Organization of Eastern Caribbean States (OECS) - Ship-Generated Waste Management Project

Organization of Eastern Caribbean States Ship-Generated Waste Management Project Project Document April 1995 - THE WORLD BANK  GEF Documentation The Global Environment Facility (GEFl assists developing countries to protect the global environment in four areas: global warming. pollution of international waters. destruction of biodiversity. and depletion of the ozbne layer. The GEF is jointly implemented bythe United Nations DevelopmentProgramme.the United Nations Environment Programme, and the World Bank GEF Project Documents - identified by a green band - provide etended project- specific information. The implementing agency responsible for each project is identified by its logo on the cover of the docLfment. Global Environment Coordination Division Environment Department World Bank 1818 H Street. NW Washington. DC 20433 Telephone: (202) 473-1816 Fax: (202) 522-3256  Report No. 13868-CRG Organization of Eastern Caribbean States Ship-Generated Waste Management Project Project Document April 1995 Environment and Urban Development Division Country Department Im Latin America and the Canibbean Region  CURRENCY EQUIVALENTS Currency Unit = East Caribbean Dollar (EC$) lEC$ = US$0.37 1US$ = EC$2.70 WEIGHTS AND MEASURES 1 meter (m) = 3.28 feet (ft) 1 kilometer O3m) - 0.62 mile (ml) 1 square kilometer kn) = 0.386 square miles (sq ml) 1 hectare (ha) = 2.47 acres (ac) 1 metric ton (m ton) 2,205 pounds Cibs) ACRONYMS AND ABBREVIATIONS CARICOM - Caribbean Community CDB - Canbbean Development Bank CEH - Caribbean Environmental Health nstitute CIDA - Canadian International Development Agency EE-iB - European Investment Bank EIRR - Economic Internal Rate of Return ENCORE - Eastun Caibbean-Environmentl and Coastal Resources EU - European Union GDP - Gross Domestic Product GEF - Global Environment Facility GET - Global Environment Facility Trust Fund GTZ - Germany's Development Agency IC&I - Industrial, Commercial & Instiutional ICB - International Competitive Bidding NMO - International Maritime Organizaion RCB - Regional Competitive Bidding LU - Legal Unit of the OECS Secretariat MARPOL - International Convention for the Prevention of Marine Pollution MEPC - Marine Environment Protection Committee MOH - Ministry of Health MOW - Ministry of Works NRMU - Natural Resources Management Unit of the OECS Secretariat  OECS - Organization of Eastem Canibbean States PMU - Project Management Unit PIU - Project Implementation Unit PAHO - Pan American Healtl Organization STORE - Special Drawing Rights UNEP - United Nations Environmental Program USAID - U.S. Agency for Iternatonal Development WASA - Water and Sewerage Authority WCISW - Wider Caribbean Initiative for Ship Generated Waste FISCAL YEAR Antigua January 1 to December 31 Dominica July 1 to June 30 Grenada January 1 to December 31 St. Kitts January 1 to December 31 St. Lucia April 1 to March 31 St. Vincent Jamny 1 to December 31  Part I: Project Summary  ORGANIZATION OF EASTERN CARIBBEAN STATES SHIP-GENERATED WASTE MANAGEMENT PROJECT GLOBAL ENVIRONMENT TRUST FUND GRANT SUMMARY Recipient: The following OECS countries: - Antigua and Barbuda - Commonwealth of Dominica - Grenada - St. Kitts and Nevis - St. Lucia - St. Vincent and the Grenadines Beneficiaries: The Ministries of Health and Port Authorities of the Governments of the OECS countries listed above and the OECS Secretariat. Amount: SDR 8.8 million equivalent (US$12.5 million) Antigua and Barbuda US$1.3 million Dominica US$0.8 million Grenada US$1.3 million St Kitts and Nevis US$1.2 million St Lucia US$1.1 million St Vincent and Xt Greadines US$1.1 million Regional Component (all beneficiary Countries) US$5.7 million Terms: Grant USS million Financing Plan GET: LOCAL FOREIGN TOTAL GET 1.0 11.5 12.5 OECS Govemments 2.0 2.0 Sub-total 3.0 11.5 14.5 Associated Project: 1BRD 0.5 6.3 6.8 .DA 0.4 4.3 4.7 CDB 4.1 4.6 8.7 EIB 1.0 5.4 6.4 EU 1.3 0.6 1.9 OECS Govemnts 7.5 7.5 Sub-total 14.8 21.2 36.0 Total 17.8 32.7 50.5 Poverty Category: Not applicable Economic Rate of Returm: Not applicable  ORGANIZATION OF EASTERN CARIBBEAN STATES SHIP-GENERATED WASTE MANAGEMENT PROJECT 1. Background. The countries of the Organization of Eastern Caribbean States are small island states with fragile ecosystems. Overall, the economies have performed reasonably well in recent years with an average growth rate in GDP of 2.0 %. Their per capita GNPs were less than US$4,000 in 1989, and all except Antigua and Barbuda and St. Kitts and Nevis remain weil below US$4,000 in 1993. Their economies are each dependant, to varying degrees, on agriculure (mainly banana) and the tourism industry, which are togedter responsible for the bulk of foreign exchange earnings in all the countries. The quality of the environment, and particularly of the marine environment, is vital to the prosperity of these countries, and in recent years this has come under increasing threat from a number of sources. Paramount among these is that posed by the indiscriminate dumping of solid wast both by ships at sea, and by individuals on land. Much of the solid waste dumped by ships into the Caribbean Sea, or by individuals into rivers or onto river banks ends up as marine debris washed up on the beaches, the clean