cluj isomer, known as Lindane or Lindane) closed and issued by National
(UCT) County Hexachlorane). The remove from the Environmental Protection
Hexachlorane production is site Agency from Romania
achieved by chemical The site is
chlorination of benzene followed contaminated
by a purification step to enrich with HCH, and it
the active Gamma isomer and was included in
to remove the inactive part, the recent
which was, without containment, National
disposed. The production of Contaminated
Lindane is achieved by Sites Inventory
chemical chlorination of (2019) prepared
benzene followed by a by the NEPA.
purification step to enrich the On the site
active gamma isomer and to there are three
remove the inactive part, which areas
was disposed of as waste, with contaminated
no possibility of recovery. These with HCH. Main
wastes have been deposited source of

Final
over the years on various lands contamination is
around Turda City, on the Truda HCH installation

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
Chemical Plant site or in their and waste
vicinity. deposit.
In 1998, UCT definitively
ceased its activity and entered
the legal liquidation procedure
through bankruptcy, In October
1999, the assets of UCT were
transferred by AVAS to several
legal entities without
establishing or transferring
environmental obligations upon
cessation of the activity of
production and sale of assets. It
is known that some of the
assets were taken over by SC
Nuha Traiding SRL, SC
Sadachit Procom SA, SC
Reicon Consulting SRL, but the
current situation is not fully
clarified due to repeated sales
or winding-up procedures. It is
known that in the period 2001-

Final
2002 UCTs were demolished.

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
Aries Waste Turda 46°33'28.77"N Waste The inactive part resulting from 1954-1983 The site is Letter no.
Deposit Chemical 23°46'39.01"E deposit the Lindane production of the Considering contaminated 1/2840/VT/15.06.2020
Plants Turda plant was disposed of as the period of with HCH, and it issued by National
(UCT) waste on this landfill.. Lindane was National Environmental Protection
The waste deposit is situated on manufacturing Contaminated Agency from Romania
the right side of the river Aries in Turda Sites Inventory
(built-up area) between the limit Chemical (2019) prepared
of the enclosure of the Chemical Plants by the NEPA
Plant and the dam on the right
side of the river, with a surface
of 0,4ha. Former owner - UCT
Turda. The current owner of this
land is Turda Municipality
Not available
Constructorul Turda waste The inactive part resulting from 1954-1983 The site is Letter no.
SCCA Cluj- Chemical deposit the Turda Chemical Plant during Considering contaminated 1/2840/VT/15.06.2020
Napoca Plants the Lindane Production Activity the period of with HCH, and it issued by National
Deposit (UCT) was disposed of as waste on Lindane was National Environmental Protection
this deposit. manufacturing Contaminated Agency from Romania
Constructorul SCCA Cluj- in Turda Sites Inventory
Napoca Deposit, Turda Chemical (2019) prepared
enclosure section: situated in Plants by the NEPA
the vicinity of the Chemical (2019)

Final
Plant, in the enclosure of SC
Constructorul SA. The current

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
owner of this land is Ben SRL
Cluj Napoca.
Poșta Rât Turda Petru Maior 46°33'49.03"N waste The inactive part resulting from 1954-1983 The site is Letter no.
waste deposit Chemical Street, Turda 23°48'45.72"E deposit the Turda Chemical Plant during Considering contaminated 1/2840/VT/15.06.2020
Plants City, Cluj the Lindane Production Activity the period of with HCH, and it issued by National
(UCT) County was disposed of as waste on Lindane was included in Environmental Protection
this deposit. manufacturing the recent Agency from Romania
The current owner of this site is in Turda contaminated
Turda Municipality. This site is Chemical site inventory
being remedied. The project is Plants (2019) prepared
financed by European Funds by the NEPA
through the POS Mediu and
POIM Programme.
DN1 towards Turda 46°33'27.79"N waste The inactive part resulting from Considering The site is Letter no.
23°45'39.84"E
Alba Iulia Chemical deposit the Lindane production of the the period of contaminated 1/2840/VT/15.06.2020
deposit Plants Turda plant was disposed of as Lindane with HCH, and it issued by National
(UCT) waste on this landfill. manufacturing was included in Environmental Protection
The site is situated at the exit of in Turda the recent Agency from Romania
Turda Municipality towards Alba Chemical contaminated
Iulia, at kilometre 447 on DN1, Plants (1954- site inventory
on the outskirts of Mihai 1983) (2019) prepared
Viteazul Commune. The current by the NEPA

Final
owner - is Mihai Viteazul
Municipality. Because this site is

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
the proximity of Transylvania
Highway, the site was partially
remediated (by Consortium SC
Euro construct Trading 98 SRL
Bucureşti and I&C Transylvania
Construcţii SRL Turda -
according to Environmental
Permit no. 117
NV6/18.10.2010).
46°33'56.98"N
Turda waste The site is situated on the right Considering The site is Letter no.
23°49'17.48"E
Chemical deposit bank of Arieș, close to the the period of contaminated 1/2840/VT/15.06.2020
Plants Turda Stadium. Lindane with HCH, and it issued by National
(UCT) The inactive part resulting from manufacturing was included in Environmental Protection
the Turda Chemical Plant during in Turda the recent Agency from Romania
the Lindane Production Activity Chemical contaminated
was disposed of as waste on Plants (1954- site inventory
this deposit. 1983) (2019) prepared
by the NEPA
45° 2'27.40"N
Chimcomplex Râmnicu Uzinei Street, Production Oltchim Râmnicu Vâlcea was 1969-1998 The HCH Letter no.
24°17'54.82"E
Borzești - Vâlcea No.1, Râmnicu site founded in 1966 under the Installation and 1/2840/VT/15.06.2020
Râmnicu Chemical Vâlcea City, name of Ramnicu Vâlcea pesticide units issued by National
Vâlcea Branch Plant (until Vâlcea County Chemical Plant. were closed and Environmental Protection

Final
(since 2019) 1990) The HCH-Lindane plant was removed from Agency from Romania
Oltchim site built between 1967-1968 and the site

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
Between was put into operation in 1969. On the site are
1990-2018 The production capacity of the two areas
Oltchim plant was 800 t / year. The contaminated
HCH-Lindane section produced with HCH.
Lindane (γ-HCH) which was Those areas are
marketed, and the rest of the included in the
isomers resulting from the recent National
manufacturing process were Contaminated
stored in the hazardous waste Sites Inventory
deposit, located in the southern (2019) prepared
part of the Oltchim site. by the NEPA.
On the site Lindane has also
been used in the manufacture of
suspensions (in the pesticide
Unit I-II).
In 1998, after an economic
assessment, measures were
taken to close the HCH-Lindane
installation and the pesticides
unit. The HCH installation and
the pesticides unit have been
removed. In 2013, instead of

Final
these installations, polyether
installations were built.

