Development of Environmental Impact Assessment and Update of Environmental and Social Impact Assessment Reports For

Development of Environmental Impact Assessment and Update of Environmental and Social Impact Assessment Reports for

the Mine Tailings Disposal Facility Gradac

First Draft Environmental and Social Impact Assessment Report

JUNE 2019

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... 1 I. INTRODUCTION ...... 11 I.1. Description of the Project ...... 11 I.2. Scope and Purpose of the Environmental and Social Impact Assessment Studies...... 13 I.3. Structure of the ESIA Report ...... 14 II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...... 16 II.1. Legal Framework for Environmental Protection and Conservation ...... 16 II.2. Legal Framework for Health and Safety ...... 16 II.3. Montenegrin/European Environmental Legislative and Permitting Framework ...... 17 II.3.1. EU Directives ...... 17 II.3.2. Horizontal Legislation ...... 17 II.3.3. Nature Protection ...... 18 II.3.4. Air Quality ...... 18 II.3.5. Waste Management...... 18 II.3.6. Water Quality ...... 18 II.3.7. Industrial Pollution ...... 19 II.3.8. Inspections ...... 19 II.4. National EIA Procedure ...... 19 II.5. International Environmental and Social Regulatory Framework ...... 21 II.5.1. International Treaties and Conventions ...... 21 II.5.2. World Bank Group Environmental and Social Framework and Safeguard Policies ... 21 II.5.3. Gaps between the World Bank OP 4.01 and Montenegrin EIA Procedure ...... 23 II.5.4. Good International Industry Practice ...... 24 III. PROJECT DESCRIPTION ...... 25 III.1. Basic Characteristics of Design Solution ...... 25 III.2. Project Solution of the Remediation Process ...... 28 III.3. Recultivation Layers ...... 29 III.3.1. Geomembrane ...... 31 III.3.2. Drainage Pipes ...... 32 III.4. Levelling ...... 32 III.5. Land Clearance ...... 33 III.6. Excavation, Moving and Installation of Tailings ...... 34 III.7. Technology of the Excavation of Tailings ...... 34 III.8. Installation of Stabilization Layer ...... 34 III.9. Excavation Works ...... 35 III.10. Recultivation ...... 35 III.11. Material Quantities ...... 36 III.12. Project Duration ...... 37

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IV. ENVIRONMENTAL AND SOCIAL BASELINE CONDITIONS ...... 38 IV.1. Study Area and Sources of Baseline ...... 38 IV.1.1. Potential Area of Influence of the Project ...... 38 IV.1.2. Sources of Baseline Data ...... 40 IV.2. Characteristics of the Physical Environment ...... 40 IV.2.1. Topography, Geology, Hydrogeology and Hydrology of the Region ...... 40 IV.2.2. Erosion and Land Use ...... 45 IV.2.3. Climate ...... 45 IV.2.4. Seismicity ...... 46 IV.3. Quality of Physical Environment ...... 47 IV.3.1. Water Quality ...... 48 IV.3.2. Soil Quality ...... 52 IV.3.3. Air Quality ...... 54 IV.3.4. Noise ...... 54 IV.3.5. Landscape Features ...... 55 IV.3.6. Radioactivity ...... 56 IV.4. Ecology and Biodiversity ...... 57 IV.4.1. Definition of Study Area and Impact Area ...... 57 IV.4.2. Assessment Methodologies and Data Sources ...... 57 IV.4.3. Ecological Researches ...... 61 IV.4.4. Findings ...... 61 IV.5. Socioeconomic Environment ...... 74 IV.5.1. Settlements ...... 74 IV.5.2. Demographic Characteristics ...... 74 IV.5.3. Employment ...... 74 IV.5.4. Education ...... 74 IV.5.5. Vulnerable Groups ...... 74 IV.5.6. Health and Social Security ...... 74 IV.5.7. Social Infrastructure and Services ...... 75 IV.5.8. Economy in the Municipality of Pljevlja and Livelihoods ...... 77 IV.5.9. Affected Settlements by the Project ...... 77 IV.6. Protected Areas and Cultural Heritage and Assets ...... 78 V. ENVIRONMENTAL AND SOCIAL IMPACTS ...... 79 V.1. Area of Influence and Impact Assessment Approach ...... 79 V.1.1. Area of Influence ...... 79 V.1.2. Impact Assessment Approach ...... 79 V.2. Impacts on Physical Environmental Characteristics ...... 81 V.2.1. Impacts on Hydrogeology and Hydrology ...... 81 V.2.2. Impacts on Erosion, Land Slide and Land Use ...... 82 V.3. Impacts on Physical Environmental Quality ...... 82 V.3.1. Impacts on Water Quality ...... 82

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V.3.2. Impacts on Soil Quality ...... 83 V.3.3. Impacts on Air Quality...... 84 V.3.4. Impacts of Noise ...... 86 V.3.5. Impacts of Waste Generation ...... 89 V.3.6. Impacts on Landscape Characteristics...... 90 V.3.7. Impact of Radioactivity...... 91 V.4. Impacts on Biological Environment ...... 91 V.4.1. Impacts on Internationally Recognised Areas within the Region of the Project Area 93 V.4.2. Impacts on Terrestrial Habitat and Flora-Fauna ...... 93 V.4.3. Impacts on Aquatic Environment ...... 94 V.5. Impacts on Socio-economic Environment ...... 95 V.5.1. Impacts on the Local Population ...... 95 V.5.2. Impacts on Economy and Livelihoods ...... 95 V.5.3. Impacts on Local Public Infrastructure ...... 96 V.5.4. Community Health and Safety ...... 96 V.6. Impacts on Cultural Heritage ...... 96 V.7. Occupational/Workers Health and Safety ...... 96 V.8. Summary of the Environmental and Social Impacts and Mitigation Measures ...... 97 VI. PROJECT ALTERNATIVES ...... 101 VI.1. No Action/Project Alternative ...... 101 VI.2. Remediation Alternatives ...... 101 VI.2.1. Alternative 1: Excavation ...... 101 VI.2.2. Alternative 2: Minimizing the Erosion Effects ...... 101 VI.2.3. Selected Alternative 3: Sustainable and Long-Term Securing of the Tailings Dumpsite ...... 102 VI.3. Comparison and Assessment of Alternatives ...... 103 VI.4. Environmental and Social Assessment of Alternatives ...... 104 VII. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (esmp)...... 106 VIII. PUBLIC PARTICIPATION AND INFORMATION DISCLOSURE ...... 107 VIII.1. Previous Public Consultation for ESIA of Remediation of Five Contaminated Sites ... 107 VIII.2. General Approach for Public Consultation ...... 107 VIII.3. Public Consultation for ESIA/EIA Elaborate ...... 109 VIII.4. Public Consultation after Completion of the First Draft ESIA/ESMP ...... 110

ANNEX LIST

Annex-1 Contributors Annex-2 Environmental and Social Management Plan (ESMP)

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LIST OF TABLES

Table II.1. Gaps between the OP 4.01 and Montenegrin EIA Procedure ...... 23 Table III.1. Material Quantities ...... 37 Table III.2. Amount of Required Materials during the Construction Phase ...... 37 Table IV.1. Regulatory Classification and Categorization of Surface and Groundwater ...... 48 Table IV.2. Required Quality of Ćehotina ...... 48 Table IV.3. Comparison of Required and Established Quality Class of Ćehotina ...... 49 Table IV.4. Regulation on Classification and Categorization of Surface and Groundwater - Classes ...... 50 Table IV.5. Surface Water Measurement and Analysis Results – River Ćehotina ...... 51 Table IV.6. Leachate Quality Measurement and Analysis Results ...... 52 Table IV.7. International Union for Conservation of Nature (IUCN) Categories ...... 59 Table IV.8. Annexes to the Birds Directive ...... 59 Table IV.9. Annexes to the Habitats Directive ...... 60 Table IV.10. The List of Most Important Flora Species ...... 68 Table IV.11. List of Most Important Invertebrate Species ...... 70 Table IV.12. The List of Most Important Amphibians and Reptiles Species ...... 71 Table IV.13. The List of Most Important Bird Species ...... 71 Table IV.14. The List of Most Important Mammal Species ...... 73 Table IV.15. The List of Most Important Fresh Water Fish Species ...... 73 Table V.1 Matrix Representing Environmental and Social Impact Sources, Activities and Possible Interacts (Before Mitigation Measures Are Taken) ...... 80 Table V.2 Impact Significance Matrix ...... 81 Table V.3. Assessment of Impacts on Erosion, Land Slide and Land Use ...... 82 Table V.4. Assessment of Impacts on Surface and Groundwater ...... 83 Table V.5. Assessment of Impacts on Soil Quality ...... 84 Table V.6. Stage III B Emission Standard for Non-Road Diesel Engines ...... 85 Table V.7. List of Construction Machinery ...... 85 Table V.8. Calculated Total Emissions from Construction Machinery ...... 85 Table V.9. Assessment of Impacts on Air Quality ...... 86 Table V.10. Noise Level Guidelines of IFC ...... 87 Table V.11. Machinery and Equipment and their Noise Intensity Levels (Lw) ...... 87 Table V.12. Distribution of Noise Generated Relative to Distance ...... 88 Table V.13. Assessment on Noise Impacts ...... 89 Table V.14. Assessment of Impacts of Waste Generation ...... 90 Table V.15. Assessment of Impacts on Landscape ...... 91 Table V.16. Assessment of Impacts on Contents of Radionuclides in Surface Waters...... 91 Table V.17. Assessment of Impacts on Terrestrial Habitats and Flora/Fauna ...... 94 Table V.18. Assessment of Impacts on Aquatic Habitats and Flora/Fauna ...... 95 Table V.19. Assessment of Impacts on Economy and Livelihoods ...... 95 Table V.20. Assessment of Impacts on Community Health and Safety...... 96 Table V.21. Assessment of Impacts on Occupational Health and Safety ...... 97 Table V.22. Summary of the Impact Assessment and Mitigation Measures (before and after Project Implementation) ...... 98 Table VI.1. Advantages and Disadvantages of the Selected Alternative ...... 103 Table VI.2. Multi -Criteria Decision Analysis ...... 103 Table VI.3. Comparison of Remediation Alternatives ...... 104 Table VI.4. Environmental and Social Impacts of Alternative Projects ...... 105 Table VIII.1. Chronological Overview of Development of Previous Documentation ...... 107 Table VIII.2. Stakeholder Groups and Methods of Communication ...... 111

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LIST OF FIGURES

Figure I.1. Location of the Tailings Disposal Facility ...... 12 Figure II.1.EIA Procedure in Montenegro ...... 21 Figure III.1. Project Location together with the Mine Šuplja Stijena...... 27 Figure III.2. Proposal for Remediation of the Landfill Gradac (Preliminary design, 2018) ...... 28 Figure III.3. Detailed View of Remediation Proposal of the Landfill Gradac (Preliminary Design, 2018) ...... 28 Figure III.4. Detailed View of Remediation Proposal of the Upper Part of the Landfill Gradac (Preliminary design, 2018) ...... 29 Figure IV.1. Project Area and the Area of Influence...... 39 Figure IV.2. Geological Map of the Project Area and its Surrounding ...... 41 Figure IV.3. River Ćehotina Catchment Basin ...... 44 Figure IV.4. Seismic Map of Montenegro ...... 47 Figure IV.5. Isolines for a Return Period of 475 Years ...... 47 Figure IV.6. Surface Soil Analysis Results of Tailings Pond Site Gradac from 2011 ...... 53 Figure IV.7. Land Character Types in the Pljevlja Municipality ...... 55 Figure IV.8. Mine Tailings Disposal Site Gradac ...... 56 Figure IV.9. Map of International Recognized Areas and National Parks of Montenegro ...... 63 Figure IV.10. Map of Emerald Network Sites Areas and KBAs ...... 64 Figure IV.11. Project Location on Ćehotina Valley Emerald Site ...... 65 Figure IV.12. Ljubišnja-Montenegrin Spruce Forest...... 66 Figure IV.13. Forest Communities around the Project Area ...... 67 Figure IV.14. Road Network of Municipality of Pljevlja ...... 75 Figure V.1. Dust Generation of the Site during Windy Conditions ...... 86 Figure V.2. Distribution of Noise Generated in the Project Area with respect to Distance ...... 89

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ABBREVIATIONS

AoI Area of Influence BAT Best Available Techniques BOD Biochemical Oxygen Demand CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora CLRTAP Convention on Long-range Transboundary Air Pollution COD Chemical Oxygen Demand CETI Centre for Ecotoxicological Testing DK Draining collectors DSP Detailed spatial plan EA Environmental Assessment EHS Environmental, Health and Safety Guidelines Guidelines EIA Environmental Impact Assessment EMAS Environmental Management System EMEP European Monitoring and Evaluation Programme EMP Environmental Management Plan EQS Environmental Quality Standard ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan EU European Union EIONET European Network for Information and Observation GIIP Good International Industry Practice GIS Geographical Information System HDPE High-Density Polyethylene IA Implementing Agency IBRD International Bank for Reconstruction and Development IMS Integrated Management System IPPC International Plant Protection Convention IUCN International Union for Conservation of Nature IWMCP Montenegro Industrial Waste Management and Clean-up Project IRM Institute for Mining and Metallurgy Bor LCP Large Combustion Plants MAC Maximum Allowable Concentration MARD The Ministry of Agriculture and Rural Development MSDT Ministry of Sustainable Development and Tourism MONSTAT Statistical Office of Montenegro NEPA Nature and Environmental Protection Agency of Montenegro NGO Non-Governmental Organization OP Operational Policy PAH Polyaromatic Hydrocarbons

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PAP Project Affected People PEHD Polyethylene high density PEHD, SN4 Double layer corrugated drainage pipes made of high density polyethylene PM Particulate Matter (Dust) PMU Project Management Unit PPE Personal Protective Equipment PVC Polyvinylchloride, Plastic PVC pipes RAP Resettlement Action Plan SLMP Safety Labour Management Plan SSIP Site-Specific Implementation Plans SEA Strategic assessment of environmental impact TPP Thermal Power Plant UP Urbanistic parcel UTC Urban-technical conditions WB World Bank WQI Water Quality Index

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EXECUTIVE SUMMARY

1. Overview

The Nature and Environmental Protection Agency (NEPA) of Montenegro is implementing the Industrial Waste Management and Clean-up Project (IWMCP) with the objectives to reduce the environmental and health risks posed by selected industrial waste disposal sites, to strengthen the local institutional capacity for regulation and management of industrial and hazardous waste. The project implementation funded with financial support from the World Bank.

In this context, one of the selected sites is Mine Tailings Disposal Facility Gradac in Pljevlja. The tailings dump site originates from the activities of the lead and zinc mine “Šuplja Stijena”. The 9.5 ha facility contains 3.9 million tons of toxic flotation tailings from zinc and lead production of this mine. The facility is located on the right bank of the Ćehotina River. The overall aim regarding this facility is stabilization and recultivation of the entire tailings pond site. This aim also includes preventing the further pollution of the Ćehotina River and decreasing the pollution stress observed on the nearest settlements to the site. This Environmental and Social Impact Assessment (ESIA) Report is prepared for the Project, which is to be financed by the funds obtained from the World Bank, formulated to include:

 Stabilization of the entire site, especially focusing on the embankments  Recultivation of the site

2. ESIA Requirements

The Project is a Category A project according to the WB categorization therefore an ESIA including an Environmental and Social Management Plan (ESMP) has to be prepared in accordance with the World Bank safeguard policies (mainly OP 4.01). Previously, during the preparation of the IWMCP, an ESIA for the Purpose of Remediation of 5 Environmental Black Spots was developed in 2012. The report included an independent assessment of environmental and social impacts of remediation on feasible level of the five contaminated locations including the tailings pond site Gradac. IWMCP implementation was expected to be financially supported by the World Bank, hence the ESIA was prepared and public consultations were conducted in accordance with WB policies and guidelines.

This ESIA provides the background to the proposed Project and an assessment of the likely environmental and social impacts of the Project, both beneficial and adverse. Based on this assessment relevant mitigation measures and monitoring activities (as an ESMP) are presented with responsibilities for their implementation. In addition, alternative analysis and the previous and ongoing public consultation activities are provided. The ESIA and ESMP have been prepared in accordance with the WB requirements.

3. The Project

The contamination at Gradac tailings pond is dominated by heavy metals located in the 3,900,000 tons of waste deposit of the settlement Gradac. The area is uncovered without vegetation and the maximum and average concentrations of lead, arsenic, zinc and cadmium in the soil exceed the threshold values. The investigation has indicated reach of contaminants into the groundwater, and potential risk to drinking and irrigation water cannot be excluded. The current impact from the contaminated site at Gradac includes several negative impacts on the environment and on the social-economic environment.

Based on the available basic design/site investigation and preparation study developed on behalf of NEPA by an international consulting consortium foreseen activity includes remediation

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option comprises of in-situ slope stabilization and full encapsulation with reshaping, top cover and re-vegetation. The activities to be performed are as below:

 Soil and groundwater analysis for detecting the type and number of contaminants.  Assessment of the risk and main pathways for the contaminants through environmental matrices.  Environmental mitigation and monitoring plan development.  Main design of the remediation development.  Realization of the designed remediation project.

The Project Area is located in the borders of Pljevlja Municipality, which is located in the northern part of the Republic of Montenegro, near the Gradac settlement. Floatation tailing disposal facility Gradac is located at 17 km north-western of Pljevlja city centre, on the right bank of the river Ćehotina. The closest settlements to the Project Area are Gradac (55 m to the nearest building), Poros (540 m to the nearest building) and Podosoje (570 m to the nearest building). Gradac is connected to Pljevlja via the highway M-8, while tailings disposal site is accessibly by a local road from Gradac. The location of the site in Montenegro and general view of the facility are shown in Figure 1.

The tailings disposal facility is located on the right bank of river Ćehotina and 500 m downstream from the settlement Gradac. The site is about 30-40 km west of the Pljevlja, downstream of the river. In the northeast, east and south, the site is limited by a massif with altitudes greater than 700 m above sea level and a depression in the valley shoulders in the southeast. In the northwest, there is a peak into the valley with an altitude of 696 m asl. River Ćehotina runs west and northwest of the valley and flows from southwest to the north up to the peak.

The western and north-western slopes of the tailings deposit end directly on the river bank and are reinforced by artificial embankment dams at the foot of the slope. The northeaster and eastern part of the deposit adjoins the mountain Plana. The southern end of the pond reclines on rising ground. In between, at the southeast end, the pond is reinforced by an artificial earth dam, securing the tailings pond towards the only present housing, belonging to the inhabitants of Gradac. A natural ridge, shaped by the meandering river, extends into the tailings pond demanding the installation of two starting dams for the material deposition.

The settlement of Gradac Donji is located south of the dumpsite with the school only a few meters from the southern dam. The residents were previously employed at the mine but are now mainly unemployed. No people are permanently living within the tailing pond.

The closest settlements to the Project Area are Gradac (55 m to the nearest building), Poros (540 m to the nearest building) and Podosoje (570 m to the nearest building).

The Project’s tender processes have already been started. NEPA as an IA of the Project considers commencing construction works on September 2019. The construction works will be performed by a construction contractor, which will be determined with the tender process. It is considered that the duration of construction works will be around one year and to be finished the works on July 2020.

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Figure 1. Location of the Tailings Disposal Facility

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4. Baseline (Current) Conditions

The recent study performed on the assessment of water quality of river Ćehotina, which was conducted by Mining and Metallurgy Institute from Bor-RS, showed that the river was determined as high quality in terms of the most of the parameters other than pH, temperature and conductivity. However; the leachate forming in the tailings pond site and reaching to the river Ćehotina was also determined and it was found as high in contaminants such as lead, cadmium, zinc and fluorine.

In order to determine the soil quality, soil samples were taken from the sampling locations around the tailings pond site. The analyses results showed that the soil is rich in contaminants such as cadmium, lead, arsenic, fluorine, copper and zinc.

The recent air quality measurements conducted by CETI at Sula Settlement showed that all parameters were in compliance with the regulatory limit values. However; it is widely known that during windy conditions, massive amount of dust is generated due to the erosion observed on the tailings pond site. An example to this situation can be seen in Figure 2.

Figure 2. Dust Generation in the Tailings Pond Site

Currently there are no activities on the tailings pond site. Therefore, in the Project Area and its vicinity, background conditions prevail in terms of noise.

Anthropogenic landscape is dominant in the Pljevlja, including the Project itself. In the city and its surroundings, the impact of the urbanization and the mining-energy-industrial zone is clearly seen. Areas of tailing pond site, thermal power plant and landfills include anthropogenic elements typical of mining and industrial cities, with expressive changes in natural landscape, degradation of space and often expressive disarray in conditions of absence of recultivation

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5. Environmental and Social Impacts

The Project has various adverse environmental and social impacts. All of these impacts will be short-term – limited with the construction phase - and low in significance. As a result of the implementation of the Project, an overall significant positive impact on the environment is expected. General impacts of the Projects are summary as follow:

1. Air and dust - Main impacts of the project activities on air quality would be dust generation and exhaust gas emissions. Dust would be generated from the dry surfaces with no vegetation coverage due to wind and operation of vehicles on these surfaces. In addition, when there is excavation, hauling and storing of materials dust is a potential impact to consider. Exhaust gases would be generated by the construction vehicles/equipment. These impacts will have a local character. During the operation phase of the Project, any impacts on air environment are not anticipated. Moreover, stabilization of slopes and recultivation of the entire site will minimize the current impacts of the site on air quality, especially observed during windy conditions.

2. Soil - The potential adverse impacts of the Project on soil quality would be due to use, fuelling, maintenance and repair of the construction vehicles, waste disposal and to a rather smaller extent dust generation and dispersion/deposition of the particulates on the lands around the construction sites. These impacts would be during the construction phase only and most of them could be easily controlled with standard measures.

3. Surface and groundwater quality - The Project aims to mitigate the already existing impacts on water quality in the area, so once implemented it would have positive impacts on surface and groundwater quality. The potential impacts of the Project on water quality would be during the construction due to uncontrolled disposal of waste, potential leakage from construction vehicles/equipment maintenance and fuelling, and soils reaching the surface water as sediments. During the operation phase of the Project, main impacts might be related with the efficiency of water drainage system. Clogging of the channels should be monitored to manage this potential adverse impact.

4. Landscape: In the construction phase of the Project, active works to be performed on site will create some adverse impacts on landscape, but it would not be more powerful than the current poor aesthetics of the tailings pond site. Together with the completion of stabilization and recultivation works, the poor aesthetic image created by site itself will be eliminated. Overall, it can be said that the Project will have a beneficial/positive impact on the landscape characteristics of the region.

5. Biological Environment: There is no negative impact anticipated on the internationally recognized areas such as Key Biodiversity Areas, Important Birds Areas, and Important Plant Areas within the project region. There will be no loss of vegetation outside the project boundaries. Only direct impact would be increase in fauna disturbances and mortality by collision due to increased traffic in the region. In overall, the project itself will rehabilitate an area which creates pollution stress for terrestrial and aquatic flora-fauna. Once the project completed, positive impacts are anticipated for biological environment.