condition of which is a requirement of the flourishing tourist industry which underpins these countries' economies. Furthermore, marine debris is increasingly responsible for causing permanent damage to the unique and fragile coastal and marine ecosystems of the Caribbean Sea. 2. The Wider Caribbean Sea was in 1990 designated as a Special Area under the MARPOL Convention 73/78 (International Convention for the Prevention of Pollution from Ships) for Annex V wastes (Report No. 13868 CRG, Annex A). This effectively restricts the dumping of ship-generated solid waste (Annex V wastes) in the international and territorial waters of the Wider Caribbean Sea. While at present only two of the six OECS counties (Antigua and Barbuda and St. Vincent and the Grenadines) are signatories to the MARPOL 73/78 Convention, all of the OECS governments have agreed to provide facilities for the reception, treatment and disposal of ship-generated solid wastes which are covered under MARPOL 73/78 Convention Annex V. The regulatons govering provision of reception facilities within Special Areas state that Governments must undertake to provide adequate reception facilities for solid waste at all ports within a Special Area, taking into account the special needs of ships operating in such areas. (Through the proposed project and the ongong Wider Canbean Initiative for Ship-generated Wastes, it is anticipated that the rmaining project countries will become signatories to MARPOL 1973178 in the near future.) Cruise ships in particular, the operation of which has grown rapidly in the region over the past decade, generate large quantities of solid waste on-board. Although advances are currently being made in on-board recycling and treatment of solid wastes, however, residual solid waste must be dealt with on shore.  -2 - 3. Solid waste management services in all the countries can be characterized by: (i) fragmented institutional responsibilities for solid waste management, and generally inadequate management control of the service; (ii) poor resource mobilization in the sector and little or no means for cost recovery for the service; (ii) poor public awareness of the importance of solid waste management and undeveloped opportunities for waste recycling and management; (iv) shortage of collection equipment and inadequate provision for the maintenance of existing equipment; (v) inadequate provision for the treatment of pathogenic and other dangerous wastes including food-contaminated MARPOL 73/78 Annex V waste; and (vi) inadequate arrangenment for the final disposal of solid waste, frequently resulting in nuisance, air and water pollution and subsequent enviromnental damage. 4. In view of the above, there is an urgent need to undertake improvements to the waste agement and disposal systems in all islands, and to equip the ports and harbors with facilites to handle ship-generated solid wastes. The facilities thus established in the countries and at the project ports will also serve as a model for replication by other Caribbean countries(ports in the Wider Caribbean Region. 5. GEF Project Objectives. The objective of the proposed GEF project is to protect the environmental integrity of coastal and marine systems in the Caribbean Sea, by facilitadng compliance with the special area designation of the Caribbean Sea for MARPOL 73/78 Annex V wastes and thereby, reducing marine pollution in the Caribbean Sea. More specifically, project objectives are to assist the OECS governments to: (i) reduce pollution of international and territorial waters caused by ship-generated solid wastes by improving the collection, treatment and disposal of ship-generated solid waste; (ii) establish an appropriate legal and institutional fameworks to enable them to effectively manage and dispose of ship-generated waste; and (iii) prepare plans and programs to address the problems of collection, treatment and disposal of liquid wastes and identify regional opportunities for recycling of waste. The objectives of the GEF project wil be achieved through: (i) institutional strenghening and improved policy, regulatory and incentive frameworks; (ii) provision of facilities to receive ship-generated and yacht-generated solid wastes; (iii) incremental improvement of domestic solid waste collection and disposal systems to adequately deal with the disosal of ship-generated waste; and (iv) provision of technical assistance to help in the preparation of sewerage masterplans and carry out feasibility studies for sewerage and sewage collecton, treatinent and disposal improvement programs; and (v) identify regional oppoMnities for recycling of waste. 