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
Currently, the site carries out
activities for the manufacture of
basic organic and inorganic
chemicals. The current owner of
the site is Chimcomplex
Borzești - Ramnicu Vâlcea
Branch.
Chimcomplex Râmnicu Uzinei Street, 45° 1'23.08"N Waste The Hazardous Waste Deposit 1979-2014 The deposit is Letter no.
Borzești - Vâlcea No.1, Râmnicu 24°17'55.64"E deposit (12 ha) is situated in the closed. 1/2840/VT/15.06.2020
Râmnicu Chemical Vâlcea City, southeast part of the Oltchim The site is issued by National
Vâlcea Branch Plant (until Vâlcea County site. The hazardous waste contaminated Environmental Protection
(since 2019) 1990) deposit was built between 1979 with HCH. Agency from Romania
Between and 1980 and consisted of four
1990-2018 storage cells. The main organic
Oltchim residues resulting from the HCH
production processes initially
stored: 250 t/ ear chlorinated
residues from the vinyl chloride
plant and 6150 t/ year inactive
isomers of HCH from the HCH -
Lindane Installation.
Chimcomplex Râmnicu Uzinei Street, 45° 3'0.51"N Processing On the Oltchim site, the Lindane 1969-1998 The pesticides Letter no.

Final
Borzești - Vâlcea No.1, Râmnicu 24°18'21.38"E site has also been used in the unit were closed 1/2840/VT/15.06.2020
Râmnicu Chemical manufacture of suspensions (in issued by National

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
Vâlcea Branch Plant (until Vâlcea City, the pesticide Unit I-II). The area and remove Environmental Protection
(since 2019) 1990) Vâlcea County of the former Pesticide Unit I-II from the site Agency from Romania
Between was in the north part of the
1990-2018 Oltchim site.
Oltchim The soil from the vicinity of the
former pesticide unit is the
contaminated with HCH,
The contaminated area has
0,05 ha. According to the NEPA
letter the owner of the land is
the Romanian State.
46°14'17.64"N
Chimcomplex Borzești Industriilor no. Production Borzesti Chemical Plants was No information The HCH Letter no.
26°50'47.93"E
Borzești - Chemical 3, Onești City, site founded in 1954. Chimcomplex available Installation was 1/2840/VT/15.06.2020
Borzești Plants Bacau County was founded under Government closed and issued by National
Branch Decision no. 200 /2.11.1990, by removed from Environmental Protection
the detachment and full the site. Agency from Romania
takeover of the patrimony The waste
afferent to the Borzeşti deposit was
Chemical Plants, within the closed.
Borzeşti Petrochemical Plant.
In 1960, the plant was put into
operation installations for the

Final
manufacture of li Chimcomplex
was included in the National

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
Site Contaminated Inventory in
2019 (Code:
RO1AMOBC00108) for the
waste deposit - the site is
contaminated with organic and
inorganic compounds.
According to the NEPA Letter
no.1/2480/15.06.2020, the
source of contamination was
hazardous waste storage
(containing chloride and
Hexachlorane). There is no
information available on the
period in which Lindane was
produced.
Cogealac no Mare Street. no available Storage The owner of the land is no available the site was Letter no.
Plants available Cogaleac information facilities Constanta Council. information included in the 1/2840/VT/15.06.2020
Protection information Commune, No are available information National Site issued by National
Centre Constanta about site history and the Contaminated Environmental Protection
County chemical quantity storage on Inventory in Agency from Romania
the site. 2019
There is not enough information The soil is

Final
to locate this facility potentially
contaminated

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
with HCH-based
pesticides
Medgidia no Plantelor Street, no available Storage The owner of the land is no available the site was
Plants available Remus information facilities Constanta Council. information included in the
Protection information Opreanu The facility was used to store National Site
Centre Village, HCH-based pesticides. Contaminated
Constanta Pesticides were used in Inventory in
County agriculture to protect plants 2019 The soil is
No are available information potentially
about site history and the contaminated
chemical quantity storage on with HCH-based
the site. pesticides
There is not enough information
to locate this facility
Harsova no Caseriei Street 44°41'31.23"N Storage The owner of the land is no available The site was Letter no.
Plants available no 1, Harsova 27°57'20.55"E facilities Constanta Council. information included in the 1/2840/VT/15.06.2020
Protection information City, Constanta The facility was used to store National Site issued by National
Centre County HCH-based pesticides. Contaminated Environmental Protection
Pesticides were used in Inventory in Agency from Romania
agriculture to protect plants 2019
No are available information The soil is
about site history potentially

Final
contaminated

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
with HCH-based
pesticides
Constanta no Sos. Tulcei, km no available The owner of the land is no available The site was Letter no.
Plants available 2, Constanta information Constanta Council. information included in the 1/2840/VT/15.06.2020
Protection information City, Constanta The facility was used to store National Site issued by National
Centre County. HCH-based pesticides. Contaminated Environmental Protection
Pesticides were used in Inventory in Agency from Romania
agriculture to protect plants 2019. The soil is
No are available information potentially
about site history and the contaminated
chemical quantity storage on with HCH-based
the site. pesticides
There is not enough information
to locate this facility
Alchimex SA Alexandru 44°28'3.65"N Production Alchimex was founded in 1998. no available no available Letter no. 5858
Constantinescu 26° 4'22.76"E site The facility was registered by information information /09.06.2020 issued by
no 63, sector 1, the National Phytosanitary National Phytosanitary
Bucharest Authority as a manufacture of Authority
plant protection products based
on hexachlorocyclohexanes
No are available information
about site history.

Final
Sintor SA Soseaua 47° 5'13.10"N Production The company was dissolved in no available no available Letter no.
Borșului, no.35, 21°52'49.36"E site 2010 information information 5858/09.06.2020 issued

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
Oradea City, The facility was registered by by National
Bihor County the National Phytosanitary Phytosanitary Authority
Authority as a manufacture of
plant protection products based
on hexachlorocyclohexanes.
No are available information
about site history.