6. Socio-economic Environment: The project would not directly and significantly improve the socio-economic environment of the region. There will be limited job opportunities due to the nature of the project. In such a case, the employment priority will be given to the local dwellers. However, the project would have positive impacts on the local economy by using local suppliers during the procurement processes. It is also expected that the improvement in the environmental conditions might attract new residents to the region. The construction works will also have some negative impacts in terms of social aspects. Impacts such as increased traffic on local roads, noise nuisances, dust generation during the excavation works will have impacts on local dwellers. However, as presented in Chapter V of this

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report, most of the impacts are assessed as low in significance and easily manageable through proper mitigation measures.

6. Project Alternatives

The project alternatives for the tailings pond site Gradac were studied in the scope of this ESIA.

During development of the project framework for remediation and further operation alternatives for the Gradac disposal site, three remediation alternatives were proposed and one alternative was chosen in the extent of this project. In the scope of this project the following alternatives were evaluated.

 Alternative 1: Excavation of the tailing material and re-disposal at another dump site;  Alternative 2: Minimizing the erosion effects by partial heightening of the dam and constant water cover of the pond;  Alternative 3: Geotechnical securing and sealing of the tailings slopes, surface sealing and installation of a drainage system for snowmelt and precipitation water and construction of adequate drainage channels at the upper boundary area of the tailings pond.

Alternative 3 achieves several important goals for providing a flotation pit at the site and causes steep slopes to be re-shaped to stop the current erosion effect, especially during heavy precipitation and high-water levels. When compared to other alternatives it is more feasible in terms of environmental and social risks remediation.

7. Environmental and Social Management Plan

The environmental and social impact assessment leads us to constitute an ESMP to ensure that all adverse environmental and social impacts (identified in Chapter 5 of the ESIA report) are within the acceptable level by implementing relevant mitigation and management measures. The ESMP sets out to ensure that all aspects of the works comply with the relevant legislation, the WB requirements, permit conditions, and good international practices, The ESMP also sets out the monitoring requirements for the assessment of the effectiveness of the measures developed. The ESMP that consists of Mitigation Plan and Monitoring Plan is presented in detail in Chapter 7 of this document.

The mitigation plan presented in Chapter 7 includes mitigation for all phases (land preparation and construction, and operation) of the Project including the significance of the negative/adverse impacts before mitigation and after mitigation. Impacts left after mitigation are residual impacts and as can be followed from the detailed tables in Chapter 7 all residual negative impacts have low significance. It should be added that there are many positive impacts of the Project. Key issues/factors that are facing with negative impacts during the implementation of the Project (rehabilitation and relocation activities) and summary of the mitigation measures to manage those impacts are presented in Table 1 below.

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Table 1. Summary of the Impact Assessment and Mitigation Measures

Issue Mitigation Measures Construction Phase Erosion, Landslide and Slopes of embankments will be landscaped and planted. Land Use Erosion control measures will be taken in all areas of works against erosion risks. Driving of machinery within surface waterbodies will be prevented. Maintenance, refuel, and construction machinery cleaning will be carried out at dedicated Surface and Groundwater locations with proper containment and drainage. Resources (Water Quality) Oil and fuel will be stored in places with secondary containment. Site specific emergency plans will be prepared to respond any incidents and spillages. Parking, washing, maintenance and fuelling of the construction machinery would be done at designated sites with concrete ground and in the event that soil is contaminated by spillage, affected layer would be removed in line with the relevant regulation and internal management plans. All packaging waste material for oil and other petroleum derivatives would be stored at a designated area. Storage and handling of fuels, oils and other hydrocarbons would be done at designated areas Soil Quality with solid grounds (not soil) and located at least 50 m away from any watercourse. Opening of non-controlled and unplanned access roads to any part of the Project site will be forbidden Systematic collection of solid waste during construction (including food and material packaging, and other types of waste) would be undertaken and wastes would be disposed at licensed facilities specified by national authorities Drainage channels will be constructed in accordance with the topographical conditions of the Project Area. Frequent watering of work grounds will be done during dry periods and water intended for this purpose must be used in quantities that will not result in generation of run-off Speed limits will be enforced on the Project area and public roads to limit the levels of dust generation. Vehicles delivering material will be covered. Air Quality All vehicles, equipment and machinery used for construction will be regularly maintained and inspected/certificated to ensure that the exhaust emission levels conform to the standards prescribed. No works causing dust formation are allowed when strong wind is blowing in the direction of the settlement Gradac. Loading and unloading will be carried out without scattering Construction time will be limited to day-hours (07.00 to 19.00) Use of modern equipment and machines with noise suppressors Regular maintenance of construction vehicles and equipment Noise Avoiding the simultaneous operation of several noisy machines, when possible Using natural acoustic barriers or screens around the machines, such as trees and topographical factors, in case of a grievance Leaving engines idling at the site will be avoided unless absolutely necessary Systematic collection of solid waste during construction and operation phases will be Wastes undertaken and wastes will be disposed at licensed facilities specified by national authorities or handed over to a company authorized to collect the subject waste. Preparation of a landscape restoration plan in line with the remediation design including the Landscape realistic requirements to minimize short term visual impacts from the site operations and to maximize the long-term recovery potential of the landscape Clearing up and removal of vegetation will be minimized to the extent necessary for the execution of works, including riparian vegetation along the river Ćehotina Proper implementation of rehabilitation measures from the design which envisage the complete isolation of the deposited toxic material by a waterproofing layer (with humus) in order to restore the flora and then the fauna of the site Perform a permanent covering of cut parts of tailings pond site body with protective film in order to avoid a rinsing of the polluted loose material towards surrounded habitats. Terrestrial and Aquatic Flora Restoring the site with native plants and Fauna Set established rules for the workers on the ban on lighting fires, collecting birds' eggs, disturbing and hunting of wild animals and birds, destroying of floral species and similar Scattering of wastes with the wind within and out of the project area will be prevented by collecting and temporary storage of waste at designated areas. Vehicle speeds will be limited to prevent any accidents causing animal death and no new roads would be opened unless approved by relevant authority. Incineration or burying of wastes by any means at site and/or dumping of wastes to nearby roads or water resources will be absolutely prohibited. Community Health and The construction contractor will develop and implement a Traffic Management Plan to manage Safety traffic related risks Cultural Heritage Contractor will follow the national requirements with respect to “chance finds” which may

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Table 1. Summary of the Impact Assessment and Mitigation Measures

Issue Mitigation Measures emerge during construction. Contractor is not allowed to perform excavation, demolition, alteration or any works that may harm the properties of any cultural monument. In case of chance finds, the Contractor shall mark and secure new identified sites (with a protective railing or other means of protection) to avoid damage and immediately notify the relevant authority. The project owner and the contractor of works are jointly responsible with regard to workers health and safety. This would include both management measures and reporting and investigating any incidents, i.e. Implement international HSE standards in all contracts With regard to workers health and safety, contractor will identify potential risks before commencement of works. The emergency response provisions will include an OHS Management Plan, which will also indicate a contact person available in the event of an accident. OHS Management Plan will be submitted to the project owner for approval. Contractor will ensure the following in terms of workers/occupational health and safety: Drugs and alcohol usage are forbidden on site. Workers (Occupational) Contractor is to include a provision for safe working environment and safety measures and Health and Safety personal protective equipment (PPE) for all workers in its OHS Management Plan, including gloves, hard hats, goggles, ear protection and safety footwear. OHS Management Plan is to include a provision for first aid to be administered on site and a trained person must be engaged in line with the Law on Occupational Health and Safety (Official Gazette of Montenegro, No. 034/14). Contractor shall provide to his workers potable water supply, toilets and water supply for washing. Safety Labour Management Plan (SLMP) is required to ensure health and safety provisions Contractor shall perform all project activities following the SLMP and all Montenegrin laws and by-laws Operation Phase The project owner should develop and implement the Emergency Action Plan for all potential Emergency situations (e.g. natural disasters, failures and accidents, also covering community health and safety aspects. accidents) To avoid landslides on the slopes and embankments, technical requirements in line with the Main Design and Emergency Action Plan will be implemented In the operation phase of the Project, no adverse/negative impacts are anticipated other than Other Environmental and the emergency situations. For the operation phase, mostly monitoring activities are suggested Social Characteristics and these are presented in the Environmental and Social Management Plan (Chapter VII).

In Chapter 7, details of all necessary monitoring activities for monitoring of ambient conditions and the effectiveness of the mitigation measures are also define for relevant impacts and environmental factors. The monitoring activities for both construction and operation phases are defined. A summary of the monitoring activities for related issues are summarized in Table 2 below.

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Table 2. Summary of Monitoring Activities

Issue Parameters to be Monitored Erosion and Landslide Slope stability and relevant signs Risk Surface Water Water quality parameters (sampling and analysis) as required in relevant legislation Groundwater pH, Conductivity, CN, heavy metals Drainage water pH, Conductivity, CN, heavy metals Contamination control of surface layer in the vicinity

Soil Number of spill/leakage incidents and corrective measures taken in accordance with national and international standards and soil quality parameters (analysis) as required in relevant legislation Air Quality TSP, PM10 and heavy metals Noise Working hours and Noise levels (dB) Waste Management Waste management plan, records and temporary waste storage areas Landscape Related grievances records Flora and Fauna Survey for flora and fauna species, risk of residual contamination Socio-economy Surrounding population satisfaction , number of grievances received HS records (on accidents, employment, training) emergency preparedness plan, personnel Workers/ Occupational grievances, and periodical ESMP performance review and monitoring reports, existence and Health and Safety validity of the legal environmental and health and safety permits, Traffic Traffic management plan, selected route and time for transport of material

Monitoring records will be kept by construction contractor and NEPA. Reports will be prepared regularly to describe monitoring activities and their results (including any need for improvement and the means of achieving this). These reports will be available to relevant governmental agencies, when required, and to the public as appropriate. During the construction phase, a monthly report on the environmental and social performance of the Project will also be prepared by construction contractor or supervisor for submitting to NEPA. In this period, NEPA will also prepare quarterly environmental and social performance reports to submit WB.

8. Public Participation and Information Disclosure

IWMCP is funded by the World Bank and according to the WB Guidelines (OP 4.01), the remediation and the hazardous waste landfill projects require Environmental and Social Impact Assessment (ESIA), Environmental Management Plan (EMP) and two public consultations. With the aim of developing the document “ESIA for the purpose of remediation of 5 environmental black spots”, public consultations were held in line with the OP 4.01 including two public discussions. The first public consultation conducted for the tailings pond site Gradac was held on 10.04.2012 at 11:00 at local municipality hall of Gradac and 15 people attended to the consultation. The second one was conducted on 12.07.2012 at 15:30 at municipal administrative unit in Gradac. In addition to three representatives of NEPA and four representatives of COWI-CDM, total of six people attended to the second consultation.

Minutes were taken during both public discussions. Reports on the public consultations which were held represent one of the components of the final version of the document “ESIA for the purpose of remediation of 5 ecological black spots”.

For the ESIA studies, public consultation and disclosure of information will be conducted to ensure collaboration of local authorities, local non-governmental organizations and local affected

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community in the project area. By public consultation, some undefined advert impacts and mitigation measures can be identified and added in the Second Draft ESIA/ESMP Report.

The participation by the public in the ESIA is pertinent for the integration of the project into its socio-economic context. Timely, well planned and appropriately implemented public involvement programs will contribute to ESIA procedure and to the successful implementation, operation and management of proposals. Stakeholders was defined as those people and organizations who may affect, be affected by, or perceive themselves to be affected by, a decision or activity.

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I. INTRODUCTION

I.1. Description of the Project

Remediation of industrial waste disposal sites and management of the ongoing disposal of industrial hazardous wastes in order to reduce contamination of Montenegro’s natural resources and public health risks are among the key strategic goals of the Government of Montenegro. In this regard, the Government of Montenegro has obtained a loan (Loan No. IBRD 84280 ME) from the World Bank (WB) for the Industrial Waste Management and Clean-up Project (IWMCP) to remediate five selected industrial waste disposal sites and to manage the ongoing disposal of industrial hazardous waste. The Nature and Environmental Protection Agency (NEPA) is the Implementing Agency (IA) of the Project.

The western and north-western slopes of the tailings deposit end directly on the river bank and are reinforced by artificial embankment dams at the foot of the slope. The north-eastern and eastern part of the deposit adjoins the mountain Plana. The southern end of the pond reclines on rising ground. In between, at the southeast end, the pond is reinforced by an artificial earth dam, securing the tailings pond towards the only present housing, belonging to the inhabitants of Gradac. A natural ridge, shaped by the meandering river, extends into the tailings pond demanding the installation of two starting dams for the material deposition.

After heavy rainfall events and especially after the snowmelt in springtime, the river discharge increases significantly and heavy erosive activities in the narrow river valley can be expected to take place. The first groundwater layer forms in gravel and sandy terrace-sediments and the groundwater flow is to be expected northwest, following the direction of the river.

Conducted analysis showed that the surface of the dumpsite is contaminated with high levels of toxic metals and metalloids like lead, cadmium, mercury, and arsenic. The area is uncovered and has no vegetation. It is lacking a proper fencing; thus, it is freely accessible to humans and animals.

The entire Ćehotina river flow, riparian area and flows of tributaries are recognized as a significant area for establishing the Emerald ecological network in Montenegro, and the tailing dump site is thus situated inside the Emerald site. Approximately 10 km south-west of the site (air distance) there is another proposed Emerald network site, planned also to be declared as Regional Natural Park “Ljubišnja” which occupies part of the mountain area.

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Figure I.1. Location of the Tailings Disposal Facility

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In the present situation, the contaminated dump site has several negative impacts on the environment and on the social-economic environment. The objective of the remediation is to limit the negative impact by implementing various mitigating measures.

Based on the available basic design/site investigation and preparation study developed on behalf of EPA by an international consulting consortium foreseen activity includes remediation option comprises of in-situ slope stabilization and full encapsulation with reshaping, top cover and re-vegetation. Water management is based on prevention of infiltration into the tailings body and diversion of run-off water. Chosen alternative: Sustainable and long term securing of the tailings dump, aims for the safe enclosure of the contaminated flotation material to eliminate any release of contaminated material (seepage water, eroded material) into the environment. It includes the geotechnical securing and sealing of the tailings slopes, a surface sealing and installation of a drainage system for melt and precipitation water. The inflow of snowmelt and rain water from the surrounding mountains on the tailings pond will be minimized by constructing adequate drainage channels.

The remediation has a significant positive impact on the environment; however, during the implementation of the remediation some short-term minor negative impacts might be expected including noise, increased traffic or dust related to the construction works during implementation of the remediation.

I.2. Scope and Purpose of the Environmental and Social Impact Assessment Studies

During preparation of the Industrial Waste Management and Clean-up Project (IWMCP), the document “ESIA for the Purpose of Remediation of 5 Environmental Black Spots” was developed in 2012 by Ministry for Sustainable Development and Tourism (MSDT) and Nature and Environmental Protection Agency (NEPA). The report included an independent assessment of environmental and social impacts of remediation on feasible level of the five contaminated locations including the tailings pond site Gradac. IWMCP implementation was expected to be financially supported by the WB, hence the ESIA was prepared and public consultations were conducted in accordance with WB policies and guidelines.

Following the above mentioned ESIA study, an EIA Elaborate report is needed prepared in accordance with the Montenegrin EIA regulation. This EIA Elaborate is developed for the purpose of the remediation of the tailings pond site Gradac and will be submitted to NEPA once it is finished for approval/permit. This document included an assessment of environmental and social impacts of the entire remediation project formulation for the tailings pond site with applicable mitigation and monitoring measures to be applied during remediation works and also during operation of the landfill. Public consultation will be conducted following Montenegrin EIA legal requirements.

This ESIA study (including the development of the ESIA Report and ESMP, and conducting public consultations) has been conducted for the Project in accordance with the WB safeguard policies and procedures OP/BP 4.01 on Environmental Assessment, whereby the Project shall meet requirements of the environmental Category A – type investment standards.

This ESIA report presents the ESIA and EMP in accordance to WB requirements. The present document provides the background to the proposed remediation activities on the tailings pond site as well as an assessment of their likely environmental and social impacts, both beneficial and adverse. Proposed enhancement and mitigation measures, as well as monitoring needs, are outlined where necessary together with an assessment of responsibilities for their implementation.

The purpose of this ESIA is to:

 update and revise the ESIA prepared in the preparation phase with new information based on the development of site, activities that were undertaken since

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2012 and agreement between the Government of Montenegro and the WB on the scope of activity;  assess the likely impact that the option (and alternatives) for investment proposed by the comprehensive analysis may have on the environmental of the site and their corresponding region, social situation and public health, outside the resettlement and land acquisition measures;  identify and estimate costs related to mitigation measures and monitoring activities, including proposed staffing and training requirements related to ESMP;  ensure that the affected communities are appropriately engaged in issues that could potentially affect them;  ensure that the procedure of public consultation is carried out and documented according to the WB requirements.

I.3. Structure of the ESIA Report

The World Bank Group Environmental Policies formed the basis of the development of environmental, social and ESIA policies of the International Finance Institutions (IFIs). The general outline of this ESIA report is guided by the requirements of the WB OP 4.01 Environmental Assessment (EA) for Category A Projects1, and includes the following major headings;

 Introduction  Project description  Policy, legal and administrative framework  Baseline data  Environmental and social impacts and mitigation measures  Analysis of alternatives  Environmental and social management plan (ESMP)  Public participation  Annexes

The Project was structured around the above-mentioned main headings. The information provided in the report was detailed under these headings to the extent that the best available data allowed. Accordingly, the chapters included in the ESIA Report can be briefly explained as the following:

 Chapter I. Introduction; leads an introduction to the project and ESIA Report, providing project details and environmental and social impact studies.  Chapter II. Policy, Legal and Administrative Framework; explains national and international legal requirements, and also identified environmental agreements that are relevant to the project. It also gives an in-depth explanation on the EIA procedure in Montenegro.  Chapter III. Project Purpose and Description; is a description of the project including its location, components, technical specifications, associated construction and operation activities, and a proposed schedule for implementation.  Chapter IV. Environmental and Social Baseline Conditions; describes the baseline conditions in and around the proposed project area, including physical, biological and socio-economic conditions.  Chapter V. Environmental and Social Impact Assessment and Mitigation Measures; assesses the potential positive and negative impacts of the project, identifying mitigation measures.

1A proposed Project is classified as Category A if it is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. The impacts may affect an area broader than the sites or facilities subject to physical works. EA for a Category A project examines the project’s potential negative and positive environmental impacts, compares them with those of feasible alternatives, and recommends any measures needed to prevent, minimize and mitigate, or compensate for adverse impacts and improve environmental performance (The World Bank, 2011). DEVELOPMENT OF EIA AND UPDATE OF ESIA REPORTS FOR THE MINE TAILINGS DISPOSAL FACILITY GRADAC, PLJEVLJA Chapter I - Pg. 14/112 ESIA REPORT

 Chapter VI. Project Alternatives; is an analysis of feasible alternatives to the proposed project site, technology, design and operation, including a “no project” alternative.  Chapter VII. Environmental and Social Management Plan; describes the necessary management strategies, monitoring activities, and responsibilities for implementation of the identified mitigation measures.  Chapter VIII Public Participation, gives the detailed information about the conducted public participation meeting, sets out the comments of the community, and the results of the questionnaire,

In line with the WB OP 4.01, supplementary information, such as list of preparers and contributors, references, official letters, related reports, etc., which is relevant to the contents of the chapters listed above, will be provided in the annexes of the ESIA Report.

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II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

II.1. Legal Framework for Environmental Protection and Conservation

In Montenegro, the Constitutional Law particularly defines environmental protection. Article 1 of the Constitution, among other things, defines Montenegro as an ecological state. Article 23 of the Constitution of Montenegro defines that “everyone has the right to a healthy environment”.

The framework of the environmental legislation of Montenegro is laid down in the Law on Environment ("Official Gazette of Montenegro”, No. 52/16). The Law regulates principles of environmental protection and sustainable development, instruments and measures for environmental protection and other issues of importance for the environment.

Ministry of Sustainable Development and Tourism (MSDT) has the key role in formulation and implementation of the environmental policy in Montenegro. The Ministry performs administrative supervision over a number of institutions that are involved in environmental monitoring (Hydro-meteorological Institute, Centre for Eco-toxicological Research) and nature protection (Public Enterprise “National Parks of Montenegro”).

The Nature and Environmental Protection Agency of Montenegro (NEPA), established in 2008 and operational since 2009, is an administrative authority and ensures implementation of the environmental legislation. Its mandate includes implementation of strategies, programs, laws and regulations in the field of environment, implementation of international treaties within its jurisdiction, environmental permitting, EIA, SEA, IPPC licensing, environmental monitoring, keeping relevant registers and databases, and reporting and coordination of reporting on the state of the environment. The NEPA is also responsible for provision of information to national and international organizations and to the public. Also, as the competent authority for designation of natural objects as protected areas, NEPA is responsible for preparation and implementation of biodiversity monitoring, preparation and maintenance of an environmental database (including biodiversity data) and issuance of all types of permits relating to nature protection.

The Ministry of Agriculture and Rural Development (MARD) has major environmental competencies through its mandate in water management, forestry, fishery, and hunting.

Major steps have been taken in Montenegro during the last decade towards alignment with the EU environmental legislation, and also toward integration of environmental considerations in other policies. National Strategy on Sustainable Development was adopted in 2016. National Waste Management Plan was prepared and adopted in 2015. National Strategy on biodiversity was adopted in 2016. National Strategy on climate change was adopted in 2015. Strategic master plans on wastewater were adopted in 2004 and 2005, while their revision is expected in 2019. National Waste Management Plan for the period 2015-2020 describes the handling and management of waste in Montenegro.

II.2. Legal Framework for Health and Safety

As the key authority, the Ministry of Labour and Social Welfare of Montenegro, among other things, performs the activities related to monitoring, studying and encouraging the development of Occupational Safety and Health (OSH), preparing regulations in the field of OSH, monitoring and implementing ratified conventions and EU directives in the field of OSH, preparing professional basis for development of a national program for development of occupational safety and monitoring its implementation, and this is done through the Directorate for Safety at Work. Supervision of implementation of the Law on Safety and Health at Work (“Official Gazette of Montenegro”, No. 34/14, 44/18) and other applicable regulations is conducted by the Labour inspection, through the Labour inspectors for occupational safety and health at work, if the law does not establish that the supervision of such regulations in specific activities is performed by other authorities.