6. GEF Project Description. The project comprises a number of national components which are similar for each of the OECS beneficiary countries and a regional component which covers issues common to all. Tnh national components comprise: (i) establishment of a Solid Waste Management entity to include dedicated staff and eqipment with independent accountng procedures to safeguard the sustainability of the project through monitoring and enhanced control of revenues and  -3- expenditi-es for the solid waste collection and disposal system; (ii) provision of port reception facilities for ship- and yacht-generated MARPOL Annex V wastes, comprising waste receptacles and associated civil works; (iii) procurement of equipment associated with the Iindling and transfer of ship-generated solid waste both within ports, and between ports and the point of ultimate waste disposal; (iv) provision at the landfill sites of civil works for improved handling of ship-generated solid waste; (v) incremental improvements to existing landfill sites. and provision of necesscry equipment to upgrade them to sanitary disposal facilities, commensurate with the estimated proportion of marine-generated waste to be disposed at the landfill sites calculated at about 13% of the total volume of waste deposited at the facility; (vi) provision of technical assistance for tht wastewater and sewerage sector; and (vii) provision of technical assistance to identify Regional opporunities for recycling of solid waste. This GET funded component is an integral part of the OECS Solid Waste Management Project which will provide improvements to the entire solid waste management systems in all six OECS countries member of the Bank. 7. The Grenada GEF Project will include an additional component to support the establishment and management of a protected area for the endangered Grenada Dove. The discovery of the Grenada Dove at the previously proposed (now rejected) landfill site at Perseverance Estate served to increase the awareness of Govermnent and the international community over the plight of this species. In response to this, Government has declared the hillsides of the Mount Hartman Estate as a protected area for the Grenada Dove. To support this effort and ensure adequate protection for the sanctuary, the GET grant will provide for physical demarcation, protection related equipment, and management support for conservation activities in the prorected area. 8. The regional component comprises support activities and technical assistance to all countries for project management, training and education, establishment of common legal frameworks, developing recycling opportuities for solid waste, assistance with the enforcement of MARPOL 73178 Convention, and public awareness programs. Project management assistance will ensure that the project is implemented in a timely and efficient manner. The development of common legal frameworks will concentrate on creating conditions conducive to the receipt of ship-generated waste and facilitation of its proper transport and disposal, and the development of appropriate controls which wiU also assist with the management and safe disposal of land-generated waste. The trainig program will focus on developing capabilities in port-state control of ship generated waste and in system management to ensure smooth operation of the reception, tansport and disposal systems. A project monitoring and evaluation program will be developed to provide mangement information on the success of the project in meeting its objectives. This program will also evaluate the efficiency of the mistitutions operating the systems m terms of both operational and financial parameters (efficiency of cost recovery and degree of self financig). Physical monitoring of the sanitary landfill sites will be carried out by the Caribbean  -4 - Environmental Health Institute (CEHI) or other qualified body, under agreements reached with each beneficiary country 9. Associated Bank/IDA Project. The GEF project is associated with an IBRD/IDA project co-financed by CDB and EIB, which has similar objectives namely of: (i) reducing indiscriminate disposal of shore-generated solid waste, and thereby contributing to reducing pollution of territorial waters; (ii) improving the collection, treatment, and disposal of shore-generated solid waste; and (iiij enhancing the countries' capabilities for dealing with dangerous wastes. The estimated cost of the associated project is US$36.0 million, and was appraised in January/February 1994. 10. Project Implementation. National components of the Project will be implemented by a Project Implementation Unit (PIU) in each country which forms a part of the Solid Waste Management Entities being established in each country with the support of the Project. The Solid Waste Management Entities will operate witiin the overall jurisdiction of the Ministries of Health, and will implement the project in accordance with Government and Bank guidelines. Certain of the port components will be implemented by the Port Authorities in each country. The regional components will be implemented by a Project Management Unit (PMUI) to be established at the regional level under the Director General of the OECS Secretariat, and alongside or witiin the Natural Resources Management Unit (NRMU) of the Secretariat. This unit will also undertake overall co-ordination and consolidated monitoring of the project. The PIUs to be established in each country will be responsible for day-to-day management and supervision of the national components. The PMU and the PIUs will utilize technical assistance support as required, to be provided by consultants contracted either individually by each country, or jointly through the OECS Secretariat. Technical experts will assist the PMU in improving its technical capacity to improve waste management and project monitoring in the OECS countries. Equipment and capital civil works financed by GET will be procured according to Bank procurement guidelines. 