Association Turda Moldovenești Treatment The highway route crosses 2010-2020 The land is Cluj Local Environmental
Euro construct Chemical Commune, Cluj Centre through this deposit. For the partial Protection Agency -
Trading 98 Plants County construction of the highway, it contaminated Integrated Environmental
Bucharest and (DN1 DN 1 section was necessary the partial with HCH. Authorization no. 117
I&C towards 2B, Km 10 + decontamination of the land. Source of NV6 of 18.10.2010
Transylvania Alba Iulia 500, Brasov- The treatment centre was set up contamination is issued by LEPA Cluj
Construcţii deposit) Cluj-Bors to treat the contaminated soil in waste deposit of
Turda Highway the area of the DN1 towards Turda Chemical
Alba Iulia deposit. The deposit Plant
was belonging to the Turda
Chemical Plants.
The main activities of the facility
were:
• Temporary storage of

Final
hazardous waste
containing HCH and other

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
hazardous materials (Hg,
other heavy metals, etc.),
discharged from the site
DN 1 section 2B, Km 10 +
500, Brasov-Cluj-Bors
Highway (Transylvania
Highway) according to
Environmental Agreement
no. 10- NV6 from
19.03.2010 issued by
ARPM Cluj-Napoca.
• Treatment of the entire
amount of waste
containing HCH and other
hazardous materials (Hg,
other heavy metals, etc.)
discharged from the site of
the DN1 site, from section
2B, Km 10 + 500,
temporarily stored for
recovery / disposal.
The facility activity was

Final
regulated by the Integrated
Environmental Authorization no.

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Current Site Former Address Coordinates Site type Description Years in Status on HCH References used
name site name X, Y operation
117 NV6 of 18.10.2010 issued
by APM Cluj.
Sinteza SA Calea Borșului 47° 5'13.10"N Processing Pesticides with HCH were no available no available IMPLEMENTATION
no.35, Oradea 21°52'49.36"E site produced on site. information information PLAN - for DIRECTIVE
City, Bihor Lindane supplied from Oltchim NO.76 / 464 / EEC
County was used in the process and the “subsequent
directives” on pollution
caused by certain
hazardous substances
discharged into the
aquatic environment of
the Community -
prepared by Mures
Water Basin
Administration

Final
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Appendix 5 Site Characterization

• A5.1: Site Turda Industrial Platform with the site location code RO-TU-01
• A5.2: Oltchim site with the site location code RO-VL-01
• A5.3: Chimcomplex Borzesti site with the site location code RO-BC-01

Final

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A5.1 Site Turda Industrial Platform - RO-TU-01

A5.1.1 Site details


Table A5.1.1 gives an overview of the site details.

Table A5.1.1 Site details


Issue
Site code parent site RO-TU-01 Cluster Yes
Current site name Turda Industrial Platform Site use label parent Production site
site
Former site name Turda Chemical Plants Site authority Cluj Local Environmental
(UCT) Protection Agency, Turda
Municipality
Country Romania Name of National Environmental
organisation Protection Agency (NEPA), Cluj
Environmental Protection Agency
(Cluj EPA)
Region or Province Cluj County Name of focal point Ioan Baceanu (NEPA - Soil
Departament Director)
City / Municipality Turda Office address Splaiul Independenței, no. 294,
Bild B, Bucharest, District 6
Site address 22 December 1998. Nr. 12C. Telephone
email office@anpm.ro
GPS coordinate N/S 46°33'24.34"N GPS coordinate E/W 23°46'50.14"E

A5.1.2 Site background


From a geological point of view, the city of Turda is in the Lower Aries Corridor. According to data
from the literature, this depression, corridor, highlights the following levels on the scale
geochronological: Upper Jurassic (limestone), Badenian (salt formations), Sarmatian (clays and
sands with intercalations of tuffs), Pannonian (carbonate and sandy clays) and Quaternary,
corresponding to different types of sedimentary deposits (sands, gravels, banks), but Tortonian
deposits (marly clays, sands, and tuffs) and cineritic levels also appear in some places.
According to the data from the literature, terraces that constitute the Aries River meadows have in
composition boulders, gravels, and coarse sands with a granulometry that allows the accumulation
of water in the groundwater layer 4 - 6 m.
UTC was located near the River Aries, on the right bank of the river. The hydrostatic level in the
meadow terrace of Aries is represented by a single water table, located at a depth of 1.50 - 2.,5 m,
fed from Aries, by direct infiltrations, upstream of Mihai Viteazu where the river intersects the
impermeable formations at the base. The land is flat, the land level being around 300 - 320 m.
Currently the site is known as the Turda Industrial Platform. The old name of the site was
Turda Chemical Plants (Uzinele Chimice Turda (UCT)). Between 1911 and 1948, the
Solvay Soda Factory (Solvay Plant Group) operated on the site. This company was nationalized
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In 1954, Turda Chemical Plants began to produce HCH (1,2,3,4,5,6 - the Gamma isomer, known
as Lindane or Hexachlorane). The production of Hexachlorane is achieved by chemical
chlorination of benzene followed by a purification step to enrich the active gamma isomer and to
remove the inactive part, which was disposed of as waste, with no possibility of recovery. These
wastes have been deposited over the years on various lands around Turda. It is estimated that
approximately 60,000 tons of waste from Lindane production were stored on various lands around
Turda. In addition to HCH in the early 1990s, the activity of Turda Chemical Plants focused on the
production of potassium carbonate, liquid chlorine, calcium chloride, calcium hypochlorite, copper
oxychloride, organic polymers, potassium iodide. The production of HCH stopped in 1983. On the
site there were two deposits for waste resulted from HCH production. There are No information
available about the deposits area and quantity of waste stored on the site.
Currently, the following companies are active on the site:
• SC Sadachit Procom SA - Basic an organic products platform - produce inorganic salts,
storage and bottling of liquid chlorine, sulfuric acid, other inorganic chemicals, filling, repair
(seamless), periodic technical inspection decommissioning and scrapping containers for liquid
chlorine (according to draft Environmental Permit available on the EPA Cluj website)
• Saint Gobain Weber Romania - Plaster production
• CDS Performance Chiptuning Cluj - Optimization of car engine software
• AIRBAG Turda - Car Service
• Rewa Turda - Shopping centre
• Doctor Service Car Wigs - Car Service,
• Modulo Decorative Solutions SRL - Manufacture of plaster products for construction
purpose (from 2004).
• SC A 3 LOGISTIC SRL - logistic park