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II.3. Montenegrin/European Environmental Legislative and Permitting Framework

II.3.1. EU Directives

The following EU directives in the field of environmental legislation are fully transposed into the legal system of Montenegro:

 Directive 2001/42/EC (SEA);  Directive 2011/92/EU (EIA), which codified Directive 85/337/EEC and its amendments by Directive 97/11/EC, Directive 2003/35/EC and Directive 2009/31/EC and as amended by 2014/52/EU (EIA);  Directive 2003/4/EC (access to environmental information);  Directive 2003/35/EC (public participation and access to justice in EIA procedures and procedures for the issuance of IPPC permits);  Directive 2004/35/EC (environmental liability), as amended by the Directive 2006/21/EC (mining waste), Directive 2009/31/EC (geological storage of carbon dioxide) and Directive 2013/30/EU (safety of offshore oil and gas operations);  Directive 2008/99/EC (on the protection of the environment through criminal law);  Waste Framework Directive 2006/12/EC;  Landfill Directive 1999/31/EC;  Hazardous Waste Directive 91/689/EEC, with accessories 94/31/EC, 166/2006;  Sludge directive from wastewater treatment plants 86/278/EEC;  Waste Incineration Directive 2000/76/EC;  The Packaging and Waste Directive 94/62/EC, with accessories 2005/20/EC 2004/12/EC, 1882/2003;  Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste.

II.3.2. Horizontal Legislation

The Law on the Strategic Environmental Impact Assessment (SEA) (“Official Gazette of the Republic of Montenegro”, No. 80/05 and “Official Gazette of Montenegro”, No. 40/11, 59/11, 52/16) establishes the obligation to develop the SEA for plans and programs and other strategic documents that serves as basis for effective environmental protection and the implementation of sustainable development principles during their elaboration and in the decision-making process on final solutions.

The Law on the Environmental Impact Assessment (EIA) (“Official Gazette of Montenegro“, No. 75/18) is fully harmonized with the EU directives regulating this area. The Law regulates the EIA procedure for projects that can have a significant impact on the environment, the content of the study, the participation of interested authorities and organizations and the public, the assessment and approval process, notification of projects that can have a significant impact on the environment of another state, supervision and other issues. The EIA is intended for the projects in the field of industry, mining, energy, transport, tourism, agriculture, forestry, water management and utilities, as well as for all projects planned in a protected natural asset and in a protected environment of a fixed cultural property. The Law contains separate chapters dedicated to reporting, keeping records and providing information for inspection, also for public consultation. All the national waste facilities in Montenegro will be subject to carrying out an EIA according to the regulation.

The Law on Liability for Environmental Damage (“Official Gazette of Montenegro”, No. 27/14) defines the responsibility of the legal entity and the entrepreneur (operator) that caused damage or imminent danger to the environment. Environmental damage compensation is based on the “polluter pays” principle, according to which the legal and physical person who caused damage in the environment or imminent danger from damage must compensate for the caused danger by implementing preventive measures and remediation measures at its own expense.

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II.3.3. Nature Protection

The Law on Nature Protection (“Official Gazette of Montenegro”, No. 54/16) provides comprehensive nature protection through identification of protected areas of nature using the European typology of habitats important for the protection and establishment of an efficient system for managing protected natural assets (in line with IUCN management categories). The prescribed measures of protection will ensure the conditions for reasonable use of natural resources on the principles of sustainability, and for the benefit of present and future generations. The key novelties of this Law are providing grounds for establishing the ecological network NATURA 2000 and the NEPA is a body that, in cooperation with expert and scientific institutions, will form a database and prepare documentation for establishment of an ecological network area.

II.3.4. Air Quality

The Law on Air Protection (“Official Gazette of Montenegro”, No. 25/10, 40/11, 43/15), regulates the way of monitoring air quality, protection measures, assessment and improvement of air quality, as well as air quality planning and management. Air, as a natural value of general interest, is part of the environment and has special protection in Montenegro. Protection of air from pollution by radioactive substances, genetically modified organisms, noise and natural disasters is regulated by specific regulations. The Law prescribes that, in zones where concentrations of pollutants exceed any established marginal or target value, taking into account the tolerance limits, the Ministry in charge of environmental issues, in cooperation with the NEPA and local government authorities is obliged to pass the Air Quality Plan to reach the values as determined by the Decree on the Determination of Types of Pollutants, Limits and Other Air Quality Standards ("Official Gazette of Montenegro", No. 25/12). On the basis of the available data, the territory of Montenegro was divided in three air quality zones in 2011, whereas network for air quality monitoring was expanded to include seven automatic stations in order to meet minimum requirements set out in Directives 2008/50/EC and 2004/107/EC. All pollutants regulated in the legislation of Montenegro are monitored regularly. Air Quality data are available on-line in real time (http://www.epa.org.me/vazduh/) and annually reported to the EU through EIONET.

II.3.5. Waste Management

The Law on Waste Management (“Official Gazette of Montenegro”, No. 64/11 and 39/16) represents the legislative framework in the waste management sphere. The law describes the waste management processes, including prevention or reduction of the amount of waste, reuse of waste collection, transport, processing and disposal facilities, monitoring of these procedures and subsequent maintenance of the landfill.

Basic principles of waste management that EU waste management is based on, even though integrated in the National Waste Management Strategy and National Waste Management Plan, are still not fully applied in the system in Montenegro, particularly when it comes to the hierarchy principle which ensures compliance with the order of priorities in waste management (prevention, preparation for re-use, recycling and other recovery operations (use of energy) and waste disposal). This also applies to the management of specific waste streams in Montenegro. Systems for separate collection of municipal waste are not still established at a satisfactory level, while exportation is the only option at present for certain types of specific waste streams (e.g. waste oils). The main waste management infrastructure developed includes regional landfills of non-hazardous waste (in Bar and Podgorica), several recycling centres and also medical waste treatment facilities in Podgorica and Berane.

II.3.6. Water Quality

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Water quality is governed by an extensive legal framework, while the key legislation is the Law on Waters (“Official Gazette of Montenegro”, No. 27/07, 32/11, 47/11 48/15, 52/16, 55/16 and 02/17). The Law regulates the legal status and integrated water, coastal land and water facilities management, conditions and methods of water activity and other significant issues of management and water resources (regulates status and the ways for managing all types of water, water resources, as well as other matters of relevance for water resources management). Water management duties are under this Law assigned to a separate state administration body within the MARD – Water Administration.

II.3.7. Industrial Pollution

Control of industrial pollution is governed mainly by the Law on Integrated Pollution Prevention and Control – IPPC (“Official Gazette of Montenegro“, No. 80/05, 54/09, 42/15, 54/16). The Law regulates the conditions and procedure for issuing an integrated permit for installations and activities that may have negative effects on human health, environment or material goods. According to the Decree on types of activities and installations for which the integrated permit is issued ("Official Gazette of Montenegro" No. 07/08), the IPPC permit is not required for the Mine Tailings Disposal Site Gradac.

II.3.8. Inspections

The Project will be inspected by various national authorities either for the monitoring of the conditions or within the scope of permitting requirements. The first level of inspections will be performed by the State through the Administration for Inspection Affairs as follows:

 Ecological inspection (fulfilment of the requirement from the EIA study i.e. ecological permit)  H&S Inspection etc.

Municipal level inspections will be performed by Communal Inspection unit which belongs to Municipality of Pljevlja. The inspection subjects will be noise levels, communal order, local roads, traffic etc.

The construction inspection will be performed under by the jurisdiction of MSDT, which is responsible for the fulfilment of the requirements from Construction Permit and all other requirements prescribed by the Law on spatial planning and construction of the structures (Official Gazette of Montenegro 51/08, 40/10, 34/11, 40/11, 35/13, 39/13).

II.4. National EIA Procedure

An Environmental Impact Assessment (EIA) for certain projects is required to be carried out in Montenegro in accordance with the Montenegrin Law on EIA and associated secondary legislation. This Law and the associated secondary legislation set out the requirements for undertaking environmental assessments of potential environmental impacts of public and private projects which are likely to have a significant impact on the environment before development consent / construction permit is granted in the form of an approval for project implementation. Hence, it is required that before development consent is granted for certain types of projects, an EIA has to be carried out. The EIA process is meant to anticipate potential environmental harm and to avoid or mitigate such harm while balancing environmental, social and economic objectives. The whole EIA process includes three specific procedures. They are the following:

1. Screening as the stage of determining whether an EIA is required; 2. Scoping as the stage of determining the scope or extent of the environmental impact assessment;

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3. Review as the stage of reviewing the EIA study to see if it has been undertaken to an acceptable standard and in accordance with the legal requirements.

According to Montenegrin Legislation, the EIA Procedure is shown schematically as a flowchart in Figure II.1 below. This procedure is in full compliance with the EU EIA Directive (2011/92/EU) and the general implementation in the world. The NEPA is the competent authority for the EIA process for projects where project development consent (e.g. construction permit) is issued by a state (national) authority. The local self-government unit responsible for environmental protection is ‚the competent authority for other projects for which approvals, permits and licenses are issued by local authorities.

The types of projects that require an EIA are determined by the “Decree on determining projects for which an environmental impact assessment shall be carried out” - EIA Decree (“Official Gazette of Montenegro” No. 20/07 and 47/13). Under the EIA Decree, projects are classified in two groups (lists): projects listed in List 1 are all subject to compulsory EIA while for projects in List 2 the assessment contains an element of discretion, noting that an EIA procedure will, in any event, be required for projects with potentially significant environmental impacts. The public and other parties are to be consulted in all stages of the EIA procedure.

The Project is included in the List 1 of the EIA Decree within the point 11. (a) Installations for the treatment or removal of hazardous waste by incineration, chemical, mechanical or biological treatments as well as landfills for temporary and permanent storage of hazardous waste.

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Figure II.1.EIA Procedure in Montenegro

II.5. International Environmental and Social Regulatory Framework

II.5.1. International Treaties and Conventions

Montenegro has ratified a number of international treaties and conventions along with the ongoing process of transposing EU law into the National legal and policy framework. All treaties and conventions relevant to the Project will be considered during the elaboration of the ESIA, such as the Aarhus Convention.

The Convention on Public Participation, Access to Information and Access to Justice in Environmental Matters (Aarhus, 1998) - Aarhus convention is part of the national legal system. Its implementation started in 2009. Access to justice in respect of environmental matters is governed by several pieces of legislation, which fully transposed relevant provisions of the EU legislation governing public access to environmental information and public participation in making decisions on environmental matters, while these are also aligned with Aarhus Convention.

The Ministry of Sustainable Development and Tourism regularly updates its websites that contain all the relevant documents for access to information. Other institutions are also active in the field; local authorities, the Agency for Personal Data Protection and Access to Information and the Administrative Court of Montenegro. Dissemination of the information related to the environment is also done through the Aarhus centres in Podgorica, Nikšić, Pljevlja, Kolasin and Berane.

In addition to the Aarhus Convention, the certain number of international conventions ratified by Montenegro will be considered during the elaboration of the ESIA.

II.5.2. World Bank Group Environmental and Social Framework and Safeguard Policies

The benchmark for the assignment will be the World Bank Safeguard Policies. World Bank Policy on environmental and social protection measures are the backbone of its support to sustainable poverty reduction. The aim of these protective measures is to prevent and mitigate undue damage to people and their environment. These measures provide guidelines to the Bank and the loan beneficiary in the identification, preparation and implementation of programs and projects.

These policies include the following:

 Environmental Assessment (OP 4.01)  Natural Habitats (OP 4.04)  Indigenous Peoples (OP 4.10)  Physical Cultural Resources (OP 4.11)  Involuntary Resettlement (OP 4.12)  Forests (OP 4.36)  Safety of Dams (OP 4.37)

OP 4.01 Environmental Assessment (EA)

The Bank requires Environmental Assessment (EA) for projects proposed for obtaining the Bank support, in order to ensure that they do not have, or mitigate potential negative environmental impacts. The EA is a process in which breadth, depth, and type of analysis depend on the nature, scale, and potential environmental impact of the proposed project. The EA evaluates a project's potential environmental risks and impacts in its area of influence; examines project alternatives; identifies ways of improving project selection, siting, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and

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enhancing positive impacts; and includes the process of mitigating and managing adverse environmental impacts throughout project implementation. The EA takes into account the natural environment (air, water and land); human health and safety; social aspects; and trans-boundary and global environmental aspects.

The OP 4.01 Environmental Assessment consists of the following basic elements:

 Screening  Environmental assessment (EA) documentation  Public consultation  Disclosure  Review and approval of EA documentation  Conditionality in loan agreements  Arrangements for supervision, monitoring, and reporting

The Bank classifies the proposed projects into three major categories, depending on the type, location, sensitivity, scale of the project and the nature and magnitude of its potential environmental impacts.

1. Category A: The proposed project is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. These impacts may affect an area which is broader than the sites or facilities subject to physical works; 2. Category B: Potential adverse environmental impacts of the proposed project on human population or environmentally important areas - including wetlands, forests, grasslands, or other natural habitats - are less adverse than the Category A projects. These impacts are site specific; few if any of them are irreversible; and in most cases migratory measures can be designed more readily than Category A projects; 3. Category C: The proposed project is likely to have minimal or no adverse environmental impacts.

Depending on the project, a range of instruments can be used to meet the World Bank’s EA requirement: environmental and social impact assessment (ESIA), regional or sectoral EA, environmental audit, hazard or risk assessment, and environmental and social management plan (ESMP). EA applies one or more of these instruments, or elements of them, as appropriate. When the project is likely to have sectoral or regional impacts, sectoral or regional EA is required. For the purposes of this Project, an ESIA shall be prepared.

The OP/BP 4.01 Environmental Assessment includes the following three annexes:

 Annex A: Definitions  Annex B: Content of an Environmental Assessment Report for a Category A project o Executive summary o Policy, legal, and administrative framework o Project description. o Baseline data o Environmental impacts o Analysis of alternatives o Environmental management plan (EMP). Covers mitigation measures, monitoring, and institutional strengthening (as outlined in OP 4.01, Annex C) o Appendices (list of EA report preparers—individuals and organizations, references, record of interagency and consultation meetings, tables/figure presenting the relevant data referred to or summarized in the main text, list of associated reports (e.g., resettlement plan or indigenous people’s development plan)  Annex C: Environmental Management Plan o Mitigation o Monitoring DEVELOPMENT OF EIA AND UPDATE OF ESIA REPORTS FOR THE MINE TAILINGS DISPOSAL FACILITY GRADAC, PLJEVLJA Chapter II - Pg. 22/112 ESIA REPORT

o Institutional measures o Implementation Schedule and Cost Estimates

The ESIA report and the ESMP for the Project will be prepared in accordance with Annex B and Annex C of the OP 4.01.

World Bank Group Environmental, Health and Safety Guidelines (EHS Guidelines) – General and Sectoral Guidelines, and Guidelines on Hazardous and Toxic Materials are also the guiding documents for the studies. The Guidelines on Hazardous Materials Management apply to projects that use, store, or handle any quantity of hazardous materials (Hazmats), defined as materials that represent a risk to human health, property, or the environment due to their physical or chemical characteristics.

II.5.3. Gaps between the World Bank OP 4.01 and Montenegrin EIA Procedure

The Montenegrin requirements for the EIA procedure are quite similar to the requirements of the WB, but there are some differences which are presented in the Table II.1 below.

Table II.1. Gaps between the OP 4.01 and Montenegrin EIA Procedure

Subject Montenegrin requirements WB requirements Screening Categorization and screening is based on the Screening is based on the type, location, EIA decree with the List 1 of installations and sensitivity, and scale of the proposed project, facilities requiring an EIA and List 2 of activities identifying key issues including any resettlement for which the Ministry or local authority determine and cultural property concerns. whether an EIA is necessary. Categorization and Category 1. (significant impact) Installations and Category A: EA documentation facilities to be assessed for their impact on the Projects likely to have significant adverse content environment requiring full EIA (List 1). The environmental impacts that are sensitive study must also incorporate the comments and (irreversible). suggestions of governmental and non- Full Environmental Assessment is required, governmental organizations as well as the usually an ESIA. The Environmental and Social results of the public consultations. Management Plan (ESMP) is an integral part of Category 2. (moderate impact) the ESIA. Ministry (or local authority) screens the project Category B: and decides whether an EIA is required (List 2). Projects with environmental impacts less The law defines facilities/installations which adverse than those of category A. These undergo screening and criteria for screening, impacts are site-specific and, in most cases, such as size, cumulative impact, use of natural mitigation measures can be designed more resources, sensitivity, etc. readily than for category A projects. Scope of Environmental Assessment (EA) is usually narrower than in Category A projects. Usually, Category 3. (Low impact or no impact) only an ESMP is required. All facilities and installations below the Category C: threshold levels regulated in the EIA decree. Projects with minimum or no adverse impact. The EIA procedure is not required. No EA is required. No action is required after screening. Public consultation Public consultations are the responsibility of The borrower is required to consult project and disclosure the competent institutions. affected groups and local NGOs about the Projects from list 1: project’s environmental and social impacts and Public disclosure and public consultation will take their views into account. be held after EIA is submitted to the For Category A projects: competent authority. It is necessary to hold public consultations at Projects from list 2: least twice: (1) shortly after the screening and Projects from List 2 are made publicly before the terms of reference are finalized; and available after the documentation regarding (2) once a draft EA study is prepared. the decision on EIA procedure is made Information on the proposed objectives, project available. Depending on the screening results description and potential impacts are provided (if decision is taken that an EIA is required), for the initial public consultations. After projects from the List 2 undergo public finalizing the draft of the Environmental disclosure and public consultation, just like Assessment report, it is necessary to disclose the projects from the List 1. the document, in the local language. In addition, for Category A projects, the borrower For Projects for which an EIA is required, EIA makes the EA Report draft publicly available should be disclosed 15 calendar days prior to for project-affected people. the public consultation. The public discussion For Category B projects: shall be organized and chaired by the It is necessary to hold public consultations at

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Subject Montenegrin requirements WB requirements Competent Authority. least once during the EIA procedure. Reports are to be made available to the NGOs and project-affected people. The disclosure process is complete only after the EA report is officially received by the WB. EA review and The Competent Authority shall decide on Before formal clearance of environmental and approval granting the approval or rejecting the social aspects of the project, the WB reviews application for approval of the EIA Study, the results of the EA (especially consultations, based on the report and proposals of the EIA ESMP and institutional capacities), ensuring Commission. The Competent Authority is that the EA is consistent with the ToR. obliged to inform the organizations and public concerned about its decision. Mitigation and For projects requiring an EIA, mitigation Mitigation measures are included in the ESMP. monitoring measures and monitoring are described in the Obligation to carry out the ESMP and EIA study, which are also included in the additional measures contained in the ESMP Environmental Permit. needs to be included in the tender For other categories for which an documentation/contract. Environmental Permit is issued, measures for protection of air, water, soil, flora and fauna, Monitoring Plan is included in the ESMP. waste management etc., and monitoring, are included in the permit itself.

When comparing the WB safeguard requirements with the EIA legislation of Montenegro, the most important difference, which is significant for the Project, is related to the public consultation. According to the WB guidelines, projects in the category “A” will require two public consultations, while they only require one according to the legislation of Montenegro. Following the WB requirements, the NEPA as a borrower consults project-affected groups and local NGOs in the form and language that are understandable and accessible to the group being consulted at least twice: (i) shortly after the environmental screening; and (ii) once the draft of the EA report is prepared. The public consultation also should be provided during Project implementation (construction and operation). Gap-filling measures with the timing and detailed description of these consultations are given in Chapter 8.

II.5.4. Good International Industry Practice

Good International Industry Practice (GIIP) is defined as the exercise of professional skill, diligence, prudence and foresight that would be reasonably expected from skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally.

The WB requires borrowers/clients to apply the relevant measures (at necessary levels) of GIIP. In this context, Environmental, Health, and Safety (EHS) Guidelines are technical reference documents with general and industry-specific examples of GIIP. These General EHS Guidelines are designed to be used together with the relevant Industry Sector EHS Guidelines, which provide guidance to users on EHS issues in specific industry sectors. For this Project, use of multiple industry-sector guidelines would be necessary, such as Guidelines for Mining and Guidelines for Waste Management Facilities.

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III. PROJECT DESCRIPTION

The remediation of the mine tailing disposal facility is planned in the area of interest, cadastral plot number 5150, CM Gradac-Pljevlja. Figure III.1 shows the Project Area together with the zinc and lead mine Šuplja Stijena.

As a brief information, for the execution of the project, the project area is needed to be fenced first. On site transportation will be provided by appropriate construction machinery (bulldozers, loaders, trucks, rollers, etc.). The dynamics of the Project for each phase will be in accordance with the construction contractor's operational plan. During the construction phase, water will be provided to the employees with demijohns. Gravel and sand will be used during preparation of concrete mix using a mixer and brought to the site. During the execution of works, solid waste or waste construction material will be generated, which will be removed from the site in accordance with the regulations. Due to the operation of machines and other construction equipment, there will be emission of exhaust gases into the atmosphere, and noise and vibrations that are periodic in character will also be generated.

III.1. Basic Characteristics of Design Solution

On the basis of previous studies and variant conceptual solutions for remediation measures of the mine tailing disposal facility Gradac of "Šuplja Stijena" mine, a variant conceptual solution was selected.

The urbanistic technical conditions of No 1055-1769/9 from 30.08.2018. for the preparation of technical documentation for the reconstruction of the mine tailing disposal facility of the mine "Šuplja Stijena", Gradac, in the Municipality of Pljevlja only apply to cadastral parcel No 5150 CM Gradac.

Considering that the existing mine tailing disposal facility occupies the entire mentioned cadastre parcel, one part of the deposited material eroded out of the area of this parcel, and that the planned remediation measures require the formation of stable slopes on the mine tailing disposal facility which must be in better conditions than the current slopes, which requires reorganization of the excavated tailings on the flat part of the facility body, and then putting protective layers of materials over the tailings, and it follows that in the final the level of the recultivated terrain will be higher than the existing one for several meters, which, as a justified and rational solution, required the amendment of the urban technical conditions permitting a wider intervention for remedial measures. In this regard, the Ministry of Sustainable Development and Tourism, the Directorate of Civil Engineering, the Directorate for the Issuance of Urban and Technical Conditions with Act No. 101/2-389-435/2 has issued a supplement to the urban technical conditions permitting the subject remediation to cover the area consisting of cadastral parcels No. 13, 5146, 5148, 5150, 5166, 5380, 5384 i 5389/4, all CM Gradac, in Pljevlja Municipality

After that, by geodetic surveying and site visits, the presence of transmission lines of 35kV was identified from which two towers are located in the mine tailing disposal facility itself, and in agreement with the project owner, the final design for the relocation of the disputable towers of the transmission line was prepared, out of possible area of rehabilitation and recultivation operations of mine tailing disposal facility. Since the design is prepared on the basis of special design requirements and is not an integral part of this project, so not even the position related to the relocation of the transmission lines are considered within the design, and the rehabilitation and recultivation measures have been designed with the assumption that there are no points at the location of the disputable towers of the transmission line, i.e. that they will be moved before the remediation work.

By the hydrological and hydraulic analysis of the river Ćehotina, the consultant has reached the annual water levels of 100 on the basis of which, over the stabilization of the mine tailing disposal facility, the positioning of the stabilization dam from the gabion at the bottom of the

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planned foot of the slope of the facility is performed. Measure of dam sanation is defined over the final design of stabilization of the mine tailing disposal facility, where the cover layers of the facility are defined, with removal of the necessary thickness of the existing materials at the facility.

On the basis of this measures, the first step is to re-arrange the deposited tailings on the spot and re-forming the slopes in order to form the inclination V:H = 1:3, with two berms of width 5m and slope of 2%, on orienteering height distance from the eye approximately 8.50m, while at the bottom of the slope foot, there would be a 4.0 m gabion wall, or 5.0 m, with a stone filling.