11. The project is expected to become effective (commensurate with governments having satisfied all conditions leading to effectiveness of their national components) in the fourth quarter of FY 1995, completed (all project components fully implemented) by June 2000, and fully disbursed (all disbursements made by the Bank) by December 31, 2000. A mid-term review of the Project (about two and a half years from the date of effectiveness) will be carried out to evaluate progress of implementation against planned objectives. 12. Project accounts will be maintained by the Ministries of Finance on behalf of the respective PIUs of each of the participating countries for civil works, equipment procurement, and national technical assistance components. The OECS Secrtariat will maintain accounts for the regional component. Country accounts will be  -5- consolidated in the Ministries of' Finance and made available for inspection by supervision missions. 13. Monitoring and Evaluation. Monitoring and Evaluation will be carried out at two levels: (i) to determine progress of the project, and (ii) to monitor the efficiency of the newly formed solid waste management entities in perfonning against their mandate according to national solid waste management plans. 14. For the project, the PIUs will prepare, and submit through the PMU for Bank review, quarterly progress reports on the execution of the infrastructure works and procurement of equipment. The PMU will be responsible for the consolidation of quarterly reports from all project countries. Each fiscal year, the PIUs will ppare a progress report of the preceding year and annual implementation plans for the forthcoming year based on the projected project implementation program and progress will be evaluated against this plan. This plan will be finalized taking into account Bank's comments. 15. Monitoring of the performance of the solid waste management entities themselves will be carried over the duration of the Project. Every fiscal year, concurrently with the preparation of the annual budget, the governments will prepare a progress report of the preceding year's operations, and a detailed solid waste management and maintenance program, and its funding, for the forthcoming year. The progress report for the preceding year and subsequent annual program including funding will be furnished to the Bank for review through the PMU by December 31 of each year. 16. Project accounts, audited by an external auditing firm acceptable to the Bank in accordance with international auditing stadards, will be prepared and submitted to the PMU for onward transmittal to the Bank annually. The OECS governments will submit certified copies of the audited accounts to the Bank, through the PMU, no later an three months after the end of audited period. 17. The project is designed to include a set of key indicators to be used for monitoring and evaluation of both the project and the solid waste management system as a whole, to assess the impact of the project on the OECS countries and the Caribbean Sea, and to facilitate the intoduction of adjustments when necessary. Development of these criteria and their adoption would form part of the regional component, bi- t suitable indicators for the overall project would include: (a) adherence to collection schedules; (b) equipment downtime and reasons; (c) frequency and nature of public complaint; (d) coverage by system; (e) cost per ton of disposal; and (f) employee performance, absence etc. For the maritime component specifically, the volume and characteristics of wastes landed (including composition and whether compacted or sterilized etc.) would be closely monitored and measured throughout the period of implemenation, and database of this information would be established in  -6- each country and for the region; (there is no data available on waste landed on the islands from ships and yachts at present). The degree of compliance by ships with the regulations of MARPOL 73/78 would also be closely monitored. In addition, through the education element of the regional component, commuimty and NGO involvement in beach clean-up campaigns would be encouraged to provide data on the impact of the project on marine debris larding on the beaches of the region. 18. Project Cost and Financing. The total cost of the GEF project is estimated at US$14.5 million including US$2.0 million for taxes and duties. The foreign exchange component totals about US$11.5 million. Taxes and duties due on GEF project components (e.g. imported equipment) will be borne by the beneficiary governments. The GET grants will be applied to the full cost of reception, handling and disposal of ship-generated MARPOL Annex V wastes in all six countries. GET grants will also be applied towards the technical assistance for wastewater collection, treatment and disposal masterplans, and the regional component. (Project cost and financing plan is shown at Schedule (A). 