The nearest houses are on the SE side of the site (houses located on Chimistilor Street and N.
Teclu Street) - about 25 m from the site. According to the information available on the website of
the Aries water company (CCA Aries), the inhabitants of Turda City are supplied with water from
the public water network. For the water supply groundwater is extracted from 8 to 13 meters deep.
According to the draft environmental permit Sadachit Procom SA (available on Cluj EPA website),
there are 2 groundwater quality monitoring wells on site. The water quality monitoring is performed
by Sadachit Procom SA annually. The monitored indicators are pH, CCOCr, Chlorides (Cl-), total
iron, fixed residue. The HCH is not monitored.
The site was included in the recent contaminated site inventory (2019) prepared by the NEPA.
On the site of Turda Chemical Plats there are 3 contaminated areas. The official site codes from
national inventory are: RO6APMCJ00037, RO06AMPCJ0029, RO6APMCJ00025. Outside of
Turda Chemical Plants there are 5 other contaminated areas (former waste deposits). The official
codes from national inventory for these 5 waste deposits are: RO6APMCJ00020,
RO6APMCJ00021, RO6APMMCJ00023, RO6APMCJ00024, RO6APMCJ00028.
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Figure A5.1.1 Map of site RO-TU-01


A5.1.3 Aerial photograph interpretation
For the Turda Industrial Platform, the aerial photographs mentioned in Table A5.1.2 have been
reviewed.

Table A5.1.2 Aerial photographs for site Turda Industrial Platform


Site code Site name Aerial Scale Years
photographs
TO-TU-01 Turda Industrial Platform Turda City 2013
Turda City 2018

Figure A5.1.2 Aerial photograph of Turda Industrial Platform, 2013


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Figure A5.1.3 Aerial photograph of Turda Industrial Platform, 2018

The aerial photograph of 2013 provides a general site view


The aerial photograph of 2018 the location of the UCT and waste deposits are indicated

A5.1.4 ICSM and Tier 1 risk assessment


For the Turda Industrial Platform an Initial Conceptual Site Model and Tier 1 risk assessment has
been made. The source zones identified at the Turda site are listed in Table A5.1.3 Table A5.1.4
gives the source receptor pathways and the receptors are presented in Table 5.1.5. The site risk
scores are presented Table 1.5 7. The total site risk score is 37 and the migration risk, spreading
in the environment (soil, groundwater, surface water and river sediment) is causing the risk for the
aquatic ecosystem which has the largest risk score. Figure A5.1.4 is an aerial photograph with the
source zones, the related pathways, and receptors.

Table A5.1.3 Sources for Turda Industrial Platform with the site code RO-TU-01
Source type Source ID Source description Source Volume (m3)
Contaminated soil 1 Topsoil Unknown
Contaminated groundwater 2 Shallow groundwater Unknown
Surface water 3 Water in River Unknown
Aquatic sediment 4 Sediment in River Unknown
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Table A5.1.4 Pathways for Turda Industrial Platform with the site code RO-TU-01
Pathway type Pathway Pathway description Pathway Source Receptor
ID status ID ID
Direct contact 1 Direct human contact with Only when 1 1
contaminated soil working
Wind 2 Indirect human contact contaminated Active 1 2
fine soil particles getting airborne
Wind 2 Direct contact ecosystem Active 1 7
contaminated fine soil particles
getting airborne
Leaching infiltrated 3 Leaching of contaminants in the soil Active 1 3
rainwater in the soil causing soil contamination
Leaching infiltrated 3 Leaching contaminants from the soil Active 1 4
rainwater leaching into the groundwater
groundwater causing groundwater contamination
Groundwater flow 4 The groundwater flow spreading the Active 2 3
contaminants causing a plume of
groundwater contamination
Groundwater flow 4 The groundwater flow spreading the Active 2 4
contaminants in surface water
Surface water flow 5 The surface water flow causing Active 3 4
spreading of contaminants in the
surface water of the river
Surface water flow 5 The surface water flow causing Active 3 5
spreading of contaminants in the
sediments of the river
Direct contact 6 Direct contact ecosystem Active 4 6
Sediment

Table A5.1.5 Receptors for the Turda Industrial Platform with the site code RO-TU-01
Receptor type Receptor ID Receptor description
Human 1 Site personal especially the groundworkers
Human 2 People living in the down wind settlements
Soil 3 Soil onsite
Groundwater 4 Groundwater downstream onsite
Groundwater 5 Groundwater downstream off site
Surface water 6 Down stream surface water in the river
Aquatic sediment 7 Down stream sediments in the river
The aquatic ecosystem 8 Ecosystem in river
Ecosystem land 9 Down wind areas ecosystem
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Figure A5.1.4 Map with Source - Pathway - Receptors

A5.1.5 Site classification


Table 5.1.6 gives the site classification according to the article “From uncontrolled to controlled
final sink“. The objectives to classify the contaminated sites is to direct the site responsible entity
to the hurdles that obstruct the implementation of risk reduction measures. The aspects reviewed
to classify the sustainable management status of the site are:
• The environmental risks present/controlled
• The availability of funds to manage the contaminated site in sustainable manner
• The awareness of the stakeholder
• The availability of technique to remediate the site

Table A5.1.6 Site classification Turda Industrial Platform with the site code RO-TU-01
Aspects Explanation Category
Risk controlled Direct risks are controlled Semi controlled
Funds available for site Funds available on the short term Semi controlled
management
Awareness stakeholders Receptors and local decision makers are aware of Semi controlled
risks
Techniques available All risk control measures are readily available and Completely
feasible controlled

The site is considered semi-controlled because only the direct risks are controlled, and the
potential risk related to wind and groundwater are not controlled. Funds to maintain the site are
only available for the short term. The site is on the national list of contaminated sites and the
surrounding population and local decision makers are aware of risks but accept the current
situation. The techniques to survey and remediate are available.
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A5.1.6 Conclusions
The main risk is the migration risk of the contaminants in the surrounding environment. According
to the classification the actions to come to complete controlled site, should focus on awareness
raising on a higher level so that funds are allocated to:

• Monitoring of the status of HCH contamination


• Carry out a site survey to complete the CSM
• Select and design appropriate remedial actions
• Implement these remedial actions

Furthermore, the time that has elapsed since the production of Lindane stopped (1983) and the
use of the land by different economic operators may constitute additional problems for carrying out
the site survey and the possible future remediation. Considering the proximity of the riverbed and
the city itself to the site where Lindane was produced, a survey to complete the CSM should be
undertaken to define the scope of the problem and, where appropriate, implement appropriate risk
reduction measures.