After calculating the stability and determination of the slopes, their inclination and altitudes, the digital terrain model of new modified slopes of the facility was developed, which was done in the GCM program package in the AutoCAD environment, resulting in a quantity of material from the existing tailings that needs to be removed from the slope of the facility, in order to get stable slopes. In the next step, it was intended to redistribute the surplus material from the slopes over the flat part of the mine tailing disposal facility body, in order to achieve its levelling that would conceptually correspond to the final levelling of the recultivated facility. In doing so, it was taken into consideration that the total amount of excavated tailings from the slopes was utilised and regrouped on the flat and more stable part of the facility. The other intention was to achieve a levelling such as to reduce or eliminate the need for different thicknesses of the same cover layers over the tailings, or to avoid the need to increase the thickness of the calculated cover layers in order to achieve an adequate final levelling of the recultivated facility. In the final, levelling of the reorganized tailings which achieved the goal completely, that is the amount of excavation and embankment in the process of regrouping of tailings is completely uniform, and that all the foreseen cover layers of the material have a constant thickness equal to prescribed values, making the most rational solution possible.

During the final step considerations, the final point of the recultivated mine tailing disposal facility with all cover layers in the zone of the existing access road is fitted to the level of the existing terrain, which allows access to the recultivated facility without additional costs for the construction of a new road.

Also the same was achieved in the zone of earthen dam against the settlement, by bringing the level of recultivated facility to the level of the existing terrain before the earth dam, avoiding any interventions on it and retained in its basic form and works on the rehabilitation and recultivation of the mine tailing disposal facility, will not be jeopardize its stability.

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Figure III.1. Project Location together with the Mine Šuplja Stijena

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III.2. Project Solution of the Remediation Process

As already mentioned, the Preliminary project envisages remediation of the slopes of the landfill, which includes the formation of slopes, covering with appropriate protective layers, and the installation of a gabion retaining wall (see Figures III.2, III.3 and III.4).

The inclination of slope is planned to be 1: 3, with two berms with a berm width of 5 m, placed at every 7m of height. In some parts of the slope it will be necessary to side cut, while on other parts there will be performed backfilling and filling the existing ravine. The newly formed slopes will be covered with a multilayer protective material with a total thickness of about 2 m, which will be cultivated in the surface area.

The retaining wall, composed of gabions filled with stone, will be about 4 m high. Gabions have a dual function to stabilize the slope and prevent its erosion by the water of the Ćehotina river.

Figure III.2. Proposal for Remediation of the Landfill Gradac (Preliminary design, 2018)

Figure III.3. Detailed View of Remediation Proposal of the Landfill Gradac (Preliminary Design, 2018)

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Figure III.4. Detailed View of Remediation Proposal of the Upper Part of the Landfill Gradac (Preliminary design, 2018)

III.3. Recultivation Layers

The design solution foreseen mechanical stabilization of the reshaped slopes of the mine tailing disposal facility, while on the flat part of the mine tailing disposal facility, due to work with heavy construction machinery, the stabilization of surface area of the mine tailing disposal facility by cement is planned, with 50 cm thick layer , after which it would be putting up of the recultivation layers over a reorganized mine tailing disposal facility.

Putting following layers over reshaped mine tailing disposal facility, are foreseen, from top to bottom:

On the slopes of the dam:

 0.20m humus with suitable geocomposite for grass covering;  0.30m remediation layer of clay material;  Geotextile 500gr/m2;  0.20m filter layer;  0.30m layer of gravel;  Geotextile 500gr/m2;  0.30m protective layer;  Geotextile 300gr/m2;  HDPE geomembrane 2.5mm;  Geotextile 300gr/m2;  0.50m levelling layer

On the flat part of the mine tailing disposal facility:

 20cm humus with suitable geocomposite for grass covering;  80cm remediation layer of clay material;  Geotextile 500gr/m2;  0.50m layer of drainage material  Geotextile 500gr/m2;  HDPE geomembrane 2.5mm;  Geotextile 300gr/m2;  0.50m levelling layer;  0.50m layer of cement for stabilization of tailings

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During reshaping of the mine tailing disposal facility body, partial excavations and embankments of the natural surrounding terrain will be performed.

Excavation materials of Class III and IV should be used in the excavation sites, while the stone blocks from the excavation of materials of Class V and VI should be temporarily deposited on the construction site.

When reshaping the mine tailing disposal facility body, it is necessary to remove the eroded tailings which occupies the surface from the bottom of the mine tailing disposal facility to the river Ćehotina and install it on a flat part of the reshaped mine tailing disposal facility. This quantity is included in the quantity of tailings for regrouping in order to reshape the mine tailing disposal facility.

After performing excavations and embankments, as well as reshaping the mine tailing disposal facility, it is necessary to install a levelling layer having a thickness of 0.50m over the entire body of the mine tailing disposal facility, including the slopes, to the position planned for the installation of the gabions. The levelling layer should be properly planned according to the design profiles and should be adequately compacted, leaving a flat surface for the installation of the next layers.

Over the levelling layer, geotextile of 300gr/m2 will be placed on the entire surface of mine tailing disposal facility with prescribed overlapping and backfilling of the ends according to the details of the project. This layer of geotextile has a preventive role to protect the geomembrane against potential damage in case of contact with the material embedded in the levelling layer.

It is planned to install HDPE geomembrane of 2.5mm with prescribed overlaps over this embedded geotextile, digging and burial of the ends according to the design details and it is planned to place another geotextile layer over it. Considering the next layer for recultivation of the basins of the mine tailing disposal facility is again composed of clay material, it is planned to install geotextile of 300gr/m2 on the slopes, while on the flat part of the mine tailing disposal facility it is planned to install geotextile of 500gr/m2 and to install drainage material over it

After this, it is necessary to construct the gabion wall at the bottom of the embankment foot according to the designed profiles and levels. On the move from the gabion wall to the river Ćehotina, from which the eroded layer of tailings will be removed, it is necessary to install a layer of stone blocks. This layer is of variable thickness, but not less than 0.50m. Surplus materials of Class V and VI from the excavation of terrains should also be incorporated into this position. The use of this material would provide a faster evacuation of the high waters of the river Ćehotina, and there would be no fear of the possibility to wash and deport it by time, as would be the case with smaller materials.

In the mine tailing disposal facility, it is planned to install drainage pipes over the installed layers of geotextile and HDPE geomembrane for faster evacuation of water from recultivation layers. The main pipes with a circumference of diameter DN 250 are arranged in the section below the canal and on the slope of the mine tailing disposal facility of the flat part of the mine tailing disposal facility as well as behind the gabion wall. The auxiliary pipes are of diameter DN 200 and the water they collect are conducted in the main pipes. At critical points, it is envisaged to carry out revision holes for maintenance at the exploitation stage. All waters from drainage pipes drains downslope of the mine tailing disposal facility, next to the gabion walls and perform of concrete blocks (sprinkling heads) at the corner of the terrain where they are freely discharged into the Ćehotina river as in its natural form.

An exceptional drainage pipe is planned to be installed behind the gabion wall. It is planned to be installed in a drainage trench, filled with drainage material and all completely wrapped with geotextile.

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A further continuation of recultivation on the slopes of the mine tailing disposal facility is planned, where a protective layer of clay materials with a thickness of 0.30m is installed over another layer of geotextile of 500gr/m2. A layer of drainage is planned to be installed over the geotextile consisting of 0.30m of gravel material and 0.20cm of filter sandy layer, and another layer of geotextile of 500gr/m2. Geotextile below and above the drainage layer has a filtration function i.e. it should prevent small clay particles from penetrating the drainage layers. On the flat part of the mine tailing disposal facility, after installation of drainage pipes, drainage material is installed with a thickness of 0.50 over which a geotextile of 500gr/m2 is also installed, which also has a filtration function to prevent the penetration of fine particles into the drainage material.

A recultivation layer of clay soil with a thickness of 0.30m is installed over the drainage layer and the geotextile on the slopes while this layer on the flat part of the landfill is from excavated earth (soil) with a thickness of 0.80m.

A layer of humus of 20 cm thick is planned to be installed as final recultivation layer over the entire mine tailing disposal facility and its slopes. The only exception is the drainage trench for the pipe behind the gabion wall, over which the final layer of the crushed stone aggregate is planned. The entire surface of the recultivated mine tailing disposal facility, along with the bays, is planned for grass covering.

III.3.1. Geomembrane

Protection of the mine tailing disposal facility in terms of water tightness will be provided with HDPE geomembrane, thickness of 2.5mm, with double-sided texture, which will be placed over a buffer layer with a thickness of 0.5m.

Before placing the geomembrane, a detailed visual inspection of the surface of the buffer layer on which the geomembrane places will be performed. All objects (branches, garbage, etc.) must be removed / cleaned from the surface of the buffer layer. The geomembrane will not be spreaded and welded when the air temperature is less than 5°C or higher than 35°C, when the humidity is greater than 70% and when the wind speed is greater than 3 m/s.

HDPE geomembrane, with a thickness of 2.5mm, with double texture will be applied. Variations in the thickness of the geomembrane can be up to max 5%. The membrane will be made of polyethylene with the addition of 2-3% carbon, which must be uniformly dispersed in the polyethylene mass.

The joining (welding) of the geomembrane will be carried out by a self-moving machine for forming a double weld with a canal between the welds. Geomembranes rolls will overlap at a width of about 15 cm and be welded by heating to a temperature that is less than the melting point of polyethylene. In places where dual welding cannot be applied, a single welding with a fill can be applied.

Prior to the start of the installation of the HDPE geomembrane, it should be considered a series of facts that are very important for the further course of the works, related to the preparation and stabilization of the soil which will be the basis for the installation of HDPE geomembranes, as well as the type and technical and technological characteristics of HDPE geomembranes to be installed.

The embankment to be constructed must be completely mechanically stabilized, in order to completely eliminate the disturbance of the mine tailing disposal facility structure that can lead to serious consequences. The substrate for the installation of the geomembrane should be uniformly compacted. The asked requirements for the substrate must not be changed during the installation of the geomembrane. The maximum length of roots should not exceed 10mm. It is not allowed to install geomembrane on water saturated soil.

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During installation of geomembrane, the conditions should be as follows:

Air temperature

It is recommended to install the geomembrane at an air temperature of +5°C to +40°C. Higher or lower temperatures will have a negative effect on handling, installation and installation of geomembranes. It is also not recommended to install the protective layer at low temperatures due to the high possibility of causing damage to the geomembrane. The joining of the geomembrane is possible at low temperatures if heated tunnels are installed on the construction site. The geomembrane temperature at the joint location should not be lower than +5°C.

Wind

Since a strong wind can have a negative impact on the installation of geomembranes, i.e. on alignment of overlapping during welding and on the cleanliness of the connecting surfaces, as well as on the appearance of a suction force that can damage a series of preinstalled geomembranes, it is recommended to clean the layers that are connected and use sand bags or similar weights in order to protect layers against displacement.

Precipitation

The soaked contact surfaces that are connected during the precipitation has a significant effect on the reduction of the quality of the welded joints. During rainy season, using a protective tunnel and drying of joints by compressed air is recommended.

III.3.2. Drainage Pipes

Drainage pipes of Ø200 and Ø250 mm will be installed in the drainage trenches. These pipes will be perforated in the upper half with 4 holes of Ø30 mm at a longitudinal distance of 150 mm in a chess matrix.

The drainage pipes will be placed in the filter material, as indicated in the drawings. The pipes should lie on the layer of this material, with a minimum thickness of 20 cm, and on the upper side, covered with a layer of this material with a minimum thickness of 20 cm.

The drainage pipes will be carried out with 1% slope, with an inclination towards the downstream side.

The perforated pipe lengths are wind up before placing in the embankment with a 2x2 mm plastic mesh.

Embankment at a distance of 50 cm around and above the pipe must not be compacted by heavy means, but only by hand vibratory ramps.

The manholes are mandatory in the sewage and drainage networks at places where change of the diameter, falls, directions or angles of the connecting pipes.

To connect corrugated pipes to concrete manholes, RDS joints of appropriate diameter will be applied.

III.4. Levelling

The levelling of the mine tailing disposal facility surface is conceived so that the middle of the mine tailing disposal facility is lifted to drain water from the middle towards the periphery of the mine tailing disposal facility. As the highest point of the canal, the side is selected towards the hill

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that is in direction to opposite to the settlement and from there by the canals 1 and 2 water from the surrounding hills and from the mine tailing disposal facility body will drain along the perimeter to the slopes of the mine tailing disposal facility, down the slope, then pouring along the gabion walls and discharged as pure water directly to the river Ćehotina. Given the irregular shape of the body of the mine tailing disposal facility, in which the hill hits in around which the river Ćehotina was previously meandered (before the formation of the mine tailing disposal facility, the river was redirected over 2 hydrotechnical tunnels through the hill), a water canal 3 will be formed from the very peak of the hill toward the settlement Gradac. From the beginning of this canal, canals 4 and 5 will be formed that descend from the east and west sides of this hill to the slopes of the mine tailing disposal facility, down which descends, then pours along the gabion walls and discharges as pure water directly into the river Ćehotina. Inflow will be sent from the end of this canal into canals 1 and 2. Canal 3 will be raised in the middle, so that part of the water collected from the mine tailing disposal facility area will be fed into the canals 1 and 2, and part of the water into the canals 3 and 4.

Immediately before the end of the flat part of the mine tailing disposal facility, and the beginning of the slope of the mine tailing disposal facility, canals 6 and 7 will be formed, which have the role of reducing the amount of water that will freely flow over the slopes of the mine tailing disposal facility, which reduces the possibility of erosion of slope material.

As all layers of recultivation will have the same levelling, the aforementioned main drainage pipes DN 250 are planned to follow the route of the concrete canals i.e. they are installed exactly below them.

By means of canal 3, the system will divide the mine tailing disposal facility into two parts, so that the levelling of the mine tailing disposal facility is resolved at both parts with same principle, that is, middle of these surfaces will be elevated and water drains from the centre to the peripheral canals.

In the fitting part of the mine tailing disposal facility located on the existing access road, during the exploitation stage, construction of a reinforced concrete plate with a thickness of 0.15 m across the concrete canal is foreseen, in order to allow the access to the mine tailing disposal facility surface.

The slopes of the surface of mine tailing disposal facilities to the peripheral canals is variable so that, for the needs of performing and monitoring the works, a set of nearly 1,800 detailed points is included within the numerical documentation containing its mark, number, coordinates and level of final surface, accompanied by a graphic attachment showing the position of the given detailed points.

III.5. Land Clearance

The cleaning of the terrain includes the area of the surrounding terrain where the construction works will be performed directly, as it is defined in the design.

The cleaning of the site includes the following works:

 Cleaning of the terrain from shrubs, bushes, weeds and other vegetation including trees with extraction of roots and levelling  Cutting trees over 10 cm in diameter with classification into groups according to the thickness of the tree  Extraction of stumps, making classification and transporting to a place designated by the project owner and all the holes resulting from extraction of the stumps must be filled in with material approved by the project owner, unless excavations will be carried out at that place,  All cut material will be classified and stored in a place designated by the project owner.

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III.6. Excavation, Moving and Installation of Tailings

The organization of the technological procedure for excavation, moving and disposing of tailings is carried out with the aim of forming projected slopes and slope inclinations of mine tailing disposal facility, in order to ensure the stability of the body of mine tailing disposal facility and protection of soil and water.

Works include an organization:

 Excavation of existing tailings on all surfaces within the boundary of the captured area from which it is necessary to remove the existing waste in accordance with the design documentation.  Regrouping of all internal disposal of existing tailings on all surfaces within the boundary of the captured area from which it is necessary to remove the existing waste in accordance with the design documentation.  Installation, spreading and compaction of the transferred tailings as prescribed by the design documentation.

In addition to the abovementioned operational procedures, the construction and maintenance of all necessary construction and technological roads in the area of the existing mine tailing disposal facility is being carried out within the framework of the intervention.

III.7. Technology of the Excavation of Tailings

The excavation of the tailings is performed by mechanical or some other form of mechanized work according to the construction contractor's choice, that is, the:

 Any type of loaders,  Any type of excavators or  By any other load-excavator means intended for the site excavations and loading of bulk or pieces of materials.

Excavation by excavators, loaders or any other means includes loading of tailings into transport vehicles that carry out the transfer (transfer or transport of waste) to the site of its temporary or final disposal. Mechanical excavation and loading of tailings is carried out at one or more sites within the excavation area.

Transport of tailings from the excavation area to the temporary of final disposal site will be carried out only within the area of excavation and re-disposal area designated in the current tailings pond site

III.8. Installation of Stabilization Layer

Prior to the application of surface sealants on layers, it is necessary to improve the surface layer load (reducing the plasticity coefficient) of the flotation material - the tailings, to ensure the smooth and safe use of machines for recultivation works. For this purpose, the surface of the mine tailing disposal facility must be stabilized with cement in a layer of thickness of about 0.5 m. This stabilization measure will already significantly reduce the leakage of water into the body of the mine tailing disposal facility.

In case of a noncoherent soil (like the material in the Gradac mine tailing disposal facility) mixed with cement, in the presence of water, comes to the cement hydration, and the gluing and bonding of the granules.

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Although practically every soil can be stabilized by cement, in practice the dusty-clayey, dusty and sandy soils are more suitable than clay soils, which can be considered as a soil suitable for stabilizing by cement and low-strength cements such as PC-25 and possibly PC-35 are envisaged for this purpose

III.9. Excavation Works

All excavations will be carried out in soft material. The constructions will be conducted mechanically or manually without the use of explosives. Materials that can be classified in this category (but this does not exclude other materials) of the excavation are: sand, dust sand, alluvial material and similar materials in which the excavation can be carried out without the use of explosives. All excavations can be performed with the D-8 type of bulldozer with one riper. In addition, the excavation materials that contain free rocks and blocks with volumes less than 0.5 m3 can be extracted by a hand tool or machine. All excavations will be carried out according to the slopes given in the project or approved by the project owner.

The deposition of the excavation material shall be performed next to the excavation site or on temporary and / or permanent landfills whose locations are indicated on the drawings or are determined or approved by the project owner.

The excess excavated material will be evenly spread to the landfill (temporary or permanent). Permanent landfills will be arranged so that they look nice and fit into the surrounding topography in everything according to the instructions of the project owner.

III.10. Recultivation

The closure procedure of the mine tailings disposal facility ends with the recultivation of the terrain. Recultivation is a complex environmental measure taken to prevent surface erosion, uncontrolled rupture of the tailings, disturbances in the decomposition of the tailings and uneven subsidence of the terrain. The purpose of recultivation is the protection of the environment that is safe, ecologically and aesthetically acceptable integration of the mine tailing disposal facility area into the environment.

Works to be performed

Technical recultivation is accessed immediately after completion of works on the arrangement and levelling of the mine tailing disposal facility. Applying a fertile layer of soil with a thickness of 0.80 cm on the horizontal and 0.30 cm on the slope will follow immediately after the completion of the laying of the finishing layers of gravel and clay. The surface for technical recultivation must be completely cleaned of vegetation, stones, construction or any other waste. The earth spreading to a permanent position, according to the foregoing order, must be performed as a time unique operation, and followed immediately by biological recultivation. During these works, it must be ensured that there is no damage to the final cover - the previous layer.

The material that will be embedded represents autochthonous material from the surface to a depth of 20 cm which is obtained in the phase of works on preparatory works for borrow clay pit and temporary landfill. Filling will be done in layers, to the required thickness. The embedding and spreading of the layer may only be carried out after approval of the previous fertile layer by the project owner. After the filling, the material will be spread by the appropriate machinery on the surface of the plateau and slopes. Material embedding control will be performed visually. Visual control includes control over the thickness of the layers, methods of embedding, homogeneity of materials, harmful adds in the material, zoning of the material, cleaning and wetting the surface of the layers.

In order to complete the formation of the recultivation layers, the installation of the fertile soil layer at a height of 0.20 m on the plateau and slopes will be carried out. In this way, a layer of

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total height of 1m is obtained on a flat part, that is, 0.5m on slopes, which is necessary for recultivation. In order for the biological recultivation to be performed successfully, it is necessary to carry out the enrichment of the fertile soil layer. These works belong to agrarian technical works, and include:

 mechanical spread of mineral fertilizer by a tractor  ploughing  plating  harrowing

Biological recultivation begins immediately after the completion of technical recultivation by forming grassland. The livestock type of vegetation will favourably affect all soil properties and at the same time will be an adequate protection against erosion.

The basic processing for autumn sowing is done at a depth of 20-25 cm and at the latest twenty days before sowing, so that the soil up to sowing could subsidence. The areas for spring sowing must be ploughed in autumn and at the latest by the end of December.

During grass sowing on the plateau, a mixture of grass, i.e., grass leguminous mixture in the amount of 5 g/m2 in the mixture (50 kg/ha) selected according to the microclimate conditions of the environment, its purpose, the position of the terrain, the intensity of use and care, consists of:

 Yellow star (36%)  Jezevica (36%)  Red screw (18%)  English Swing (10%)

Work on grass covering using machinery involves the following:

 Sowing grass - leguminous mixtures, sowing depth ranges between 1-2 cm, to 50 kg/ha,  Rolling with a toothed roller of sown surfaces for the purpose of establishing of good contact between soil and seeds allowing the faster and evener germination  Sprinkling (irrigation) of planted and sown areas of grass yield (if it's a dry season) and after depending from the amount of precipitation.

III.11. Material Quantities

During the construction works, certain quantities of materials will be generated during the excavation of the land. The materials will be being excavated by machine. All this material will be used for the construction of embankments on the tailing. The amounts of excavated material is given in Table III.1.

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Table III.1. Material Quantities

Types Amount (m3) Excavation of soil Class III and IV Soil 1,534.04 Class V and VI Soil 2,301.05 Total Excavation 3,835.09 Material regrouping for the needs of reshaping the body Tailings Excavation 168,881.52 Tailings Embankments 168,890.20

Amount of required materials during the construction phase are presented in Table III.2.