19. Project Sustinability. Project sustainability rests on the overall commitment of the respective OECS governments to the environment. However, the project is designed to be self sustaining. Specifically, the project will support the adoption of an appropriate legal framework to deal with ship-generated solid waste, provide institutional strengthening, support waste minimization and recycling, introduce cost rcovery mechanisms, encourage private sector participation in waste management, and stimulate public awareness through media exposure and education programs. Financial sustainability will be achieved through the introduction of independent financing arrangements for the solid waste management system. In particular the project will (i) introduce an enviromnental levy of US$1.50 to be imposed on all visitors to the OECS beneficiary countries; (ii) maintain, in real terms, the current levels of government contributions to the solid waste management sector; (iii) make use of any revenues generated from the proposed recycling programs; and (iv) introduce tipping fees at landfill sites. The project has an excellent chance of succeeding because of the support it has already received from the sub-region an technical as well as political grounds. 20. Lessons from Bank/IDA and GEF Involvement. This is the first operation to prevent marine pollution in the OECS countries. This project represents a considerable challenge as it involves six different countries and five sources of funding. Lessons learned from other single country experences in the sector have been applied, notably from the China 'Ship Waste Disposal Projectt (SAR No. 9852- CHA). Specifically, the integration of a port solid waste plan for ships' wastes with that of the islands' solid waste management plans constitute the overall proposed waste management program.  -7- 21. Rationale for GEF Funding. This project is designed to redress existing problems and prevent further pollution of coastal, territorial and international waters in an area of the world which, now and in the fature, depends heavily on its coastal zone for income and employment. The project would result in considerable regional benefits. It would achieve a significant reiuction in marine pollution, and thus protect valuable and irreplaceable natual resources. Annex V of MARPOL 73f78 Convention, under its own terms, cannot be enforced in an area until that area has sufficient ports and harbors equipped with reception facilities to receive Annex V wastes. Countries with coastlines bordering on a Special Area are obliged, under the terms of the convention, to provide ports with suitable reception facilities "as soon as possible". Reception of Annex V wastes and the provision of reception facilities and associated investnents are a regional responsibility. It is primarily through the provision of such facilities that sea disposal of Annex V (solid) waste in the region can be eliminated. Avoidance and minimization of such waste can also be facilitated through the more widespread use of better on-board waste treatment technology. 22. The GET grants are the only source of funding available to the OECS countries to assist them in the provision of these facilities. The GEF project is critical in inducing governments to make the required investments in reception and transport facilities and in sharing the cost of upgrading landfills to a level that will allow them to begin to accept ship-generated waste. Wastes received from ships will be collected and transported in sealed containers, and disposed of at sanitary landfills in an enviromentally acceptable manner. The investments to be financed under GET grant are needed to ensure adequate disposal of ship-generated waste and the sustanabiity of dis effort over the long term. While limited to the six OECS countries, the proposed project will serve as a model for other countries in the Caribbean with comparable needs. The pro, osed project provides a basis for approaching the similar problems experienced by the other 16 developing counties included in the Wider Canrbbean Initiative for Ship-generated Waste (WCISW). 23. Procurement and Disbursement. Procurement of all contracts under the project is designed on a parallel-financing basis and would follow the applicable guidelines of the individual financing agency. All items included in the country component will be procured through the Central Tender and Supplies Committee of the respective govermnents. Procurement of port related items will be procured by the respefive port authorities or through the Central Tender and Supplies Committee of the respective governments and items included in the regional component will be procured by the PMU according to Bank's procurement guidelines. The GEF-financed components would be procured as follows: (a) equipment and material purchase costing US$50,000 or more would be procured through Interational Competidve Bidding (ICB; total estimated value - US$5.5 million); (b) civil works contracts would be procured through shopping procedures acceptable to the Bank (estimated total value US$0.3 million); and (c) equipment and material costing less than US$50,000 would  -8- be procured through shopping procedures, acceptable to the Bank Group, (total estimated value - US$0.6 million). For such contracts, award would be made on the basis of at least three price quotations from at least two countries. Consultants would be recruited in accordance with the Bank's guidelines using the Bank Standard Form of Contract for Consultants' Services. 