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Table A5.1.7 Contaminant risks for Turda Industrial Platform with the Location code RO-TU-01
Risk Risk description Risk Source Pathway Receptor Human Human Ecosystem Ecosystem Migration Migration
ID score ID ID ID Health health likelihood impact likelihood impact
likelihood impact
1-1-1 Direct contact with 6 1 1 1 2 3
contaminated soil by onsite
groundworkers
1-2-2 Indirect contact people 3 1 2 2 1 3
living down wind
1-3-3 Contaminant migration in 1 1 3 3 1 1
soil
1-7-2 Direct contact ecosystem 2 1 7 2 2 1
area down wind
1-3-4 Contaminant migration into 2 1 3 4 2 1
groundwater onsite
2-4-6 Contaminant migration in 3 2 4 6 3 1
groundwater off site
3-5-5 Migration downstream 1 3 5 5 1 1
surface water
3-5-7 Contaminant migration into 3 3 5 7 1 3
aquatic sediments
4-6-8 Direct contact with 16 4 6 8 4 4
Ecosystem in river

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A5.2 Oltchim site - RO-VL-01

A5.2.1 Site details


Table A5.2.1 gives an overview of the site details.

Table A5.2.1 Overview site details

Site code parent site RO-VL-01 Cluster Yes


Current site name Oltchim site Site use label parent Production site
site
Former site name Chemical Plant Ramnicu Site authority Valcea Local
Valcea (until 1990) and Environmental Protection
Oltchim (1990-2018) Agency
Country Romania Name of organisation National Environmental
Protection Agency (NEPA)
Valcea Local
Environmental Protection
Agency
Region or Province Vâlcea County Name of focal point Ioan Baceanu (NEPA - Soil
Departament Director)
City / Municipality Ramnicu Valcea Office address Splaiul Independenței, no.
294, Bild B, Bucharest,
District 6
Site address Uzinei Street, No.1, Telephone
Râmnicu Vâlcea City,
Email office@anpm.ro
GPS coordinate N/S 45° 2'27.40"N GPS coordinate E/W 24°17'54.82"E

A5.2.2 Site background


The geological conditions and soil characteristics are like those of the RO-TU-01 site (see A
5.1.2). Oltchim Râmnicu Vâlcea was founded in 1966 under the name of Ramnicu Vâlcea
Chemical Plant. Oltchim is situated in the south of Râmnicu Vâlcea, at 10 km from the national
road DN 64 (Râmnicu Vâlcea - Dragasani), on the right bank of the Olt River. In 2012, Oltchim
was privatized and became a joint stock company.
The HCH-Lindane plant was built between 1967 - 1968 and was put into operation in 1969. The
production capacity of the plant was 800 tons/year. The HCH-Lindane section produced Lindane
(γ-HCH) which was marketed, the rest of the isomers resulting from the manufacturing process
were stored as the hazardous waste a deposit called Cell no. 3, located in the southern part of the
site. Lindane has also been used to formulate pesticides.
The HCH installation was situated around the organic section between the V road (northeast), the
IV road (southeast) and the power station (South-West).
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The hazardous waste deposit was built between 1979 and 1980 and consisted of four storage
cells. The main organic residues resulting from the production processes were initially stored in
the following quantities: 250 tons/year chlorinated residues from the vinyl chloride plant and 6,150
tons/year inactive isomers of HCH from the HCH - Lindane plant. No information is available on
how the storage of HCH-containing waste was organized prior to the construction of this deposit. It
is assumed that it was stored at and in its vicinity of the Cell 3, given the fact that, at the time of
construction the soil at the site of Cell 3 was already heavily contaminated.
Oltchim produced Lindane between 1969 - 1998. In 1998, following an economical analysis,
measures were taken to close the HCH-Lindane and pesticide formulation plant. The HCH
installation was decommissioned and since 2013 Polyether are produced on this site.
The hazardous waste deposit was closed in 2014. After the closure, Oltchim must monitor (post-
closure) the quality of groundwater, soil, and surface water, for a period of 30 years.
In January 2013, Oltchim entered insolvency proceedings, and the consortium formed by
Rominsolv SPRL and BDO Business Restructuring SPRL was appointed judicial administrator.
Oltchim's shareholding consisted of: Ministry of Economy (with 54.8% of shares), PCC SE,
Duisburg, Germany (18.32%), Poliyolt Holding Limited loc. Nicosia Cyp (14.03%) and other
shareholders, with 12.85%. In 2016, the Romanian state put Oltchim up for sale on nine asset
packages. In 2018, Chimcomplex Borzesti acquired five groups of assets so that Oltchim's core
business is currently managed by Chimcomplex Borzesti.
On the site of the HCH installation is currently polymers installation and warehouses for raw
material (According to Environmental Approval no 3/7.07.2010 and Decision of Scoping
no.1416/2.03.2010 issued by LEPA Valcea). Since 2019, the administrator of the polymer plant is
Chimcomplex Borzesti - Ramnicu Valcea Branch. The land on which the HCH installation was
situated is the property of the Romanian State (according to the information received from NEPA).

Figure A5.2.1 Aerial photograph of the of the Oltchim site, and its satellite sites
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Figure A5.2.2 GIM map of site Oltchim site


A5.2.3 Aerial photograph interpretation
For the site Oltchim site the aerial photographs mentioned in Table A5.2.2 have been reviewed.