Table III.2. Amount of Required Materials during the Construction Phase

Types Amount Construction of embankments from natural excavation material 1,632.92 m3 Tailings stabilization by cement on the surface of the reshaped landfill – without slopes 53,104.36 m3 Installation of the levelling layer 66,454.24 m3 Installation of the protective layer on the slopes 8,345.44 m3 Installation of gravel layer on the slopes 7,904.27 m3 Installation of the filter layer on the slopes 5,231.06 m3 Installation of the clay layer on the slopes 7,822.86 m3 Installation of drainage material 16-32 mm in a shell of geotextile 314.92 m3 Installation of aggregates 0-64 mm over the drainage canal behind the gabions 79.83 m3 Installation of stone blocks 30-50 cm from gabions to river Ćehotina 10,171.43 m3 Installation of drainage material 16-64 mm on the surface – without slopes 52,164.67 m3 Installation of soil material on the surface – without slopes 82,725.38 m3 Installation of humus on the surface, slope, and berms 25,826.42 m3 Installation of HDPE geomembrane d=2.5 mm over the surface and slope 136,300 m2 Installation of geotextile 300 gr/m2, below geomembrane on the entire surface, and 165,790 m2 above the geomembrane on the slopes 2, Installation of geotextile 500 gr/m under and above the drainage layer of the flat part, 2 272,600 m under the gravel drainage, and above the filter layer of the slope Installation of the gabion at the foot 3,000 m3 Construction of Canal 1 685 m Construction of Canal 3 250 m Construction of Canal 4 350 m Construction of Canal 5 400 m Construction of Canal 6 265 m Construction of Canal 7 140 m Construction of Canal 2 670 m Number of manholes 23 pcs Ø200 – 1,331 m Installation of drainage pipes over HDPE geomembrane Ø250 – 2,555 m Grass 19,131.10 m2

III.12. Project Duration

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IV. ENVIRONMENTAL AND SOCIAL BASELINE CONDITIONS

IV.1. Study Area and Sources of Baseline

IV.1.1. Potential Area of Influence of the Project

Potential area of influence (AoI) of the Project would include the geographical area that potential impacts of the Project could extent. In this regard, the AoI for physical and biological environment would include the Project footprint (entire floatation tailing disposal site), the upstream and downstream of the river Ćehotina. Moreover, a circular area with 500 m radius from the center of the Project Area is also taken into account for the AoI determination by considering biological extent of the Project. In terms of socioeconomic environment, the AoI would include the close-by settlements mainly Gradac, Poros and Podosoje since the Project might have direct and indirect impacts on these settlements either through job creation, improvement in environmental conditions or changes in river Ćehotina water quality. Šuplja Stijena mine is not included in the AoI since the disposal site does not accept mine tailings any more.

To sum up; the Project will have different physical, biological and socio-economic aspects. An AoI that involves all above issues is presented in Figure IV.1.

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Figure IV.1. Project Area and the Area of Influence

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IV.1.2. Sources of Baseline Data

A baseline data adequacy review has been conducted to evaluate existing data relevant to the project and project area. The adequacy of the available information has been checked for meeting the ESIA requirements and identifying data gaps. During this baseline review, firstly the existing reports and project documentation for the Project have been reviewed. In addition, the existing data has been collected from literature and related sources and institutions. The list of sources for preparation of the ESIA including sources for baseline data is given in the References of this report.

IV.2. Characteristics of the Physical Environment

IV.2.1. Topography, Geology, Hydrogeology and Hydrology of the Region

Topography

Municipality Pljevlja is located on the northern part of Montenegro and belongs to the area of high mountains. The Municipality is encompassing the area of 1,346 km2 or 9.75% of the total territory of Montenegro, which makes it the third largest municipality in the country. The Pljevlja Municipal Centre is located in the Pljevlja basin at an altitude of 770 m.

The floatation tailing disposal site is located on river bank. The western and north-western slopes of it end directly on the river bank and north-eastern and eastern parts of it adjoin the mountain Plana. In the north-west of the site, there is a peak into the valley with an altitude of 696- 697 m above sea level.

Geology

The information provided in this chapter is majorly taken from Main Design of the Reconstruction of Mine Tailings “Šuplja Stijena”, Gradac in the Municipality of Pljevlja – Notebook 2.2 Elaboration on Detailed Geological and Geotechnical Investigations. The geological map of the close proximity of the Project Area is presented in Figure IV.2.

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Figure IV.2. Geological Map of the Project Area and its Surrounding

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The geology of the wider investigation area comprises rocks of Triassic, Jurassic, Neogenic and Quaternary age.

Triassic sediments make the ground base to the western part of micro-location and its adjacent surrounding. They are represented by bedded and plated limestones with pieces of cherts and reef limestones (T22), and also by massive and zoogenically reef limestones (T2,3). In places, they are extremely tetanized and intensively karstificated. Infiller for karstification and discontinuities is clay with red limestone fragments. Thickness of limestone complex is cca 400 m. The limestones are mostly covered by clayey-deluvial debris of varying thickness, which depends on hypsometric position in the relief. Thickness of deluvial-clayey debris ranges 0.5-5.0m.

Jurassic sediments are represented by bedded gray and reddish marly limestones (J1) as well as a diabase-chert formation with volcanogenic-sediment lithologic complex of claystone, marlstone, chert, sandstone, spilite and diabase (J2+3). According to J.R. Ramponuh (1970) limestones of Early Jurassic age in surrounding of Šuplja Stijena and Gradac are layered yellow and rosy limestones with interlayers and pieces of cherts and interlayers of marlstone developing gradually from the Late Triassic limestones with cherts. The Jurassic volcanogenic-sediment (diabase-chert) formation in surrounding of Šuplja Stijena and Gradac occurs in form of zones in direction northwest – southeast. Mesozoic rocks are covered by Neogenic and Quaternary deposits.

Neogenic lacustrine sediments are distributed across the wider surrounding, not at the very micro-location. They are represented by freshwater lacustrine sediments: clays, sandy clays, clayey and sandy marlstones, marls and transition variants of these lithological members with interlayers and layers of coal.

Quaternary sediments in natural conditions are represented by: deluvial sandy-gravel material and alluvial sandy-clayey deposits. The Quaternary deposits at the very micro-location are characterized by an embankment made of mine tailings. The height of the embankment is up to 30 m. Deluvial deposits are represented by limestone pieces of various size and shape, which are sometimes bound into a slope breccia. The deluvial deposits are accompanied by screes. Alluvial deposit is found in the river valleys, being represented by gravel, sand and clay in thickness even 20-30 m.

The studied site belongs to Durmitor tectonic unit. It contains various structural forms: over- thrusts, nappes, faults, and, to lesser extent, folds. Prevalence of disjunction tectonic formations, shearing in particular, indicates the presence of intense tectonic movements in this part of the Dinarides, direction northeast-southwest.

Along the Gradac nappe, the Triassic sediments are thrusted over volcanogenic-sediment series of Jurassic age. The Gradac nappe extends from Gradojevici, where it connects with dislocation of Sula and Vrbe, over Cestin, Petin, Pracica, Gradac, Kobila and further to the southeast and Donje Tikve.

Durmitor tectonic unit is characterized by numerous faults with varying direction that are of no regional importance. Mostly, they are intraserial faults.

Hydrogeology

Hydrogeological properties and function of rock masses are a direct consequence of geological and structural composition. Wider investigation area in terms of its structural type of porosity is characterized by:

 Dense type of aquifer;  Kars-fracture type of aquifer, and  Conditionally waterless parts of ground.

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The dense-intergranular type is present in the Quaternary deposits. It is found within debris deluvial deposits and sandy-gravel alluvial deposits. Depending on presence of clay component in these deposits, they are highly to poorly permeable.

Karst-fracture type of aquifer is formed in the Triassic and partly in the Jurassic deposits. Depending on division ratio as well as orientation and linkage of fractures, they are poorly to highly permeable.

Conditionally waterless parts of the ground are represented by the Triassic limestones and formation of Jurassic diabase-chert formations in their more compact, not cracked parts. Within the Quatemary deposits, clays show impermeable properties.

Hydrological Characteristics

The mountains of Ljubišnja, Lisac and the mountain zone in the upper part of the river Ćehotina, as karst terrain in the broader zone of Boljanić and Crljenica to Jabuka are often scarce of water, and also anhydrous, and at the juncture of karst terrains with impermeable substratum, often very strong karst springs occur (at the foot of Ljubišnja, Lisac and Crni Vrh, and in smaller numbers at the foot of Mount Kovač). The yield of certain major sources is: Breznica 100 L/s (summer 60 L/s), Jugostica 10-15 L/s, Bezarsko vrelo 24 L/s, Zmajevac 43.75 L/s, Mandojevac 67.05 L/s. Considering the karst composition of the terrain, the water in the Karst hot springs Breznica and Jugoštica is subject to the occasional blurring of the excessive rainfall. In some zones (Glibaći), the lowest zones of Karst springs and bays occur.

Around the Project Area, the most important water courses are river Ćehotina and river Tara together with their tributaries.

The river Ćehotina rises at 1,045 m (asl) from a hot spring called Glava Ćehotine, which follows northwest direction for 128 km before flowing into Drina near Foca on the territory of Bosnia and Herzegovina. River Ćehotina’s catchment basin is shown in Figure IV.3.

The tributaries of river Ćehotina are Kozika (10 km), Suva Dubočica, Breznica Jugoštica (5 km), Gornja rijeka (12 km), Gotovuša, Glisnička rijeka, Kamenica (9 km), Buna (10 km), Luska Reka (12 km), Kržava River (7 km), and Šuplica (6 km) on the right side, and Maocnica (17 km), Vezisnica (18 km), Voloder (36 km), Sredenica, Koritnik (12 km), Mejdanik (8 km) and Škopotnica (17 km) on the left side of it. The lengths of left tributaries are greater than the right ones, and right tributaries majorly pass through forest areas. Therefore, the flowrates of right tributaries are greater than the left ones. The average flowrate of river Ćehotina near Pljevlja and Grac are 7.4 m3/s and 14.2 m3/s, respectively.

River Ćehotina and many of its tributaries had caused flooding events near Pljevlja until the construction of the dam was completed and Otilovici Lake was formed. Otilovici Lake is 12 km in length and has a volume of 12 million m3 with its maximum depth of 37 m. Otilovici Lake is used for the needs of a thermal power plant and water supply for Pljevlja through water treatment plant on the Velika Plijes.

River Ćehotina Catchment Area is 1296 km2 in total, which 809.8 km2 of it is in Montenegro. Average perennial precipitation in the basin is 930 mm with average discharge of 13.4 m3/s.

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Figure IV.3. River Ćehotina Catchment Basin

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IV.2.2. Erosion and Land Use

In the area of municipality of Pljevlja, various types of land with various physical-chemical characteristics and fertility are present. The most important factors influencing the formation of soil and their properties are geological background, dynamic montane relief, climate, hydrography, vegetation and humans. The relief of the Pljevlja region is abundant in various forms such as river valleys, bays, fields, ridges, steep sides and peaks. On some forms of relief there are lands of varying thickness, from shallow to karst and steep slopes, to very deep or flat terrain. Different types of brown soils are dominated in the area of Pljevlja, while alluvial soils are found in the valleys of the river Ćehotina.

The site is a floatation tailing dump site originates from the activities of the lead and zin mine Šuplja Stijena. Therefore, the site itself is typically anthropogenic land, where the previous natural layer is practically destroyed by human intervention.

IV.2.3. Climate

The Pljevlja basin has a modified moderate continental climate with characteristics of the mountain climate and it has a very small annual average level of precipitation. Winters are long and cold, summers are short and fresh, while autumn is warmer than spring. The Pljevlja basin is characterized by thermal inversions, cold air (during winter when temperatures drop below -20 °C) and radiation fog, all of which contributes to reduction of air quality in the town, especially during silent periods in winter (periods without wind) and during cold days. The Foehn is the wind which intermittently blows from the top of the mountain to the basin.

Air temperature

Pljevlja is characterized by temperature fluctuations during August, which means that the difference between maximum and minimum temperatures is high and July is the hottest month. Frosting usually ends by the end of April, and the winter in Pljevlja is two months longer than the summer. Mean monthly air temperatures in the Pljevlja region is about 9.5 °C.

Precipitation

With the average annual precipitation of 796 mm and average of 128.5 days with precipitation during the year, Pljevlja fall into the category of areas with the least amount of precipitation in Montenegro. The precipitation regime also has the characteristics of the continental climate. A large distance from the sea, as well as mountain massifs that rise up high in the central part of Montenegro represent an obstacle for the transition of humid air from the sea, thus, consequently, they affect the precipitation regime. Rain is present during the warmer part of the year (April-September). The average number of rainy days during summer is 34. In terms of the distribution of rainfall by months, it may be said that it is evenly distributed throughout the year. The driest months of the year are April and August.

Humidity, Cloudiness and Occurrence of Fog and Soot

Relative humidity of air coincides with the cloudiness of the Pljevlja area and it ranges at 70-80%. The average perennial relative humidity value is 75%; the maximum is 83% in December, and the minimum is 70% in August. Although the relative humidity of the air is high, often there are no conditions for reaching the level of condensation, so the amount of precipitation is relatively low. Cloudiness is increased during cold part of the year, while it reaches the minimum in the summer period.

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The average annual insolation value (number of sunny hours) is 1633.6 h, with the monthly maximum in July (228.9 h) and August (226.3 h), while the minimum is in December 35.4 h. Sunny days are the most frequent during summer, while gloomy days are very frequent in the period from December to March, which is also the period marked by the highest air pollution level in the valley, because a “pond” of soot is retained at the bottom of the valley due to the TPP and it covers the town. In Pljevlja, due to the basin position, the number of days with fog is increased. In this respect, the annual average is 80.8 days with fog, with the highest number of foggy days in December and the lowest in April.

Winds

Winds in the Pljevlja region is determined by the general circulation of air in this area, with certain changes under the influence of local conditions, with a special influence of the closeness of Pljevlja basin by high mountain ranges, resulting in frequent silence (74.6%). The most frequent winds are southern, with 17.5% and with average force of 3.1 Beaufort, and the northern with a 6.2% and with average force of 2.2 Beaufort. In some zones of Pljevlja region (passing towards Jabuka, the area of Kosanica, the Karst region of Ravno Cemerno), the windiness is more pronounced, with a frequent occurrence of dry frost. The northern wind brings little precipitation (mostly in the form of snow) and low temperatures, and the southern wind as one of the most expressive winds in the Pljevlja region brings rapid snow melting and temperature rise.

IV.2.4. Seismicity

The wider area of municipality of Pljevlja belongs to the seismically relatively quiet region with a degree of seismic intensity of VII-degree MCS scale (see Figure IV.4), while the level of the expected maximum soil acceleration (agmax) is 0.11, or 11% of the acceleration of the Earth's gravity within the return period of 475 years (Figure IV.5).

The relatively low level of seismic hazards in the area of Pljevlja municipality is due to the absence of intense autochthonous batch zones in that area, as well as the moderate seismic potential of the closest seismic zones of Piva and Golija in Montenegro and Sjenica in Serbia. In the area of the tailings pond site, the maximum expected degree of seismic intensity is VII-degree MCS scale, while the level of the expected maximum soil acceleration (agmax) is 0.08.

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Figure IV.4. Seismic Map of Montenegro

Figure IV.5. Isolines for a Return Period of 475 Years

IV.3. Quality of Physical Environment

The baseline environmental quality at the Project location and its surroundings is evaluated and presented in this ESIA Report based on; annual Information on the state of the environment in Montenegro as a result of the State Environmental Monitoring Program, results of measurements conducted at the site and surroundings, and measurements carried out during the preparation of main design documents.

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IV.3.1. Water Quality

Water Quality of the River Ćehotina (regular state monitoring)

The quality of river Ćehotina is regularly monitored through state measuring station. Determination of the water quality class has been performed by comparing the relevant values of water quality parameters with the limit values in the Regulation on classification and categorization of water (Official Gazette of Montenegro 2/07). By purpose, water is divided into water that can be used for; drinking and food industry, water that can be used for fishery and shellfish farming and water that can be used for bathing (see Table IV.1).

Table IV.1. Regulatory Classification and Categorization of Surface and Groundwater

Type of Water by Purpose Class of water Water Characteristics Waters that are in natural condition, with possible Class A disinfection, can be used for drinking Waters that can be used for drinking after a simple physical Class A1 Waters that can be used for drinking treatment and disinfection and food industry Waters that can be used for drinking after proper Class A2 (based on the limit values of 50 conditioning (coagulation, filtration and disinfection) parameters and are classified into Waters that can be used for drinking after intensive four classes) physical, chemical and biological treatment with prolonged Class A3 disinfection and chlorination, i.e. coagulation, flocculation, decantation, filtration, active carbon absorption and ozone or chlorine disinfection. Waters that can be used for the cultivation of precious fish Water that can be used for fishery Class S species (salmonidae) and shellfish farming Class Š Waters that can be used for shellfish farming (are classified according to 10 Waters that can be used for the cultivation of less precious parameters in the class) Class C fish species (cyprinids) Class K1 – excellent, Water that can be used for bathing Water that can be used for bathing Class K2 – satisfactory

Regulation on Classification and Categorization of Surface and Ground Water has established Environmental Quality Standard (EQS) values for all main rivers in Montenegro, in the format AnSnKn where: code A is a category for water representing basic physico-chemical standards, S, Š or C is the assessment for fisheries water and K is the assessment for bathing water. According to the quality of water that needs to maintain or provide for achieving good status of water, river Ćehotina is classified as presented in Table IV.2.

Table IV.2. Required Quality of Ćehotina

River Water body Classes Category Upstream of Pljevlja A1, S, K1 I Ćehotina Downstream of Pljevlja A2, C, K2 II

During 2017 Ćehotina River was sampled in 4 locations and its waters should belong to the A1SK1 class upstream of Pljevlja (Rabitlja) and A2CK2 downstream of Pljevlja (after the confluence of the river Vezisnica and tailing pond Gradac). This watercourse in the part of Pljevlja has been polluted for many years, and data from 2017 confirmed this. Even the upstream part of the watercourse before Pljevlja has pollution, and from certain classes of quality, the prescribed class was 62.4%, and 28.2% were outside the required class and 9.4% out of all classes. The worst situation was in places below the town and below the mouth of Vezisnica, where 42.7%, and 46.8% of certain classes were out of class: Ca/Mg ion ratio, saturation oxygen percent, BOD5, COD, phosphate and nitrite, TOC, phenols and significantly contaminated with coliform and fecal bacteria (bathing class and fish life). This data suggests that Ćehotina is under pollution stress due the sewage waters of the city and contaminated lands such as tailing pond site Gradac.

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Table IV.3 provides comparison of required and established quality class of Ćehotina per parameters.

Table IV.3. Comparison of Required and Established Quality Class of Ćehotina

Watercourse Ćehotina Below the Below the city Measurement profile Rabitlja confluence of Gradac Pljevlja Vezišnica River Required class A1S K1 A2C K2 A2C K2 A2C K2 pH A A A A

Electrical conductivity A1 A1 A1 A1 Ca / Mg ratio Out of all classes Out of all classes Out of all classes Out of all classes Suspended parts A1, S A2, C A3, C A2, C Turbidity A1 A2 A3 A2 Temp C° A2 A2 A2 A2

PER PARAMETER PER

- % saturation A Out of all classes Out of all classes A3 O2 S, Š S, Š C, Š S, Š BOD5 A3 Out of all classes A3 A3 COD A2 A2 Out of all classes A3 Iron A1 A2 A3 A2

BLISHED CLASS CLASS BLISHED Ammonia A2, S Out of all classes Out of all classes Out of all classes Chlorides A A A A

ESTA Sulphates A1 A2 A3 A2 Phosphates A2 Out of all classes Out of all classes Out of all classes

The established water quality class of the river Ćehotina during 2017 are provided in detail in the Environmental Yearbook VIII-17, Hydrometeorology and Seismology Institute (ref: http://www.meteo.co.me/ekologija/VODE%202017.pdf).

Water Quality of River Ćehotina (results of monitoring campaign)

Water quality of river Ćehotina was assessed in September 2018 by Mining and Metallurgy Institute from Bor-RS. The sampling locations were selected as upstream (Br-1) and downstream (Br-2) of leachate influx. Then, the measurement and analysis results were compared with Maximum Allowable Concentration (MAC) values stipulated in Regulation on Classification and Categorization of Surface and Ground Water. While the regulatory MACs are presented in Table IV.4, measurement and analysis results are given in Table IV.5.

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Table IV.4. Regulation on Classification and Categorization of Surface and Groundwater - Classes

MAC – Classes Parameters Unit A A1 A2 A3 pH - 6.80-8.30 6.80-8.50 6.50-8.50 5.50-9.00 Electrical Conductivity µS/cm 300 400 600 1000 Temperature °C 8-12 9-12 30 30 Dissolved Oxygen mg/L - - - - As mg/L 0.001 0.010 0.05 0.05 Pb mg/L 0.001 0.010 0.05 0.05 Cd mg/L 0.000 0.001 0.005 0.005 Cr(total) mg/L 0.000 0.000 0.05 0.05 Cu mg/L 0.005 0.02 0.05 1 Ni mg/L 0.002 0.002 0.05 0.100 Hg mg/L

Fenol Indicator – C6H5OH mg/L 0.0005 0.001 0.005 0.01

NO3 mg/L 10 20 25 50

NO2 mg/L

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Table IV.5. Surface Water Measurement and Analysis Results – River Ćehotina

Sampling Locations Parameters Unit Br-1 Br-2 Before Leachate Influx After Leachate Influx pH - 7.38 6.79 Electrical Conductivity µS/cm 3870 4130 Temperature °C 15.8 15.5 Dissolved Oxygen mg/L 14.7 14.4 As mg/L <0.0021 <0.0021 Pb mg/L <0.0027 <0.0027 Cd mg/L <0.00014 <0.00014 Cr(total) mg/L 0.002 0.0019 Cu mg/L 0.008 0.008 Ni mg/L <0.0036 <0.0036 Hg mg/L <0.0005 <0.0005 Ba mg/L 0.0111 0.0111 Zn mg/L <0.005 0.008 F mg/L <0.02 <0.02 Fe mg/L <0.007 <0.007 Co mg/L <0.0001 0.008 Mg mg/L 2.9 3.5 Sn mg/L <0.001 <0.001 CN mg/L <0.01 <0.01 PAH mg/L - - THC mg/L 0.500 0.500 PCB mg/L <0.0005 <0.0005

Fenol Indicator – C6H5OH mg/L <0.01 <0.01

NO3 mg/L 0.6 0.7

NO2 mg/L 0.002 0.003

The water quality of river Ćehotina before and after leachate influx from tailings pond is determined as A and A1 for most of the parameters; except for pH, temperature and conductivity. The conductivity value exceeds the MAC value for A3 class.

In addition to the surface water samplings, a sampling campaign was also performed for the assessment of the quality of leachate forming in the tailings pond site. In order to fulfil this aim, three samples were taken from three boreholes drilled on the tailing pond site and two samples were taken from drainage channels collecting leachate and run-off water and flowing into the river Ćehotina. The analysis results are compared against the reference values stipulated in the Regulation on the Quality and Sanitary-Technical Conditions for the Discharge of Wastewater into Receiving Body and Public Sewerage (Official Gazette of Montenegro, 45/08). The analysis results together with regulatory limit values are presented in Table IV.6. The parameters that are not in compliance with the regulatory MAC are indicated with red font colour.