24. The Bank will review ex-ante all procurement documentation under ICB (tender documents, bid evaluation and award recommendation). Procurement documentation for equipment and work contracts procured through Shopping will be subject to selective ex-post-review by the Bank. All such procurement documentation will be retained by the borrowers to facilitate selective ex-post review by the Bank. Consultancy contracts not exceeding US$25,000 equivalent would be subject to ex- post review by the Bank and the Association. 25. The proposed GET grants of US$12.5 million equivalent would be disbursed in accordance with the following proportions of total project costs: (a) 100% of total expenditures for port reception facilities; (b) 100% of total expenditures for consultants' services, technical assistance and training; and (c) 100% of the cost of those items of landfill equipment included for GET fumding and equivalent in cost to about 13 % of total long-term expenditures for civil works, equipment, material and supplies related to solid waste treatment and disposal. All the above are net of taxes and duties which would be borne by Govemment. All disbursements will be fully documented, except for payments against contracts valued at less thn US$50,000 which would be disbursed on the basis of statements of expenditures (SOE). To the extent possible, all withdrawal applications should be aggregated to no less than US$25,000. Supporting documents for amounts withdrawn on the basis of SOEs would be held in a central location (both in the country and with the PMU), and made available for review by auditors and visiting Bank missions. Retroactive disbursement of up to 10% of the Grant amount would be considered provided that procurement was made according to Bank's guidelines. 26. Agreed Actions. Agreement have been reached with the recipients concerning the following key activities (including the preparadon and passage of necessary legislation/regulatons) as conditions of effectiveness: (i) the acquisition (or long tem lease) of all lands required for solid waste landfill sites (and associated access), and tansfer stations; (ii) the establishment by all governments of a suitable institutional framework for managing the operation of the solid waste management system; (iii) the amount and method for charging for the proposed enviromnental levy; (iv) all waste management charging mechanisms; (v) the detailed arrangements for project implementation and monitoring; and (vi) the detailed scope of technical assistance components including the preparation of sewerage masterplans. In addition, agreement between each of the OECS Governments and CEHI (or other competent body) on the arrangements for the periodic monitoAing of pollution at the solid waste landfill sites is a condition of disbursement for development of the sites.  -9- 27. Environmental Aspects. Environmental Impact Assessments have been prepared, and hydrogeological surveys have been undertaken, for the proposed sanitary landfill disposal facilities for which they are required. Where necessary and appropriate, environmental criteria and mitigation measures have been incorporated in the design of all project components. An Environmental Assessment Summary Report on the project, submitted by the OiECS countries, has been provided to the Board on December 1, 1993. 28. Project Benefits. By addressing the problems of marine pollution through the provision of facilities for the reception of ship-generated solid waste, and the improvement of facilities for its treatment and disposal on-shore, it is envisaged that considerable health and economic benefits will be realized. The major benefits will result from progress in the reduction of the amounts of marine debris found in the seas and on the beaches of the region, and significant improvements in the environmental quality of the landfill sites of ultimate waste disposal. Health benefits will accrue to the population of the OECS beneficiary counties. In addition, major economic benefit, for the region as a whole, will result from the sustainable growth in the tourism industry, which would otherwise be threatened by the worsening condition of the region's beaches and countryside. 29. Risks. The main risks relate to effective operation, coordination and maintenance of the project components and cost recovery in six independent Caribbean countries. One risk is that one or more of the beneficiary countries will fail to implement the institutional reforms proposed under the project and thus not adequtely strengthen the institutional arangents for solid waste management both for ship-generated waste and for land based waste. A firther risk relates to the failure of beneficiary governments to itroduce the appropriate level of tariffs needed to fiance the investments, inchding recurrent costs, associated with the proposed waste plans as proposed under the project. A condition of effectiveness will be that insdtutional and cost recovery reforms proposed under the project will be adopted by all beneficiary governments.  SbediiIeA lag. 1 47 -ores sEmFENERAThn, WASTIEMANAGEMIEN'TPRJECT- Natool me Component RoxzpfoFsmedes (a) CMvlWaft 129 76 205 205 0 (b) Eq#nxtns BB9 2406 3295 2406 889 (e) Design and Supcvision 0 205 205 205 0 (d) Start-up andTrainng 0 285 285 285 0 () O T. amdfill 0 ERqyip