Table A5.2.2 Aerial photographs for site Oltchim site with the site code RO-VL-01
Site name Aerial photographs Scale Years
Oltchim site Industrial zone 1985
Oltchim site Industrial zone 2012
Oltchim site Industrial zone 2019

Figure A5.2.3 Aerial photograph of Oltchim site from 1985 with the satellite site, RO-VL-02-01, the Waste deposit
(Cell3), situated in the southeast part of the Oltchim site, on the right bank of the River Olt
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Figure A5.2.4 Aerial photograph of Oltchim site from 2012 with the Cell 3, the waste deposit

Figure A5.2.5 Aerial photograph of Oltchim site from 2019 with the location of the former HCH Plant

A5.2.4 ICSM and Tier 1 risk assessment


For the Oltchim site an Initial Conceptual Site Model and Tier 1 risk assessment has been made.
The source zones that have been identified for the Oltchim site are listed in Table A5.2.3.
Table A5.2.4 gives the source receptor pathways and the receptors are presented in Table A5.2.5.
The site risk scores are presented Table A5 2.7. The total site risk score is 29. The migration risks
from the former plant and the waste deposit determine the score. There are human risks when
groundwork on these locations has carried out. It is assessed that the processing site does not
cause environmental risks. But this should be verified. Figure A5.2.6 is an aerial photograph with
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the source zones, the related pathways, and receptors.

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Table A5.2.3 Sources for Oltchim site with the site code RO-VL-01
Source type Source ID Source description Source Volume (m3)
Contaminated soil 1 Soil at the former HCH plant
Contaminated groundwater 2 Groundwater at the Former HCH plant
HCH Waste 3 Waste in deposit Cell 3 capped
Contaminated soil 4 At and around the waste deposit Cell 3
Contaminated groundwater 5 At and around the waste deposit Cell 3
Aquatic sediments 6 Aquatic sediment in Olt River
Contaminated soil 7 Former processing plant
Contaminated groundwater 8 Former processing plant
Contaminated surface water 9 Surface water Olt River

Table A5.2.4 Pathways for Oltchim site with the site code RO-VL-01
Pathway type Pathway Pathway description Pathway Source Receptor
ID status ID ID
Direct contact 1 Direct human contact with Only when 1 1
contaminated soil ground
working
Leaching infiltrated 2 Leaching of contaminants in the soil Active 1 3
rainwater in the soil causing soil contamination
Leaching infiltrated 3 Leaching contaminants from the soil Active 2 3
rainwater in into the groundwater causing
groundwater groundwater contamination
Groundwater flow 4 The groundwater flow spreading the Active 2 3
contaminants causing a plume of
groundwater contamination
Groundwater flow 4 The groundwater flow spreading the Active 2 4
contaminants in surface water
Surface water flow 5 The surface water flow causing Active 3 4
spreading of contaminants in the
surface water of the river
Surface water flow 5 The surface water flow causing Active 3 5
spreading of contaminants in the
sediments of the river
Direct contact 6 Direct contact ecosystem Active 4 6
Sediment

Table A5.2.5 Receptors for Oltchim site with the site code RO-VL-01
Receptor type Receptor ID Receptor description
Human 1 On-site groundworkers
Soil 2 Soil onsite
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Groundwater 3 Groundwater downstream onsite

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Receptor type Receptor ID Receptor description


Groundwater 4 Groundwater downstream off site
Surface water 5 Down stream surface water in the river
Aquatic sediment 6 Down stream sediments in the river
The aquatic ecosystem 7 Ecosystem in river

Figure A5.2.6 Map with Source - Pathway - Receptors

A5.2.5 Site classification


Table A5.2.6 gives the site classification according to the article “From uncontrolled to controlled
final sink“. The objectives to classify the contaminated sites is to direct the site responsible entity
to the hurdles that obstruct the implementation of risk reduction measures. The aspects reviewed
to classify the sustainable management status of the site are:
• The environmental risks present/controlled
• The availability of funds to manage the contaminated site in sustainable manner
• The awareness of the stakeholder
• The availability of technique to remediate the site

Table A5.2.6 Site classification


Aspects Explanation Category
Site risk Direct, potential, are controlled as the identified contaminated sites are built Controlled
control upon (HCH plant, processing plant) and the waste deposit is capped.. The
migration towards the river through the groundwater should be verified
Availability of Funds available, for including monitoring and aftercare. But it is not clear if Controlled
funds also the groundwater down stream the site is included. If off-site migration
takes place funds should be available to at least contain the groundwater
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Aspects Explanation Category


Awareness All stakeholders take their responsibilities. But the off-site quality of the Controlled
profile groundwater may need more involvement
Availability of All risk control measures are available Completely
techniques Controlled

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A5.2.6 Conclusions
According to the available information, annual soil and monthly groundwater monitoring are
carried out to determine the presence of pollutants, including HCH. No information is available on
the values obtained or their evolution. It is known that the levels exceed the intervention levels in
soil for industrial use. There is no information on ongoing of soil and groundwater investigation
and remediation. To be able to sustainably manage the site the CSM should be completed using
the monitoring data. If the monitoring data indicate that the situation is not standstill and off-site
migration of contaminants is taking place, additional survey should be carried to have a complete
CSM, design and implement risk reduction measure.

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Table A5.2.7 Contaminant risks for Oltchim site with site code RO-VL-01
Risk Risk description Risk Source Pathway Receptor Human Human Ecosystem Ecosystem Migration Migration
ID score ID ID ID Health health likelihood impact likelihood impact
likelihood impact
1-1-1 Direct contact with 6 1 1 1 2 3
contaminated soil by onsite
groundworkers
1-2-2 Contaminant migration in 1 1 2 2 1 1
soil
1-3-3 Contaminant migration into 1 1 3 3 1 1
groundwater onsite
2-4-4 Contaminant migration in 1 2 4 4 1 1
groundwater off site
9-4-5 Migration downstream 1 9 4 5 1 1
surface water
8-4-5 Contaminant migration into 1 8 4 5 1 1
aquatic sediments
6-6-6 Direct contact with 3 6 6 6 1 3
Ecosystem in river
3-1-1 Direct contact with HCH 4 3 1 1 1 4
onsite groundworkers
4-2-1 Contaminant migration in 2 4 2 1 1 2
soil HCH waste
4-2-3 Contaminant migration into 2 4 2 3 1 2

Final
groundwater HCH waste
deposit

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Risk Risk description Risk Source Pathway Receptor Human Human Ecosystem Ecosystem Migration Migration
ID score ID ID ID Health health likelihood impact likelihood impact
likelihood impact
5-5-5 Migration downstream 2 5 5 5 1 2
surface water
5-5-6 Contaminant migration into 2 5 5 6 1 2
aquatic sediments
6-6-7 Direct contact with 3 6 6 7 1 3
Ecosystem in river

Final
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A5.3 Chimcomplex Borzesti site - RO-BC-01

A5.3.1 Site details


Table A5.3.1 gives an overview of the site details.