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Table IV.6. Leachate Quality Measurement and Analysis Results

Sampling Locations Regulatory Parameters Unit Br-1 Br-2 B-5 B-8 B-11 Drainage Drainage MAC Channel Channel pH - 5.58 5.51 5.29 2.77 2.78 6.5-8.5 Electrical µS/cm 5620 7670 4330 8730 8660 - Conductivity Temperature °C 16.3 16.7 14.6 24.7 25.0 30 Dissolved Oxygen mg/L 3.5 5.6 7.20 13.2 11.9 - As mg/L 0.007 0.0045 <0.0021 <0.0021 <0.0021 0.1 Pb mg/L 0.68 2.616 1.05 1.983 1.943 0.5 Cd mg/L 0.11 0.159 0.277 0.0024 0.0024 0.01 Cr(total) mg/L <0.0017 <0.0017 <0.0017 0.0047 0.0047 1.25 Cu mg/L <0.005 0.1 <0.005 0.1 0.1 0.5 Ni mg/L 0.567 1.129 0.633 <0.0036 <0.0036 1.25 Hg mg/L <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 0.005 Ba mg/L 0.0168 0.0074 0.011 0.064 0.0722 3.0 Zn mg/L 226.1 0.417 509.7 3.1 3.0 1.0 F mg/L 1.61 3.10 0.72 0.24 0.26 2.0 Fe mg/L 1589.5 2.167 630.1 4.8 2.4 2.0 Co mg/L 0.380 0.682 0.480 0.0033 0.003 1.0 Mg mg/L 369.3 0.573 285.7 3.4 2.9 - Sn mg/L <0.001 <0.001 <0.10 <0.001 <0.001 0.75 CN mg/L <0.10 <0.10 <0.10 <0.10 <0.10 - PAH mg/L <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 - THC mg/L <0.005 <0.005 <0.005 <0.005 <0.005 - PCB mg/L <0.0005 <0.0005 <0.0005 <0.0005 <0.0005 - Fenol Indicator – mg/L <0.01 <0.01 <0.01 <0.01 <0.01 - C6H5OH

NO3 mg/L 0.0022 <0.1 <0.1 0.003 0.004 -

NO2 mg/L <0.1 0.85 <0.1 2.90 1.90 -

As seen from the above, leachate formed in the tailing pond site is rich in contaminants such as Pb, Cd, Zn, F and especially Zn and Fe.

Although the river Ćehotina water quality assessment as class A and A1, the overall water quality campaign results show that the surface waters in and around the Project Area and leachate reaching to the river Ćehotina have toxic characteristics.

IV.3.2. Soil Quality

Soil Quality around the Tailings Pond Site Gradac

In Montenegro, the program for the testing of harmful substances in the soil has been implemented since 1999 in accordance with the Environmental Law and the Ordinance on permitted quantities of hazardous and harmful substances in the soil and methods for its examination (Official Gazette of the Republic of Montenegro 18/97). In this program there are two types of soil monitoring campaigns have been led by State, which are the monitoring of soil contamination by hazardous substances and the monitoring of soil quality. Soil contamination monitoring is still in place to monitor agricultural land near motorways, landfills and industrial DEVELOPMENT OF EIA AND UPDATE OF ESIA REPORTS FOR THE MINE TAILINGS DISPOSAL FACILITY GRADAC, PLJEVLJA Chapter IV - Pg. 52/112 ESIA REPORT

facilities. The municipality of Pljevlja is one of the municipalities that have the highest number of sampling locations.

In 2012, 2013 and 2014; soil contamination monitoring campaign was conducted near the tailings pond site by CETI within the National Program for Land Monitoring (NEPA). The analyses were carried out on all metals, metalloids, PAHs, PCBs, TPH, pesticides and dioxins and furans. The analysis results showed that:

 Cadmium concentration is 3.2 to 3.5 times greater than MAC  Lead concentration is 40 to 800 times greater than MAC  Arsenic concentration is 2.25 to 2.50 times greater than MAC  Fluor concentration is 1.50 times greater than MAC  Copper concentration is 2.40 to 3.50 times greater than MAC  Zinc concentration is 7.50 to 100 times greater than MAC  The other parameters were significantly lower than MAC.

Quality of Sediments

In 2009 during Study “0” conducted for the Šuplja Stijena’s environment, sediment samples were taken from the two tributaries, which are Mednjicki and Ribnicki. The analysis results of the samples show that the sediments were extremely high in arsenic, lead, cadmium, zinc and iron concentrations. Since there is no Montenegrin regulatory MAC for sediments, the obtained concentration values were compared against the Italian legislation’s Environmental Quality Standard (EQS) values. The comparison showed that arsenic, lead and cadmium concentrations were more than ten times greater than the EQS. Mercury concentration also exceed the EQS.

Quality of Disposed Waste Material

Analysis on the deposited material at the tailings pond site was carried out throughout several location from the surface layer and wells up to 30 m.

In 2011, within the context of “Field research and preparatory study for the remediation of industrial landfills in Montenegro” project, CETI carried out detailed tests. 10 samples from the surface layer were analysed and leaching test was also performed. The findings of the study are given in Figure IV.6.

Figure IV.6. Surface Soil Analysis Results of Tailings Pond Site Gradac from 2011

In 2018, a sampling campaign was conducted within the context of IWMCP Main Design of the Reconstruction of Mine Tailings “Šuplja Stijena”, Gradac in the Municipality of Pljevlja to assess the quality of dumped material. The samples were taken from 3 boreholes for every 2 meters up to 30m depth. The analysis results are compared against the MACs stipulated in the Regulation on the Limit Values of Polluting, Harmful and Hazardous Substances in Land (Official Gazette of Republic of Montenegro, No 15/92). The analysis results showed that As, Pb, Cd, Cr, Cu and Zn were mostly greater than the MAC.

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IV.3.3. Air Quality

The territory of Montenegro consists of three zones of air quality. In accordance with the requirements of the European and Montenegrin legislation, the air quality zones are reconsidered every 5 years. Pljevlja is located in the northern critical zone, and it is necessary to improve air quality in this zone.

Air quality monitoring for sulphur dioxide, nitrogen (IV) oxide and suspended particulates (PM10 and PM2.5) in Pljevlja was monitored in the period from 2014 to 2018. An automatic stationary station was installed in Skerliceva Street in Pljevlja. The measuring station is moved to the new location - Gagovica estate, in December 5, 2016.

Air Quality Monitoring in Pljevlja in the Period 2014-2018

Air quality in the city is mostly affected by the high content of suspended particles (dust), high concentrations of smoke and soot (especially during the winter period) as well as high concentrations of PAH (benzo(a)pyrene) in floating particles of ash, smoke and soot, which are carcinogenic substances. The results of the monitoring implemented by the NEPA, indicate that besides industrial sources, city and individual combustion plants contribute to air pollution in the area.

The results of these analyses in Pljevlja are given in the monthly reports of the Center for Ecotoxicological Testing d.o.o. for the period from January 2014 to July 2018. Pljevlja, as an industrial center, is characterized by seasonal variation of the concentration of SO2, nitrogen oxides and PM particles. The high impact of individual combustion plants on air quality during the heating season is best seen from these results. The results show that the concentrations of these parameters in the air during the heating season are considerably higher than the concentrations from May to September.

Air Quality Monitoring in the Vicinity of Gradac

Air quality at the Gradac is no longer monitored within the State Monitoring Program. The latest air quality monitoring of Gradac was conducted within Study “0” of Šuplja Stijena in 2009. Based on the request of the company responsible for the operation of the mine, CETI carried out emission measurements at Sula settlement with the aim of examining the impact of Šuplja Stijena. The following tests were carried out:

1. Seven-day measurements were performed with mobile automatic monitoring station equipped with sensors for the measurement of sulphur dioxide, nitrogen monoxide, nitrogen dioxide, total nitrogen oxides, ozone, carbon monoxide, PM10 particles, benzene, ethylbenzene, m-xylene, p-xylene, o-xylene, toluene and meteorological parameters such as atmospheric pressure, air temperature, humidity, wind speed and direction of wind 2. 24-h sampling of Total Suspended Particles (TSP) and analysis of metal content of the samples.

Emission measurement results showed that none of the measured parameters exceeded the limit values stipulated in the Decree on Determining Types of Pollutants, Limits and Other Air Quality Standards (Official Gazette of Montenegro, 45/08) and The Rulebook on Deadlines and Measurement of Air Quality (Official Gazette of Republic of Montenegro, 4/82).

IV.3.4. Noise

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Currently, there are no activities on the tailing pond site. Therefore, in the Project Area and its vicinity background conditions prevail in terms of noise. The most recent measurement of noise levels in the vicinity of tailings pond site Gradac was performed in 2009 by CETI during Study “0” of the state of Šuplja Stijena mine and the measured noise levels were in compliance with the limit values stipulated in the Rulebook on the methods of calculation and measurement of the environmental noise level (Official Gazette of Montenegro, 27/14).

IV.3.5. Landscape Features

In the Spatial Plan of Montenegro, the wider area of Pljevlja belongs to the Mountain landscape type and "Pljevlja area" unit. The greater part of Municipality Pljevlja belongs to the area of high mountains with altitude between 1400 and 2200 meters asl (Ljubisnja, Kovac, Gradina, Klik, Crni Vrh, Mihajlovica, Ravna Gora, Stozer, Bunetina). The lower parts of the relief are represented by Kosanica, Jabuka and fields (Maocko, Matarusko, Otilovicko, Pljevljsko, Brvenicko, Glisnicko and Racevicko) in the Basin of Ćehotina River (Figure IV.7).

The largest karst field in the basin of the Ćehotina River is Pljevaljsko field, which has an area of 16 km2. Through the central part flows the Ćehotina River that is the basic feature of this and much wider area. The limestone heights of the Pljevljsko field - Velika Plijes, Mala Plijes and Ilino hill represent an exhumed relief and together with the Rabitljanska epigenia make a special value of the relief of this region. The Pljevaljsko field is a part of the larger area of the Pljevlja basin. This basin has an area greater than 30 km2 of a quadrilateral shape and extends in the north-south direction.

Figure IV.7. Land Character Types in the Pljevlja Municipality Anthropogenic landscape is dominant in the area of Pljevlja. In the city and its surroundings, the impact of the urbanization and the mining-energy-industrial zone is clearly seen. Areas of tailing pond (Figure IV.8), thermal power plant and landfills include anthropogenic elements typical of mining and industrial cities, with expressive changes in natural landscape, degradation of space and often expressive disarray in conditions of absence of recultivation.

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Figure IV.8. Mine Tailings Disposal Site Gradac

The largest open-pit mining Potrlica is the central part of the Ćehotina basin. The consequences of coal mining are open-pit mining and landfills. Some parts of the relief are recultivated, others are still degraded. The quality of landscape within a specific area is important for both physical and mental health of the people, and therefore has an exceptional ecological significance. Due to degradation of soil during construction of the landfill, a micro-relief was changed and, consequently, microclimate. The absence of forests and green areas affects the increase of soil temperatures, and there is also the presence of strong winds and frequent fogs in the winter period. Such changes in microclimate affect the organization of the work of the surrounding population engaged in agriculture, fruit growing and cattle breeding.

Final recultivation of mine tailings disposal facility will be of great ecological significance. This will contribute to reduction of air pollution, slowing down speed of wind blows, mitigating extreme temperatures, reducing high levels of underground and capillary waters, protecting against excessive insolation, reducing slip and preventing soil erosion, enhance visual landscape of area, calming effect on people's psyche and in providing active and passive recreation.

IV.3.6. Radioactivity

Measuring levels of radioactivity, which occurs in the environment through natural or artificial processes, is important for human health and environment. Radioactivity measuring is realized in line with the national Program of systematic testing of radionuclide content in the environment, pursuant to the regulations.

Radioactivity analysis of the mine tailings disposal site was performed in 2009 by CETI within the scope of Study “0” and the analysis showed that the activity of the radionuclides was below the maximum allowed values for all the analysed radionuclides, which is in line with the provisions of the Article 23 and Article 24 of the Rulebook on the limits of radioactive contamination of the environment and decontamination procedure (Official Gazette of FRY, No: 9/99, 1/2003). Additionally, analysis results were also below the limit values defined for letting out and discharging, in line with the provisions of the Article 9 and Article 15 of the Rulebook on methods of

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collecting, keeping, processing and storing of radioactive waste (Official Gazette of Montenegro, No:058/11).

IV.4. Ecology and Biodiversity

In order to evaluate the baseline conditions and the potential impacts of the Project on the biological environment and various species inhabiting natural habitats around the Project Area, both the terrestrial and aquatic ecosystems were studied to identify the existing biological conditions.

In the scope of the biological studies for the Project biological environment studies which included terrestrial flora and fauna, aquatic environment, national and international designated areas have been conducted with desktop studies which described in detail in the following sections. The assessment follows the recommendations and requirements of the IFC Performance Standard 6 (PS6): Biodiversity Conservation and Sustainable Management of Living Natural Resources and OP 4.04 Natural Habitats definitions.

IV.4.1. Definition of Study Area and Impact Area

Project area is located in Gradac, which is a small settlement in Pljevlja Municipality of northern Montenegro. The tailings pond site is on the north of Gradac and covers its north eastern, eastern and southern borders. The tailings pond site is enclosed by a mountain massif whose altitude exceeds 700 m, whilst at south east it is bordered by the valley. River Ćehotina runs from west to northwest of the valley. The only permanent watercourse in the immediate vicinity of the site in Gradac is river Ćehotina.

Lead and zinc mine Šuplja Stijena floatation tailings have been stored in the tailings pond site since 1954. Therefore, the vegetation structure of this region has disappeared for 65 years. Wild animals in the region have been moved away due to especially vegetation loss within the boundaries of the tailings pond site, human pressure and wastes.

Since the Project's biological inventory studies were carried out by the means of desktop studies, the regions closest to the Project Area were examined. In this context, the study area is defined as Pljevlja Municipality and Ljubišnja region in order to reach realistic information about Project Area. Pljevlja is located away 17.3 km southeast of the Project Area and Ljubišnja is located away 9.6 km south-western of the Project Area.

The project is a rehabilitation project that will be realized for the benefit of nature. Upon completion of the project, the already seriously deformed tailings pond site will be rehabilitated. At this stage, the effect will be very limited and can be eliminated. For this reason, the impact area of the project in terms of biodiversity is determined as a circle with 500 m radius from the borders of the Project Area and upstream and downstream of river Ćehotina (see Figure IV.1).

IV.4.2. Assessment Methodologies and Data Sources

The ecology assessment has considered relevant Montenegrin (national) legislation, applicable standards and guidelines for international finance, and international agreements. Applicable policy and legislation relevant to the ESIA are presented in Chapter II-Policy, Legal and Administrative Framework with those of particular relevance to ecology summarized below.

Internationally accepted criteria are considered while determining study area together with the species characteristic and habitat needs. Potential critical habitats in the Project Area were identified as well. This were done by overlaying the Project Area with the distribution of species of conservation concern; with sites identified as globally important for migratory species (e.g. IBAs, Ramsar sites); with national parks and key biodiversity areas.

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International Agreements

In evaluating the threat/protection status of species; CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora), Bern Convention, and IUCN (International Union for Conservation of Nature) Red List Database were used.

Species covered in CITES are given under three different appendices according to their conservation status. Appendix I cover the species, which are under the threat of extinction. Trade in the specimens of these species is not allowed except extraordinary circumstances. Appendix II includes species, which are not threatened with extinction, but trade in specimens is restricted in order to prevent utilization incompatible with their survival. Appendix III includes species, for which other parties of CITES is applied for assistance in controlling trade and which are conserved at least in one country.

BERN Convention aims at conserving and promoting biodiversity, developing national policies for the conservation of wild flora and fauna and their natural habitats, protection of the wild flora and fauna from the planned development and pollution, developing trainings for protection practices, promoting and coordinating the researches made regarding this subject. It has been signed by 26 member states of the European Council (as well as Montenegro) with the aim of conserving the wild life in Europe. Species that are protected under the Bern Convention are classified according to the following categories:

 Appendix I: Strictly protected flora species  Appendix II: Strictly protected fauna species  Appendix III: Protected fauna species

All the nations, which are party to the BERN Convention, have signed the Convention on Biological Diversity as well. These parties are responsible from ensuring sustainable use of resources in line with their national development trends and conserving threatened species.

To determine the threatening status of species IUCN classifications are also used, which are used in Montenegrin classification as well. IUCN Red List is published to highlight those species that are facing a risk of extinction. A species may be listed in IUCN Red List after studies on its population decrease. Thus, since IUCN List is based on research (annual updates are being made for species lists of countries), many countries attach more importance to species taking place in IUCN list than species taking place in Bern List. The IUCN categories were updated in 2001 as ver. 3.1 (previous one was 1994 as ver 2.3) and are provided in Table IV.7.

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Table IV.7. International Union for Conservation of Nature (IUCN) Categories

IUCN Red List Categories and Criteria, 1994 IUCN Red List Categories and Criteria, 2001 (ver. 3.1) (ver. 2.3) EX : Extinct EX : Extinct EW : Extinct in Wild EW : Extinct in Wild CR : Critically Endangered CR : Critically Endangered EN : Endangered EN : Endangered VU : Vulnerable VU : Vulnerable LR : Low Risk cd : conservation dependent NT : Near Threatened nt : near threatened LC : Least Concern lc : least concern DD : Data Deficient DD : Data Deficient NE : Not Evaluated NE : Not Evaluated

The Birds Directive (2009/147/EC)

Directive 2009/147/EC of the European Parliament and of the Council of 30 November 2009 on the conservation of wild birds (this is the codified version of Directive 79/409/EEC as amended). This Directive ensures far-reaching protection for all of Europe's wild birds, identifying 194 species and sub-species among them as particularly threatened and in need of special conservation measures. There are number of components to this scheme (EC, 2014a), such as:

 Member States are required to designate Special Protection Areas (SPAs) for 194 particularly threatened species and all migratory bird species listed in Annex I of the Birds Directive. SPAs are scientifically identified areas critical for the survival of the targeted species, such as wetlands. They are part of the Natura 2000 ecological network set up under the Habitats Directive 92/43/EEC.  A second component bans activities that directly threaten birds, such as the deliberate killing or capture of birds, the destruction of their nests and taking of their eggs, and associated activities such as trading in live or dead birds (with a few exceptions).  A third component establishes rules that limit the number of bird species listed in Annex III, which can be hunted (82 species and sub-species) and the periods during which they can be hunted. It also defines hunting methods which are permitted (e.g. non-selective hunting is banned).

The annexes to the Birds Directive are presented in Table IV.8.

Table IV.8. Annexes to the Birds Directive

Annex Explanation Species subject to special conservation measures concerning their habitat in order I to ensure their survival and reproduction in their area of distribution Species may be hunted under national legislation. Member States shall ensure II that the hunting of these species does not jeopardize conservation efforts within their distribution area Species whose sale, transport for sale, keeping for sale and the offering for sale of live or dead birds and of any readily recognizable part or derivatives of such birds III is not prohibited provided that the birds have been legally killed or captured or otherwise legally acquired.

The Habitats Directive (92/43/EEC)

The Habitats Directive 92/43/EEC was adopted in 1992. The main aim of this Directive is to promote the maintenance of biodiversity, taking account of economic, social, cultural and regional requirements. While the Directive makes a contribution to the general objective of sustainable development; it ensures the conservation of a wide range of rare, threatened or endemic species, including around 450 animals and 500 plants. Some 200 rare and characteristic habitat types are also targeted for conservation in their own right (EC, 2014a).

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The Habitats Directive (together with the Birds Directive) forms the cornerstone of Europe's nature conservation policy. It is built around two pillars: the Natura 2000 network of protected sites and the strict system of species protection. The directive protects over 1,000 animals and plant species and over 200 so called "habitat types" (e.g. special types of forests, meadows, wetlands, etc.), which are of European importance.

Annexes I and II to the Directive contain the types of habitats and species whose conservation requires the designation of special areas of conservation. Some of them are defined as "priority" habitats or species (in danger of disappearing). Annex IV lists animal and plant species in need of particularly strict protection at national level (see Table IV.9).

Table IV.9. Annexes to the Habitats Directive

Annex Explanation Natural habitat types of community interest whose conservation requires the I designation of special areas of conservation Animal and plant species of community interest whose conservation requires the II designation of special areas of conservation IV Animal and plant species of community interest in need of strict protection Animal and plant species of community interest whose taking in the wild and V exploitation may subject to management measures

The Emerald Network is the equivalent of Natura 2000 in Non-EU European countries, like Switzerland. It was created to integrate the European network and is based on the Bern Convention. Unlike the EU-directives, it is not legally binding.

The Emerald Network is an ecological network made up of Areas of Special Conservation Interest. Its implementation was launched by the Council of Europe as part of its work under the Bern Convention, with the adoption of Recommendation No. 16 (1989) of the Standing Committee to the Bern Convention. The Standing Committee to the Bern Convention regularly nominates officially as “Candidate Emerald sites” a number of sites proposed by all countries currently working on the establishment of the Emerald Network and Montenegro is also one of these countries. Within the scope of the ESIA studies nominated Emerald Network sites of Montenegro will be considered.

Standards and Guidelines

Ecology and Biodiversity part of the Project is guided by the requirements of the World Bank’s Operational Policy (OP) 4.04 in order to manage environmental risks and impacts on ecology and biodiversity. (OP) 4.04 aims that the protection of critical natural habitats and to be taken mitigation measure to minimizing habitat loss. According to the (OP) 4.04 this issue is explained as “…If the environmental assessment indicates that a project would significantly convert or degrade natural habitats, the project includes mitigation measures acceptable to the Bank. Such mitigation measures include, as appropriate, minimizing habitat loss (e.g., strategic habitat retention and post-development restoration) and establishing and maintaining an ecologically similar protected area…”. As appropriate, the project will take the necessary measures and implement commitments. Also Annex A of the (OP) 4.04 straightens out to determine the critical and/or natural habitats.

In the line with the (OP) 4.04, assessments of the baseline conditions and determined significant criteria for impact assessments were detailed according to IFC Performance Standards 6 (PS6). IFC PS6 covers areas of biodiversity conservation, ecosystem services and sustainable management of living resources, which are all fundamental to achieve sustainable development. The objectives of PS6 are outlined as follows:

 To protect and conserve biodiversity;

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 To maintain the benefits from ecosystem services; and  To promote the sustainable management of living natural resources through the adoption of practices that integrates conservation needs and development priorities.

The requirements of PS6 are applied to projects: (i) located in modified, natural, and critical habitats; (ii) that potentially impact on or are dependent on ecosystem services over which the client has direct management control or significant influence; or (iii) that include the production of living natural resources (e.g. agriculture, animal husbandry, fisheries and forestry) based on the risks and impacts identification process.

IV.4.3. Ecological Researches

Investigations of ecology and biodiversity conditions of the study area were conducted for both terrestrial and aquatic environment. In this scope all ecological researches were conducted with desk based to determine the baseline conditions in the study area. These baseline data/information collections were provided an overall picture of the conditions and sensitivities (if any) in the area that should be considered in assessment of potential impacts and development of relevant mitigation measures for design. The overall approach to determine the baseline conditions in the context and objectives provided above were include the following data collection and interpretation means:

 Review of pertinent literature and previous works.  Satellite image interpretation, as available.

In the scope of the ESIA report, based on the assessed impacts significance relevant measures for mitigating adverse impacts were developed. The importance/sensitivity of the habitats and species were given special attention in reporting and detailed data such as identified species list, their protection status and the extent of the areas were included.

IV.4.4. Findings

Internationally and Nationally Recognised Areas within the Region of the Project Area

This section provides details on the qualifying features for each of the Internationally Recognised Areas located in the vicinity of the Project Area. These include Key Biodiversity Areas (KBAs), Important Plant Areas (IPAs), Important Bird Areas (IBAs) and Emerald Network site. The Internationally Recognised Areas described in this section are shown in Figure IV.9 and Emerald sites and KBAs are given in Figure IV.10.

There are no protected areas in the Project Area. Two areas protected by the national legislation are located in the wider area at a distance to the Project Area. One of those sites is a part of the Durmitor National Park with canyon of Tara River, protected as World Heritage site – UNESCO, which is abound with exquisite richness in terms of flora and fauna. The other area consists of mountain pine associate (creeping pine, Pinetum mughi montenegrinum) on Mountain Ljubišnja.

The closest Internationally Recognized Area from the Project Area is Ljubišnja KBA. The KBA is located in 9.6 km southwestern of the project area.

According to the Emerald Network sites which are still in candidate stage, the Project Area is located in Ćehotina valley Emerald site (number 31 in the in Figure IV.10). The Project’s location on the Ćehotina Valley Emerald Site is presented in Figure IV.11. Ćehotina valley is the second officially nominated Emerald site (and potentially Nature 2000 site) on the territory of Pljevlja with the surface area of 133.56 ha and with the following habitat types identified (according to the Resolution 4 of Bern Convention): DEVELOPMENT OF EIA AND UPDATE OF ESIA REPORTS FOR THE MINE TAILINGS DISPOSAL FACILITY GRADAC, PLJEVLJA Chapter IV - Pg. 61/112 ESIA REPORT

 Southern alder and birch galleries.  Riparian willow formation.  Termophilous and supra-Mediterranean oak woods.  Beech forests.  Montenegrin spruce forests.

The following species have been identified in this site (Resolution 6 of Bern Convention):

 Birds: Emberiza hortulana, Falco biarmicus, Ficedula albicolis, Ficedula parva, Lanius collurio, Pernis apivorus, Picus canus.  Migratory birds: Troglodytes troglodytes, Turdus merula, Upupa eppops, Turdus philomelos.  Mammals: Ursus arctos, Canis lupus.  Amphibia: Bombina variegata.  Fish: Hucho hucho, Cottus gobio.  Invertebrate: Stephanopachys substriatus.

Ljubišnja is another closest Emerald Network Site (candidate) of the Montenegro to the Project Area, which is located about 9.6 km south-western of the mine tailing pond Gradac. The ecological values of the area of Ljubišnja are confirmed through its identification as Emerald site Ljubišnja - an area that is important for protection under the criteria of the Bern Convention (Habitat Resolution 4 and Resolution 6 for Species). Existing protected natural heritage of the area of Ljubišnja, only the stand of Pinus mugho is now protected. It plays a major role in protecting the soil from erosion. The pine cones (Pinetum mughi montenegrinum) on Ljubišnja mountain, extending over an area of 900 ha, according to the Nature Protection Act, is protected as a monument of nature and is treated as a protected plant species.

Durmitor is also close region to the project area with 17.1 km away. Durmitor has KBA, IBA, IPA and national park status. Internationally Recognized Areas and national parks of the Montenegro (both existing and planned areas included) are shown in Figure IV.9 and Figure IV.10. According to figure, all recognized areas are quite far from the Project Area. It is anticipated that the Project will not have any impacts on these natural areas.

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Figure IV.9. Map of International Recognized Areas and National Parks around the Project Area

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Figure IV.10. Map of Emerald Network Sites Areas and KBAs

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Figure IV.11. Project Location on Ćehotina Valley Emerald Site

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Vegetation and Habitat Types of the Terrestrial Ecosystem

The Project Area has an already modified habitat and has not inhabit natural vegetation. The study area is covered with beech-fir forests (see Figure IV.12). According to the literature studies, general habitat types in Pljevlja region and Ljubišnja are described below:

 Oak forest is present in many localities around Pljevlja (see Figure IV.13). There are only five species that grow under forests: Carpinus betulus, Fagus moesiaca, Betula verrucosa, Pyrus pyraster, Prunus avium. These species do not have great continuity and have very little cover. The shrub layer also Floristic are very poor and has a small cover (10 to 30%). The species that grow under the bushes is represent with Corylus avellana, Carpinus betulus, Fagus moesiaca, Juniperus communis. The ground flora has a coverage of 20 to 100%, although the stands have great coverage, such as: Pteridium aquilinum, Festuca vallesiaca, Veronica officinalis, Hieracium sp. which shows the highest value of the quantity and coverage, while other types appear in a much smaller quantity and with a lower degree of presence.  The mixed forest of beech (tree of Fagus) and fir (tree of Abies) are widespread in Pljevlija's surroundings. At these sites, the forests reach normal growth (height and extent of trees). White [Pinus silvestris] and black [Pinus nigra] pine are recorded.  The juniper pine (Pinetum mughi montenegrinum) on the Ljubišnja has a different spread. It starts at about 1800 meters and locally reaches to the highest peak (2238 m). The juniper pine has great significance for the spruce forest are protected from the large spill of water streams and avalanche. In Ljubišnja, in the community of juniper pine, in the first floor of the herbaceous plants, there are some species that are not recorded in this community on other Montenegrin mountains. These are: Heracleum sibihcum, Tozzia alpinct, Anemone narcissiflora, Trollius europaeus.  The mixed forests of spruce and fir trees in the area of Pljevlja constitute 10.2% of the total covered forest area. There are 4 different tree species as Betula verrucosa, Populus tremula, Picea excelsa and Abies alba. The species that grown under the trees are Vaccinium myrttilus, Rosa alpina, Betula verrucosa, Galium rotundifolium, Veronica urticifolia, Festuca drymea, Euphorbia amygdaloides and etc.

Figure IV.12. Ljubišnja-Montenegrin Spruce Forest

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Figure IV.13. Forest Communities around the Project Area

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Terrestrial Flora

The whole Project Area has been used as a mine tailings disposal site. Therefore, the project area does not have any natural habitat. Vegetation cover of the Project Area is almost non- existent.

Various relief form, prominent differences in elevation points, climate characteristics and other factors, have conditioned formation of different types of forest vegetation, heterogeneous and rich flora in Pljevlja. Plants of open habitats are predominant in the wider zone of the study area; meadows, pastures, anthropogenic areas (backyards, fields, ruderal species by the roads). So far 33 protected species of vascular plants have been recognized on the territory of Pljevlja Municipality and the most numerous of them all are the members of the orchid family. Based on the previous research, in the target area there are no orchids whose populations in Montenegro are rare or small.

Flora species at vicinity of project site specified literature search are listed in Table IV.10. Protection status defined by IUCN (International Union for Conservation of Nature) and explanation of the scope of Bern Convention Appendix-1 List and CITES and EU habitat Directives are presented.

Vascular flora: In the study area, 483 taxa were found, grouped in 80 families. Among the meadow plants, most are the representatives of the family of grass (Poaceae), Fabaceae, Asteraceae, usnatica Lamiaceae. The most common meadow plants of this area are: Agrimonia eupatoria, Daucus carota, Cichorium intibus, Trifolium pratense, T. nigricens, Mint pulegium, Dianthus carthusionorum, Agropiron sp., Vulpia sp., Dactylis glomerata, Prunela vulgaris, Hypericum perforatum, Filipendula hexapetala, Achilea milefolium, Euphorbia cyparisias and etc.

Lihenoflora (lichen): The study of lichens in the area of Pljevlja municipality identified 120 taxa of lichen and 3 species of lynx mushrooms. Of this number, 16 taxa of lichen and 3 lynx mushrooms were first established in Montenegro. This does not mean that the mentioned species are obligatory and rare in Montenegro, but that the information mentioned is a result of poor research of the lichenoflora of Montenegro.

Brioflora (moss): There are sporadic data on moss findings in the area of Pljevlja, but since no systematic research has been conducted, it is not possible to estimate the total number of species present in this area. The most interesting are the species Buxbaumia viridis recorded on Ljubišnja in the coniferous forest and on Kosenica in a mixed forest of coniferous woods with national and international protection status. This species are endangered throughout Europe, mostly due to the cuttings that destroy the old trees in which the species develops. Buxbaumia viridis is located on the Red Lists of most states.

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Table IV.10. The List of Most Important Flora Species

Family Species English Name Endemism IUCN Bern CITES EU Habitat Directive Buxbaumia viridis Buxbaumia - - - App-II Cephalanthera White LC - - - alba(damasonium) Helleborine Cephalanthera rubra Red LC - - - Cephalanthera Coralroot LC - - - Corallorhiza trifida Orchid Heart Shaped LC - - - Dactylorhiza cordigera Lip Dactylorhiza Early Marsh- LC - - - Dactylorhiza incarnata Orchid Sack-Carrying LC - - - Dactylorhiza saccifera Dactylorhiza Elder-flowered LC - - - Dactylorhiza sambucina Orchid Dactylorhiza viridis Frog Orchid LC - - - Broad-leaved LC - - - Epipactis helleborine Helleborine Common LC - - - Gymnadenia conopsea Fragrant Orchid Nigritella (Gymnadenia) Black LC - - - nigra Gymnadenia Orchis(Anacamptis) Bug Orchid LC - - - coriophora Loose- LC - - - Orchis(Anacamptis) flowered laxiflora Orchid Orchis(Anacamptis) Green Winged NT - - - morio Orchid Orchis simia Monkey Orchid LC - - - Orchis(Neotinea) ustulata Burnt Orchid LC - - - Lesser LC - - - Neottia cordata Twayblade Listera(Neottia) ovata Common LC - - - Twayblade Neottia nidus-avis Bird's-nest LC - - - Orchid Platanthera bifolia Lesser LC - - - Butterfly Orchid Traunsteinera globosa Spheroid LC - - - Traunsteinera Galanthus nivalis Snowdrop NT App- - App-V II Narcissus poeticus ssp. - DD - - - radiiflorus Gentianella crispata - - - - - Lilium albanicum Zambaku LC - - - shqiptar Oxytropis dinarica - NT - - - Prunus padus Bird Cherry - - - - Quercus robur European Oak LC - - App-I Trollius europaeus Globeflower - - - - Verbascum nicolai Mullein - - -

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Terrestrial Fauna

The main objective of fauna studies is to identify the fauna elements (amphibians, reptiles, birds and mammals) of the study area, define the habitats these fauna elements inhabit, and make evaluations on faunal and ecological characteristics of the study area.

The area of the Pljevlja municipality is the third largest in Montenegro and covers a varied habitat at 1346 km2, belongs to the mountainous region of the northern Dinarides, practically in the central part of the Balkan Peninsula. The composition and distribution of fauna depends primarily on that type of habitat. 59% of the territory of the Pljevlja Municipality is composed of mountainous areas while uncultivated surfaces make up to 21%. As mentioned above, vegetation and habitat feature of the project area is modified and artificial areas. Therefore, there is not any fauna composition within the project area.

The fauna elements specified at study area are investigated under 3 different headings; Mammalia, Aves (Birds) and Amphibia -Reptilians. Fauna elements specified after literature search are given with their taxonomic classification, their names in Latin and English names (if any), in the tables. Evaluation is carried out for all fauna elements that possibly inhabit at study area in accordance with threatened categories of IUCN, Bern Convention, CITES and EU Directives.

Invertebrate: Invertebrates represent the most numerous groups of fauna, and among them, the largest number of species belongs to the group of insects. Deciduous, mixed and conifer forests represent habitats for many insect populations, out of which two species from the group of red wood ants should be mentioned, Formica polyctena and Formica pratensis. In terms of beetles, two species are protected on the national level: Lucanus cervus L. (stag beetle) and Oryctes nasicornis L. (European rhinoceros beetle). From the rich family of butterflies, 3 species are protected; Papilio machaon L. (Old World swallowtail), Iphiclides podalirius L. (scarce swollotail) and Parnassius apollo L. (Apollo butterfly). Stone crayfish (Austropotamobius torrentium) populates rivers Ćehotina, Lim and Tara and is on the Habitat Directive Annex V. The list of most important invertebrate species that could be found in the wider area is given in Table IV.11.

Table IV.11. List of Most Important Invertebrate Species

BERN EU Habitat Species English Name IUCN CITES Convention Directive Austropotamobius torrentium Stone Crayfish DD - App-III App-V Formica rufa Red Wood Ant NT - - - Formica polyctena European red wood ant NT - - - Formica pratensis Black-backed meadow ant NT - - - Lucanus cervus L. Stag Beetle NT - App-III App-II Oryctes nasicornis kuntzeni - - - - - Papilio machaon L. Swallowtail LC - - - Iphiclides podalirius L. Scarce Swallowtail LC - - - Parnassius apollo L. Apollo NT App-II App-II App-IV Helix vladica - LC - - -

Within the study area there are 5 amphibian species and 3 reptile species. Pools, wetland areas, numerous channels on cultivated meadows and fields, as well as streams in oak and beech forests represent suitable habitats for amphibians. The list of most important amphibians and reptile species that could be found in the wider area is given in Table V.12.

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Table IV.12. The List of Most Important Amphibians and Reptiles Species

BERN Species English Name IUCN CITES EU Habitat Directive Convention Bombina variegata Yellow-Bellied Toad LC - App-II App-II, App-IV Mesotriton alpestris Alpine Newt LC - - - Triturus vulgaris) Smooth Newt LC - - - Rana temporaria European Common Frog LC - - App-V Lacerta trilineata Balkan Green Lizard LC - App-II App-IV Natrix tessellata Dice snake LC - App-II App-IV Vipera ammodytes Long Nosed Viper LC - App-II App-IV Zamenis longissimus Aesculapian Ratsnake LC - - -

Numerous bird species are protected as rare or endangered species by national legislation such as crested lark (Galerida cristata), Golden eagle (Aqulla chysaetos), Western capercaillie (Tetrao urogallus) ect. About 41 bird species have been identified on Ljubisnja Mountain (proposed IBA site) such as Eurasian wren (Troglodytes troglodytes), grey tit, Parus montanus, Northern goshawk (Accipiter gentilis), European blackbird (Turdus menda). The list of most important bird species that could be found in the wider area is given in Table IV.13.

Table IV.13. The List of Most Important Bird Species

BERN Species English Name IUCN CITES EU Bird Directive Convention Parus montanus Willow Tit LC - - - Troglodytes troglodytes Northern Wren LC - App-II Ann-I Western Tetrao urogallus LC App-I App-II Ann-I-II-III Capercaillie Accipiter gentilis Northern Goshawk LC - - Ann-I Red-backed Lanius collurio LC - - Ann-I Shrike Phoenicurus Common Redstart LC - App-II - phoenicurus Corvus cornix Hooded Crow - - App-III - Eurasian Collared- Streptopelia decaocto LC - App-III Ann-II dove Eremophila alpestris Horned lark LC App-II - Prunella collaris Alpine accentor LC App-II - Anthus spinoletta Water pipit LC App-II - Aquila chrysaetos Golden eagle LC App-II App-III Ann-I Falco tinnunculus Common kestrel LC App-II App-II Phoenicurus ochruros Black redstart LC App-II Oenanthe oenanthe Northern wheatear LC App-III Pyrrhocorah graculus Alpine chough LC App-II Corvus corax Common raven LC App-III European honey Pernis apivorus LC App-II App-III Ann-I buzzard Tetrastes bonasia Hazel grouse - - - - Common wood Columba palumbus LC Ann-I-II-III pigeon Dryocopus martius Black woodpecker LC App-II Ann-I Great spotted Dendrocopus major LC App-II Ann-I woodpecker Troglodytes troglodytes Eurasian wren LC App-II Ann-I Fringilla coelebs Common chaffinch LC App-III Ann-I Loxia curvirostra Red crossbill LC App-II - Turdus philomelos Song thrush LC App-II Ann-II Turdus torquatus Ring ouzel LC App-II - Pyrrhula pyrrhula Eurasian bullfinch LC App-III Ann-I Eurasian Accipiter nisus LC App-II App-III Ann-I sparrowhawk Buteo buteo Common buzzard LC App-II App-III - Garrulus glandarius Eurasian jay LC Ann-II Whitebacked Dendrocopus leucotus LC App-II - woodpecker

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BERN Species English Name IUCN CITES EU Bird Directive Convention Columba oenas stock dove LC App-III Ann-II Parus major great tit LC App-II Ann-II European Turdus menda - blackbird Turdus viscivorus mistle thrush LC App-II Ann-II Parus palustris marsh tit LC App-II - Erithacus rubecula European robin LC App-II - Eurasian collared Streptopelia decaocto LC App-III Ann-II dove Hirundo rustica barn swallow LC App-II - Pica pica common magpie LC Ann-II Coloeus monedula western jackdaw - - Passer domesticus house sparrow LC - Syrian Dendrocopos syriacus LC Ann-I woodpecker Sturnus vulgaris common starling LC Ann-II Galerida cristata crested lark LC App-III - Carduelis carduelis goldfinch LC App-II - Alcedo atthis common kingfisher LC App-II Ann-I Charadrius dubius little ringed plover LC App-II - Motacilla alba white wagtail LC App-II - Motacilla cinerea grey wagtail LC App-II - Anas platyrhynchos Mallard LC App-III - Anas querquedula Garganey LC Ann-II Aythya ferina Common pochard LC App-II Ann-II Aythya fulgida tufted duck - - - - Podiceps ruficollis Little grebe - - - -

Diversity of habitats on the territory of Municipality Pljevlja is indicative of rich fauna of mammals. Large mammals prefer deciduous and mixed forest biotope, which have the highest degree of representation on Ljubišnja, as well as on the far north-west area of the Municipality. The following species belong to the deciduous and mixed forests; rob deer, bear, boar, wolf, fox, rabbit, weasel, marten, squirrel and different types of mice. The Ćehotina river valley represents a suitable habitat for bats, especially in the part where the gorge is located. The following bats are listed for the region; Hypsugosavii -Savi’s pipistrelle, Pipistrellus pipistrellus – common pipistrelle. Presence of bats in the town itself has not been documented, and this is mostly due to air pollution. There are no protected mammals in the project area of influence. It should be indicated that the Project area is an area that has already been degraded by human activities where ecosystem has already reached a balance. The list of most important mammal species that could be found in the wider area is given in Table IV.14.

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Table IV.14. The List of Most Important Mammal Species

BERN EU Habitat Species English Name IUCN CITES Convention Directive Rhinolophus Lesser Horseshoe Bat NT - - App-II hipposideros Rhinolophus mehelyi Mehely's Horseshoe Bat VU - - App-II Podiceps nigricollis Black-necked grebe - - - - Apodemus sylvaticus Long-tailed Field Mouse LC - - - Canis lupus Grey Wolf LC App-II App-II App-IV Capreolus capreolus European Roe Deer LC - - - Crocidura leucodon Bicolored Shrew LC - - - Crocidura suaveolens Lesser Shrew LC - App-II - Erinaceus europaeus Western European Hedgehog LC - App-II - Lepus capensis Cape Hare LC - App-II - Lutra lutra Eurasian Otter NT App-I App-II App-II, App-IV Martes foina Beech Marten LC - App-III - Martes martes Pine Marten LC - App-III App-V Meles meles Eurasian Badger LC - App-III - Neomys fodiens Eurasian Water Shrew LC - - - Rhinolophus Greater Horseshoe Bat NT - - App-II ferrumequinum Sciurus vulgaris Eurasian Red Squirrel LC - App-III - Sorex alpinus Alpine Shrew NT - - - Sorex araneus LC - - - Nannospalax leucodon Lesser Mole Rat LC - - - Ursus arctos Brown Bear LC App-II - App-II, App-IV Vulpes vulpes Red Fox LC - - -

Aquatic Environment

In terms of fish fauna in the Project Area, river Ćehotina, and its largest tributary are the only ones which provide a complete development cycle of fish population because they have a stable water flow during the entire year. The Voloder river is the hatchery for Salmo labrax (Black Sea salmon), and Cottus gobio (European bullhead) species has also been found here, marked by stable and numerous populations. Out of the species registered on the Habitats Directive list, the following species have been found in the Ćehotina River; Hucho hucho (huchen), Chondrostoma nasus (common nase), Barbus sp. (Pagani). Species which are on the Bern Convention list is the following; Thymallus thymallus (grayling). Although it is not protected, the species which stands out as important from the aspect of ichthyology is Salmo trutta (brown trout) - Black Sea trout, which may be found along entire stream of the River Ćehotina. The list of most important fresh water fish species that could be found in the wider area is given in Table IV.15.

Table IV.15. The List of Most Important Fresh Water Fish Species

BERN Species English Name IUCN CITES EU Habitat Directive Convention Salmo trutta Brown Trout LC - - - Hucho hucho Danube Salmon EN - App-III App-II, App-V Thymallus thymallus Grayling LC - App-III App-V Salmo trutta labrax - - - - - Cottus gobio Bullhead LC - - App-II Chondrostoma nasus Nase LC - App-III - Barbus sperchiensis - NT - -

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IV.5. Socioeconomic Environment

IV.5.1. Settlements

Municipality of Pljevlja has total area of 1,346 m², which represents 9.7% of the total territory of Montenegro. It belongs to the mountainous area with average altitude between 1,000 and 1,200 m asl. Municipality of Pljevlja from the northwest and west has border with Bosnia and Herzegovina (municipalities Foca and Cajnice), from north and northeast with the Republic of Serbia (municipalities Priboj and Prijepolje), from southeast and east with municipality of Mojkovac and Bijelo Polje and from southwest with the municipality of Zabljak. Mine tailings pond site Gradac is located near the Gradac village. Other than Gradac village, there are settlements such as Gornji Gradac, Podosoje, Poros and Crnci in the broader surrounding of the Project Area.

IV.5.2. Demographic Characteristics

Municipality of Pljevlja has a population of 30,786 inhabitants, according to the latest data (Monstat, Census 2011) whereas 49.1% are male and 50.8% female inhabitants and 41.8 years old in average. From the total population, 37.5% is active, while 47% is inactive and 15.4% is less than 15 years old. Population in Pljevlja decreased 8.6% in 2011 comparing to 2003. Depopulation is continuing and is characteristic of the municipalities from the northern region of Montenegro whereas local population is moving to other regions and the Capital Podgorica due to unemployment or better business opportunities in other regions. There are 100 families living in Gradac, including Sula village.

IV.5.3. Employment

From the total number of active population 69.3% is employed in 2011. Major economic activities of the active employed inhabitants from Pljevlja are related to public administration (14.5%) and ore and stone extracting (13.7%) according to Census of 2011. Unemployment rate in municipality of Pljevlja is one of the highest in Montenegro and it was 25% in 2017. The closest settlement Gradac’s dwellers used to work in the mine, but now they are mostly unemployed.

IV.5.4. Education

Municipality of Pljevlja has 14 primary schools, whereas three are located in urban and 11 in rural areas. There are also two high schools and one music school as well as department of the Mechanical Faculty of University of Montenegro. Majority of population from Pljevlja municipality has higher (university) education (45.8%), while 4.7% has high school education.

IV.5.5. Vulnerable Groups

Municipality of Pljevlja has its Centre for social protection, which is covering two municipalities: Pljevlja and Zabljak. Number of households in need for social and beneficial help (custodial care) in 2017 was 408. As population decreased, these number of households also decreased (from 603 in 2011 to 408 in 2017) Total number of people who are using right to personal disability pension is 111 in 2017, which showed a slight increase every year (this number was 97 in 2011).