Table A5.3.1 Site details


Issue
Site code parent site RO-BC-01 Cluster Yes
Current site name Chimcomplex SA Borzesti Site use label parent site Production site
Former site name Chemical Plant Borzesti Site authority Bacau Local
Environmental Protection
Agency
Country Romania Name of organisation National Environmental
Protection Agency
(NEPA)
Valcea Local
Environmental Protection
Agency
Region or Province Bacau County Name of focal point Ioan Baceanu (NEPA -
Soil Department Director)
City / Municipality Onești Office address Splaiul Independenței, no.
294, Bild B, Bucharest,
District 6
Site address Industriilor no. 3, Vâlcea Telephone
County
email office@anpm.ro
GPS coordinate N/S 46°14'17.64"N GPS coordinate E/W 26°50'47.93"E

A5.3.2 Site background


Chimcomplex site is located on the right bank of the river Trotuş, about 8 km downstream of
Oneşti. Chimcomplex site is bordered by: North - West - S.C. Termoelectrica - Borzesti CET
Power Plant Branch 1, South - East - agricultural land of Stefan cel Mare commune, East -
Trotus River, North - East - agricultural land of Gura - Vaii commune. According to satellite
images, it is estimated that the hazardous waste landfill was in the northern part of the plant on the
right bank of the Trotus River (see Figure A5.3.1). Figure A5.3.2 is a snip of the GIM map with the
site Chimcomplex.

From a geological point of view, around Onesti there are the following formations: in the centre,
southern, and western part there are alluvial deposits of the Upper Pleistocene, as well as
deposits alluvial and loam soils of the middle Pleistocene; to the north of Onești there are deposits
of Aquitanian - Swiss age consisting of: sandstones, sands, marls, tuffs and salt; to the east of
Onești are developed deposits of sands and clays belonging to the Meotian.
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The main soil type present are chernozem and sedimentary rocks (sand and gravel).
The elevation of the land is 183 m above sea level.

In the river valley of the Trotuș River and its tributaries, the phreatic aquifer deposits are made up
of sands, gravels and boulders located at variable depths. On the average terrace, the
groundwater level is 0.5 - 2 m from the ground surface.

Figure A5.3.1 Map of site RO-BC-01

The site was initially developed from agricultural land 1954. Chimcomplex was founded under
Government Decision no. 200 / 12.11.1990, by the detachment and full takeover of the patrimony
afferent to the Borzeşti Chemical Plants, within the Borzeşti Petrochemical Plant.

Borzesti Chemical Plants was founded in 1954. In 1959 the first installation, the oxygen factory,
came into operation, which provided the oxygen necessary for the construction works on the
industrial platform and on the construction sites in Onești. In 1960 the caustic soda plant was put
into operation with the installations: diaphragm electrolysis, liquid chlorine, hydrochloric acid,
evaporation-melting, also was put into operation installations for the manufacture of lime chloride
and Hexachlorane (Lindane).

Bacau LEPA did not provide information regarding Borzesti Chemicals Plants activities. There is
no information available on the period in which Lindane was produced, the capacity of the Lindane
installation or to the waste resulted from the Lindane production activity.

The inactive part resulting from the Lindane production of the Oltchim was disposed of as waste
on this deposit. There is no available information about location of the deposit. From the google
maps photos it is assumed that they were in the northern part outside the Chimcomplex site.
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Also, according to satellite images, this warehouse seems rehabilitated and covered with a vegetal
layer.
The site is contaminated with organic and inorganic compounds. According to the NEPA Letter
no.1/2480/15.06.2020, the source of contamination was hazardous waste storage. The waste
deposit was closed and rehabilitated in 2012.

The site was included in the National Site Contaminated Inventory in 2019 (Code: RO1AMOBC
00108)- the site is contaminated with organic and inorganic compounds. According to the
NEPA Letter no.1/2480/15.06.2020, the source of contamination was hazardous waste storage.
Investigations to determine groundwater quality conducted in the Site Reference Report
underlying the issuance of the Integrated Environmental Permit (2012) showed that the
groundwater is contaminated with HCH (α-HCH, β-HCH, γ-HCH), for soil the concentration of HCH
is below the alert threshold for less sensitive use (industrial) - Order 756/1997.

Figure A5.3.2 GIM map of site RO-BC-01

Currently, basic organic, inorganic chemicals and biocides are manufactured on the site. The
activity is regulated from the environmental point of view by the Integrated Environmental Permit
no.1/ 10.01.2013 revised in 28.08.2015 issued by APM Bacau with a validity term until
28.08.2025.

The nearest houses are at about 100 m southeast of the site boundary. Drinking water for the
Onesti City and for the site is supplied from the source of Poiana Uzului Lake. The Trotus River
water supplies the production process water for the factory. There is no information on the use of
the Trotus River as a drinking water source for the downstream settlements.
According to the Integrated Environmental Permit, the site as monitored for HCH in the
groundwater and soil (frequency is every three year). There is no available information related the
results of the monitoring.

According to the Integrated Environmental Permit no.1/10.01.2013 revised in 28.08.2015 issued


by Bacau EPA all the former hazardous waste deposits have been closed since 2012. Post-
closure monitoring of soil and groundwater quality around deposits must be carried out for a
period of 30 years according to national legislation (GD 349/2005).

A5.3.3 Aerial photograph interpretation


For the Chimcomplex Borzesti site, RO-BC-01, the aerial photographs mentioned in table A5.3.2
have been reviewed.

Table A5.3.2 Aerial photographs for the Chimcomplex Borzesti site with the Site code RO-BC-01
Site name Aerial photographs Scale Years
Chimcomplex Borzesti Chimcomplex Borzesti 1:200 2003
Chimcomplex Borzesti 1:200 2011
Final

Chimcomplex Borzesti 1:200 2016

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Figure A5.3.3 Aerial photograph of Chimcomplex Borzesti site, 2003. Mountains of white powder can be seen at the
north of the plant, between the facility and river Trotus

Figure A5.3.4 Aerial photograph of Chimcomplex Borzesti site, 2011


Final

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Figure A5.3.5 Aerial photograph of Chimcomplex Borzesti site, 2016. The deposit has been covered with grass

A5.3.4 ICSM and Tier 1 risk assessment


For the Chimcomplex Borzesti site, an Initial Conceptual Site Model and Tier 1 risk assessment
has been made. The source zones that have been identified for the Chimcomplex Borzesti site are
listed in Table A5.3.3. Table A5.3.4 gives the source receptor pathways and the receptors are
presented in Table A5.3.5. The site risk scores are presented Table A5 3.7. The total site risk
score is 33. Figure A5.3.6 is an aerial photograph with the source zones, the related pathways,
and receptors.

Table A5.3.3 Sources for the Chimcomplez Borzesti site RO-BC-01


Source type Source ID Source description Source Volume (m3)
Contaminated soil 1 Soil at the former HCH plant
Contaminated groundwater 2 Groundwater at the Former HCH plant
HCH Waste 3 Waste in deposit is capped
Contaminated soil 4 At and around the waste deposit
Contaminated groundwater 5 At and around the waste deposit
Contaminated surface water 6 Surface water Trotus River
Aquatic sediments 7 Aquatic sediment in Trotus River
Final

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Table A5.3.4 Pathways for the Chimcomplez Borzesti site RO-BC-01


Pathway type Pathway Pathway description Pathway Source Receptor
ID status ID ID
Direct contact 1 Direct contact with the waste Only when 1 1
ground
working
Direct contact 1 Direct human contact with Only when 3 1
contaminated soil ground
working
Leaching infiltrated 2 Leaching of contaminants in the Active 4 2
rainwater in the soil soil causing soil contamination
Leaching infiltrated 3 Leaching contaminants from the Active 4 3
rainwater in soil into the groundwater causing
groundwater groundwater contamination
Groundwater flow 4 The groundwater flow spreading Active 3 3
the contaminants causing a plume
of groundwater contamination
Groundwater flow 4 The groundwater flow spreading Active 2 4
the contaminants in surface water
Surface water flow 5 The surface water flow causing Active 3 4
spreading of contaminants in the
surface water of the river
Surface water flow 5 The surface water flow causing Active 5 6
spreading of contaminants in the
sediments of the river
Direct contact 6 Direct contact ecosystem Active 5 7
Sediment

Table A5.3.5 Receptors for the chimcomplez Borzesti site RO-BC-01


Receptor type Receptor ID Receptor description
Human 1 On-site groundworkers
Soil 2 Soil onsite
Groundwater 3 Groundwater downstream
Surface water 4 Down stream surface water in the river
Aquatic sediment 5 Down stream sediments in the river
The aquatic ecosystem 6 Ecosystem in river
Final

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Figure A5.3.6 Satellite with Source - Pathway - Receptors

A5.3.5 Site classification


Table A5.3.6 gives the site classification according to the article “From uncontrolled to controlled
final sink“. The objectives to classify the contaminated sites is to direct the site responsible entity
to the hurdles that obstruct the implementation of risk reduction measures. The aspects reviewed
to classify the sustainable management status of the site are:
• The environmental risks present/controlled
• The availability of funds to manage the contaminated site in sustainable manner
• The awareness of the stakeholder
• The availability of technique to remediate the site

Table A5.3.6 Site classification


Aspects Explanation Category
Site risk Direct, potential, are controlled as the identified contaminated sites are built Controlled
control upon (HCH plant, processing plant) and the waste deposit is capped.. The
migration towards the river through the groundwater should be verified
Availability of Funds available, for including monitoring and aftercare. But it is not clear if Controlled
funds also the groundwater down stream the site is included. If off-site migration
takes place funds should be available to at least contain the groundwater
Awareness All stakeholders take their responsibilities. But the off-site quality of the Controlled
profile groundwater may need more attention therefore the authorities should be
involved
Availability of All risk control measures are available Completely
Final

techniques Controlled

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A5.3.6 Conclusion
Although the levels of HCH contamination detected in the soil are below the intervention levels,
the same is not the case with the groundwater. Migration towards the river by groundwater flow
cannot be excluded. Considering the proximity to the Trotus riverbed, efforts should be directed to
detecting the source of groundwater contamination for its remediation, thus avoiding migration risk
and risk for the aquatic ecosystem.

Final

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Table A5.7 Contaminant risks for the Chimcomplex Borzesti site RO-BC-01
Risk Risk description Risk Source Pathway Receptor Human Human Ecosystem Ecosystem Migration Migration
ID score ID ID ID Health health likelihood impact likelihood impact
likelihood impact
1-1-1 Direct contact with the 2 1 1 1 1 2
contaminated soil during
groundwork at the former
HCH plant
1-2-2 Contaminant migration in soil 1 1 2 2 1 1
at the former HCH plant
1-3-3 Contaminant migration in 1 1 3 3 1 1
groundwater at the former
HCH plant
2-4-3 Contaminant migration in 1 2 4 3 1 1
groundwater off site
2-4-4 Contaminant migration into 1 2 4 4 1 1
the surface water
6-5-4 Contaminant migration in the 1 6 5 4 1 1
surface water
6-5-5 Contaminant migration in 1 6 5 5 1 1
aquatic sediments
7-6-6 Direct contact with 3 7 6 6 1 2 1 1
Ecosystem in river
3-1-1 Direct contact with the waste 3 3 1 1 1 3

Final
during groundwork in waste

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Risk Risk description Risk Source Pathway Receptor Human Human Ecosystem Ecosystem Migration Migration
ID score ID ID ID Health health likelihood impact likelihood impact
likelihood impact
4-2-2 Contaminant migration in soil 6 4 2 2 3 2
at and around HCH waste
deposit
4-2-3 Contaminant migration into 3 4 2 3 3 1
groundwater at and around
HCH waste deposit
5-5-4 Contaminant (HCH deposit) 3 5 5 4 3 1
migration downstream
surface water
5-5-5 Contaminant (HCH deposit) 3 5 5 5 3 1
migration in aquatic
sediments
7-6-6 Direct contact (HCH deposit) 4 7 6 6 2 2
with Ecosystem in river

Final
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