IV.5.6. Health and Social Security

Municipality of Pljevlja has health protection system based on two institutions: Public health service ‘Community health centre Pljevlja’ and Public health service ‘Pljevlja hospital’. Pljevlja hospital has internal, infectious, surgical, orthopaedic and urological departments. Lack of medical

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staff as well as inadequate equipment is main causes of insufficient quality of health protection. Pljevlja inhabitants are facing respiratory problems, infections, metabolism issues, but due to lack of relevant data it cannot be concluded that such issues are caused directly by the negative impacts and presence of industrial sector (TPP, Coal Mine, landfill Maljevac, sewage system, landfill Jagnjilo, scattered individual landfills, mine tailings pond site Gradac). It can be considered that number of illnesses is increasing and Municipality of Pljevlja is facing decrease in birth rate (SES, Page 85).

IV.5.7. Social Infrastructure and Services

Transportation Network

Compared to the main road network of Montenegro, the municipality of Pljevlja has an unfavourable traffic position. The mode of transport on the territory of the municipality is road traffic. Figure IV.14 shows the road network of the Municipality of Pljevlja.

Figure IV.14. Road Network of Municipality of Pljevlja

Municipality of Pljevlja is connected with the neighbouring countries with the main road M-8 (towards border with Serbia) and regional roads R-3 (towards border to Bosnia and Herzegovina)

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and its part (towards Priboj), R-10 (Trlica-Slijepac most-Bijelo Polje) and R-21 (Gradac-Sula- towards Bosnia and Herzegovina). There is also network of local roads within the municipality where total length of the road network is 533.6 km, while there are 368 km of the local roads of which 31.5% has asphalt basis. Cars are dominant in the traffic (79-94%). Nearby the project location there is a network of the local roads while regional road Pljevlja-Djurdjevica Tara-Zabljak is passing by the eastern part of the landfill (1 km).

Electricity

The Montenegrin energy system has a transmission network that makes over 1300 km of lines, 24 substations and distribution facilities at the 400 kV, 220 kV and 110 kV voltage levels. The total power of transformation of the transmission network of Montenegro is 3287.5 MVA (with a total of 44 transformer units). One of the most important facilities of the Montenegrin energy system that are connected to the power grid is the TPP Pljevlja with installed power of 218.5 MW (257 MVA). Pljevlja thermal power plant started operating in 1982 and is currently the only thermal power plant in Montenegro. The supply of thermal power plant with water for cooling and other uses is provided by the Otilovici reservoir, with a total reservoir volume of almost 18 million m3.

Telecommunication

There are 16.500 fixed phone switches per 100 inhabitants in Pljevlja whereas there is only one fixed phone operator – Crnogorski Telekom. Whole fixed telecommunication network is based in Pljevlja as well as telecommunication points: Mocevac, Golubinja, Potrlica, Grevo, Zabrdje, Odžak and Otilovici. All telecommunication points are digital, modern and satisfactory in terms of quality and capacities. Besides that, there are also other means of telecommunication systems – mobile telephony, Internet, MPLS multiservice network, radio-television network and postal network.

Tourism

Tourism represents strategic and most profitable area of economic development in Montenegro. Construction of new infrastructure such as tunnel Zabljak-Savnik and the road Niksic- Grahovo-Risan are positioning Pljevlja on a tourism map of Montenegro. On that way Municipality of Pljevlja is becoming transit point between northern and coastal area of Montenegro. In terms of capacity, Municipality of Pljevlja has six hotels and accommodation capacity of 403 beds (MONSTAT, 2016).

Social Infrastructure

All households have access to clean drinking water, by means of local water net/infrastructure. Fewer people use own water well in the household where they reside. Structures at locations that are not connected to sewage system, but discharge wastewaters in own septic pits.

Municipaltiy of Pljevlja in terms of cultural objects has museum, gallery, library and cinema. On the other hand, for the purposes of sport activities there are stadium “Golubinje’’ and Sports centre ’’Ada’’.

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IV.5.8. Economy in the Municipality of Pljevlja and Livelihoods

Mining in coal and zinc and lead is well developed in the municipality of Pljevlja. Potrlica Coal mine supplies the thermal power plant and the rest of the production is marketed to the needs of individual heating in households as well as to coal-fired utilities.

Electricity production is the most lucrative branch of the municipality's economy. TPP Pljevlja produces electricity for the needs of Montenegro. Šuplja Stijena mine is a lead and zinc mine, located to the northwest of the municipality, on the slopes of Ljubisnja Mountain, near the border with Bosnia and Herzegovina. After a perennial break, it continued working in 2006 as a strip mine.

Forestry and agriculture are also lucrative branches of economy in the municipality of Pljevlja. Agriculture in the social and individual sector is a significant source of income for most of the population. Wood industry is relatively developed in the area since Municipality of Pljevlja has great resources for wood processing and is rich in high quality forests. The most prominent subject of the wood processing industry is "Vektra -Jakić" - Pljevlja LLC for production, trade and services, which is also the main concessioner for forest exploitation.

Municipality of Pljevlja has natural and cultural-historical heritage which is representing key precondition for further development of tourism and agriculture. One part of the municipality (76.5km²) is located nearby the Tara canyon and is inside the National Park Durmitor, which is under UNESCO protection. Regarding to that municipality has great possibilities to develop rural and eco-tourism as well as organic food production (Ljubisnja Mountain, Kovac Mountain, Kosanica zone, Tara River and upper stream of Ćehotina river). Additionally, municipality of Pljevlja is the most prominent one in Montenegro in terms of agricultural development – surface of the agricultural land and agricultural potential. It has more than 15% of the total agricultural land of Montenegro whereas 51% are representing pastures and meadows (area of Kosanica). Municipality of Pljevlja has in total 4,001 registered agricultural households in its rural areas whereas main agricultural activities are; livestock breeding (70%), crop production (23%) and others (7%).

Municipality of Pljevlja has 591 registered companies in 2017 which number is increasing in the last three years (MONSTAT, 2017). However, Municipality of Pljevlja, according to the latest Index of the municipal development is on 13th position out of 23 municipalities in Montenegro (Ministry of Economy, 2015).

In Gradac, which is the closest settlement to the Project area, the citizens used to work in the mines, but now they are mostly unemployed.

IV.5.9. Affected Settlements by the Project

Municipality of Pljevlja has in total 158 settlements, while the area in the vicinity of the mine tailings pond site is relatively sparsely populated. Nearby tailings pond site there is the settlement Gradac. Currently, Gradac is potentially affected to a large extent due to the nature of the Project Area. Dust formation during windy conditions and pollution of surface and groundwater directly affect the closest settlements.

Other than Gradac; Podosoje and Podos settlements are also close to the tailings pond site. The remediation of the Project Area will solve dust problems observed in the region and decrease stress on river Ćehotina, caused by leachate and drainage waters.

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IV.6. Protected Areas and Cultural Heritage and Assets

In the territory of the Municipality of Pljevlja there are two categories I cultural monuments (monuments of extreme importance); Sveta Trojica Monastery and Husein Pasha's Mosque, which are at a distance of 28 km and 25 km to the Project site, respectively. In addition, there are 4 category II cultural monuments (monuments of great significance); the Monastery of Dovolja (65 km from the Project site), Dubocica Monastery (25 km from the Project site), Archaeological site of Komini (26 km from the Project site) and Monastery of St. Arhanđela Mihaila. In addition to the above mentioned legally protected cultural monuments, there are a large number of other assets of cultural and historical heritage in the Municipality of Pljevlja, which testify to the continuity of the lives of people in this area since early prehistoric times.

In the minor area/vicinity of the tailings pond site and the Project area of influence there are no monuments protected by law, nor other important cultural and historical heritage assets that need special attention during implementation of the Project.

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V. ENVIRONMENTAL AND SOCIAL IMPACTS

Lead and zinc mine Šuplja Stijena was started to operate in 1954. The floatation tailings of the mine had sent to the tailings pond site Gradac until the capacity of it became insufficient. In recent years, tailing disposal to the site has been stopped. So far, 3.9 million tons of tailings is disposed to the site. However, this great amount of toxic material should’ve been disposed in a sustainable and environmentally sound way. In the relevant chapters of this ESIA Report, tailings pond site Gradac’s location and extent, and the scope of the Project are provided. To summarize here, the Project includes the following components:

 Stabilization of mine tailing disposal facility, and  Recultivation

This impact assessment study is exclusively for this Project, which intends to mitigate some of the ongoing impacts of the tailings disposal activities on the environment.

V.1. Area of Influence and Impact Assessment Approach

V.1.1. Area of Influence

Potential area of influence (AoI) of the Project includes the geographical area that potential impacts of the Project could extent. The area of influence may be different for different types of impacts and different environmental components (physical, biological, social) (World Bank ESMAP, December 2012). The AoI is defined for physical, biological environment, and socioeconomic environment that has been covered as the study area in this ESIA.

In this regard, the AoI for physical and biological environment includes the Project footprint, the upstream and downstream of the river Ćehotina and a circular area with radius of 500 m from the centre of the Project Area.

In terms of the socioeconomic environment, the AoI includes the close-by settlements mainly Gradac, Podosoje and Poros. The close vicinity of the Project area and the AoI can be seen in Figure IV.1.

V.1.2. Impact Assessment Approach

The assessments of possible environmental and social impacts that the project should manage during the activities to be carried out in the construction and operation phases and the measures to be taken against the possible effects are described in the following sections. Table V.1 represents an interaction matrix that summarizes each environmental and social element discussed in the following chapters and the possible actions that might cause or potentially create benefits for these elements at different stages of the Project. The environmental and social elements to which the project may interact, the impact assessment work on these elements and the general approaches to planned preventive mechanisms to be established and the mitigation measures planned to be taken according to the evaluation results will be presented in the following sections.

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Table V.1 Matrix Representing Environmental and Social Impact Sources, Activities and Possible Interacts (Before Mitigation Measures Are Taken)

Environmental and Social Factors

Environmental Social

Source of Impact and Activity

National Economy National

Land Use Properties Land Use Topography Environment Soil Geology Environment Biological Waters Surface Groundwater Air Environment Level Noise Background Load Traffic Env. Visual and Landscape Areas Protected Env. Socioeconomic Local Safety and Health Community Safety and Health Occupational Construction Activities (including

access roads and site organization) Provision of Material, Equipment

and Service

Stabilization of Tailings Pond Site

Recultivation of Tailings Pond Site

Traffic-Construction Vehicles

Vehicle/equipment Use and

Maintenance

Use of Energy

Employment of Workforce

Possible Negative Impact Possible Positive Impact

In order to assess the impacts of the Project a two-step approach was used including the determination of the baseline conditions of the environment (covering social environment as well) before implementation of the Project and determination of the changes in the environment caused by the Project activities.

In this context, as Step 1, Chapter IV presented data on environmental quality, among other information. In the same chapter, parameters of pollution generated by the long-term operation of the tailings pond site are given and trends/changes in some of those are analysed. These analyses represent the baseline conditions at the start of the proposed Project, but not the zero state which would represent the state prior to the beginning of the operation of the site.

As Step 2, impacts are assessed and the magnitude (e.g. wide, local and restricted) and severity (e.g. high, medium, low) of the impacts are taken into consideration when determining the significance of the impact. The magnitude is classified based on the extent of the impact, while the severity is categorized according to the sensitivity of the receiver/source exposed to the impact, as much as possible. A significance matrix that is given in Table V.2 combines the sensitivity information with the magnitude of impacts. The significance of the impact is first designated without mitigation measures and then evaluated with proposed mitigation measures. This evaluation would serve to determine the significance of the residual impacts (impact left after employing mitigation measures).

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While it is important to identify the initial significant impacts associated with the Project, the key focus of impact assessment has been to define the significance of residual impacts after the application and/or consideration of mitigation measures. In this regard, a summary of the assessed impact before and after Project implementation is provided at the end of this Chapter (Table V.22) to indicate the potential significance of impacts including residual impacts.

The overall aim of employing mitigation measures is bringing the residual impacts to acceptable levels. In terms of designing mitigation measures; avoid (make changes so that the impacts is avoided altogether), minimize (apply measures to reduce size of the impacts), repair (take action to repair and/or restore the affected environment) and offset (measures to offset or compensate for the impact) mitigation hierarchy has been followed.

Table V.2 Impact Significance Matrix

Sensitivity of Magnitude of Impact Receptor High Medium Low Negligible/None High High High Medium Negligible/None Medium High Medium Low Negligible/None Low Medium Low Low Negligible/None * Adapted from Scottish Natural Heritage – A handbook on environmental impact assessment, 2013

The Project aims to reduce and eliminate some of the negative impacts of the mine tailings pond site Gradac on the environment by stabilization and recultivation of it Stream. These are expected to have the following outcomes:

 Elimination of the impact of the tailings pond site on the river Ćehotina water  Reduction of pollution in the ground water in the surrounding area  Reduction of air pollution and soil pollution in the surrounding area

The Project implementation mainly includes construction activities on tailings pond site and during these activities there would be some adverse impacts on hydrology, soils, environmental quality, ecosystem and socio-economy of the region.

V.2. Impacts on Physical Environmental Characteristics

The impacts of the Project activities and components on the physical environment and the effects of the physical environment on the Project are examined in this section. All impacts, beneficial or adverse, during construction and operation phases are discussed in the following subsections. The environmental impact analysis and assessment generally follow the outline of the previous chapter and scoping tables in order to address the impacts based on the baseline data provided.

V.2.1. Impacts on Hydrogeology and Hydrology

In order to prevent the further pollution of river Ćehotina induced by the leachate from the tailings pond site, the remediation of site will be performed and together with the construction of ring-typed drainage channels and capping, rainfall and surface run-off contact with disposed material will be prevented and collected runoff will be directed into the river Ćehotina. This will decrease the pollution stress contribution of leachate generation and erosion of tailings pond site on river Ćehotina.

In general, the potential impacts of the Project on hydrology and hydrogeology of the area would be generally positive.

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V.2.2. Impacts on Erosion, Land Slide and Land Use

The tailings disposal site itself is a typical anthropogenic land, where the former natural layer is practically destroyed. Therefore, there will be no change of the land use in the extent of the Project.

Other impacts on land use will be mainly during the construction phase of the Project in regard with the construction machinery movement in the close vicinity of the Project Area and opening of new access roads, if needed. Currently, significant erosion conditions prevail on the slopes of tailings pond site and material stored in the site reaches to the river Ćehotina in small amounts. In addition to the erosion problem observed on site, the slopes were also found unstable during geotechnical studies. Hence, the tailings pond site has landslide risk towards to the river bank, which can create transboundary environmental problem since Gradac is only 15 km away from the Bosnia and Herzegovina border. During construction works of the Project, inadequate geotechnical works could cause landslide and increase erosion potential of the site. However, these sorts of problems would be eliminated by following the implementation guidance given in design documents. The foreseen activities of stabilization and recultivation of the pond site will reduce possible sliding and prevent soil erosion.

During the construction phase of the Project, excavation works will be performed. All excavated material will be used in the stabilization of the site; thus, there will be no additional storage area required for excavated material and all of excavated material will be temporarily stored on site.

Table V.5 summarizes the potential impacts of the Project on erosion, land slide and land use.

Table V.3. Assessment of Impacts on Erosion, Land Slide and Land Use

Impact Affected Project Definition of Potential Type of Significance Ecosystem Source of Impact Phase Impact Impact Before Component Mitigation Erosion and sliding on the Erosion and landslide risks Construction Negative Medium slopes Land Erosion and landslide Beneficial / Erosion and landslide risks Operation potential of the site will be - Positive lowered

V.3. Impacts on Physical Environmental Quality

V.3.1. Impacts on Water Quality

As stated in the previous chapters, river Ćehotina flows from the northwest side of the landfill. Before the formation of the landfill, river Ćehotina passed around the landfill; however, due to the capacity increase needs of the landfill, two tunnels were drilled to change its route. This alteration helped to increase the sitting area and capacity of the landfill. Currently, the western and north-western slopes of the landfill end up directly on the banks of the river and are reinforced with stone embankments.

Massifs surrounding the landfill and their basins divert the surface runoff onto the surface of the landfill and from there, surface runoff partially flow directly into the river and the some of it drains through the body of the landfill. The remaining part creates small ponds and puddles on the surface of the landfill, which slowly drain.

In addition to these, traces of erosion of the deposited material are visible on the embankment slopes. On the bottom of the embankment slopes, erosion traces are also observed caused by the increased water levels of river Ćehotina observed during rainy season.

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All of these lead to the conclusion that, other than the wastewater discharges to the river Ćehotina, landfill itself also creates pollution stress on the both surface and groundwaters around the Project Area. The combination of abovementioned issues has detrimental effects on the environmental and public health.

Water quality analysis studies presented in the Chapter IV showed that the drainage water reaches to the river Ćehotina is highly polluted with heavy metals and has a low pH. River Ćehotina’s water quality near the landfill is also low due to high iron, manganese, zinc, chromium and cyanide concentrations.

The Project aims to mitigate the already existing impacts on water quality in the area, so once implemented it would have positive impacts on surface and groundwater quality. The potential impacts of the Project on water quality would be during the construction due to uncontrolled disposal of waste, potential leakage from construction vehicles/equipment maintenance and fuelling, and soils reaching the surface water as sediments. During the operation phase of the Project, main impacts might be related with the efficiency of water drainage system. Clogging of the channels should be monitored to manage this potential adverse impact. Therefore, the significance of impacts regarding the operation phase are considered as negligible. Table V.4 summarizes the potential impacts on surface and groundwater quality.

Table V.4. Assessment of Impacts on Surface and Groundwater

Impact Affected Definition of Type of Significance Ecosystem Source of Impact Project Phase Potential Impact Before Component Impact Mitigation

Uncontrolled disposal of waste, oil and Surface waters fuel leakage from construction vehicles, Change of water (streams and Construction Negative Medium sediments (soil) reaching surface waters quality (pollution) rivers) by runoff

Uncontrolled disposal of waste, oil and Change of water Groundwater Construction Negative Medium fuel leakage from construction vehicles quality (pollution)

Surface and Recultivation and development of Improvement of Beneficial / Operation - groundwater drainage system water quality Positive

V.3.2. Impacts on Soil Quality

Examination of soil quality in the vicinity of the tailings pond site Gradac (presented in Chapter IV) revealed that the analysed samples are contaminated with cadmium, lead, arsenic, fluorine, copper and zinc; where all of them multiple times greater than the regulatory MAC. Although the exact cause of this contamination could not be known, it can be said that the landfill is one of the contributors. However, the realization of this Project would create a positive impact on the area with regard to soil in the long run though stabilization and recultivation of the landfill.

The potential adverse impacts of the Project on soil quality would be due to use, fuelling, maintenance and repair of the construction vehicles, waste disposal and to a rather smaller extent dust generation and dispersion/deposition of the particulates on the lands around the construction sites.

The main impacts on soil quality would be during the construction phase, which is a limited duration. Most of the above mentioned potential adverse impacts could be easily controlled with standard measures. For example, forming designated areas with containment for vehicle washing, maintenance (such as oil changing, etc.), fuelling would prevent spilling of oil and fuel into the surrounding soil, and groundwater. In case of accidental oil and fuel spillage, necessary emergency actions such as cleaning off the spilled oil using an absorbent and removal of the contaminated

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surface layer of the soil would be implemented. Table V.5 summarizes the potential impacts of the Project on soil quality.

Table V.5. Assessment of Impacts on Soil Quality

Impact Affected Definition of Type of Significance Ecosystem Source of Impact Project Phase Potential Impact Impact Before Component Mitigation Dust dispersion from the landfill and deposition on the soils in Construction Soil contamination Negative Low the vicinity Inadequate maintenance and Soil fuelling of the vehicles and Soil contamination construction machinery at non Construction by spillage and Negative Medium designated areas, uncontrolled natural drainage waste disposal

V.3.3. Impacts on Air Quality

Main impact of the project activities on air quality would be dust generation and exhaust gas emissions. Dust would be generated from the dry surfaces with no vegetation coverage due to wind and operation of vehicles on these surfaces. In addition, when there is excavation, hauling and storing of materials dust is a potential impact to consider. Exhaust gases would be generated by the construction vehicles/equipment. These impacts will have a local character.

The emissions from construction vehicles are estimated based on the specifications and standards regarding the drive motors of the construction machinery/equipment and the planned number of machine hours. All the drive machines must meet the norms for the emission limits stipulated by the EU Directive 97/68/EC, which defines standards for the manufacturers.

The emissions provided below were estimated according to the standard values for off- road machinery, i.e. construction equipment for the standardised allowed emissions of CO, HC, NOx and PM10. Thus, construction machinery to be used would meet the guidelines for the EU Stage IIIb standards, but bearing in mind that the machines which were produced until 2006 are used; the calculation was carried out in line with the guidelines for the EU Stage III standard.

Table V.6 with the Stage III B emission standard shows general values of the emission of harmful gasses and dust (particulate matter), which were calculated according to data about the prevised working machines and their respective machine hours (calculation in line with EU Stage III). Considering that calculated emissions will represent the maximum allowed values, actual levels of emission will be lower. Thus, the estimated emissions may be seen as the worst-case scenario in terms of emission of exhaust gasses.

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Table V.6. Stage III B Emission Standard for Non-Road Diesel Engines

power CO HC NOx PM Cat. Date kW g/kWh L 130 ≤ P ≤ 560 2011.01 3.5 0.19 2.0 0.025 M 75 ≤ P < 130 2012.01 5.0 0.19 3.3 0.025 N 56 ≤ P < 75 2012.01 5.0 0.19 3.3 0.025 P 37 ≤ P < 56 2013.01 5.0 4.7* 0.025

*NOx+HC

The number of construction vehicles to be used at the same time and location will be the highest during the process of making surpass on the existing landfill, construction and repair of the peripheral embankments, and lining the surface with impermeable material. The list of construction machinery is provided in Table V.7 and the calculated emissions originated due to the operation of these machineries are provided in Table V.8.

Table V.7. List of Construction Machinery

Type of the Machinery Number of Machinery Trencher 1 Loader 1 Bulldozer 1 Rubber wheeled roller 1 Dump truck 4 Pick-up truck 2 Compactor 1 Grader 1

Table V.8. Calculated Total Emissions from Construction Machinery

Parameters Calculated Total Emissions (g/h) Limit Values (g/h)

NOx 108 1,263 CO 180 2,178 HC 34.8 115.2 PM 9.6 14.4

As seen from Table V.8, total emissions originated from construction machinery/equipment will be lower than the limit values. The estimated results indicate that use of these construction machines would not cause major negative impacts on air quality in the area.

During the operation phase of the Project, any impacts on air environment are not anticipated. Moreover, stabilization of slopes and recultivation of the entire site will minimize the current impacts of the site on air quality, especially observed during windy conditions. A photograph showing the site on a regular windy day is presented in Figure V.1. Therefore, the Project will have a positive impact on air environment.

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Figure V.1. Dust Generation of the Site during Windy Conditions

Table V.9 presents the potential impacts on air quality and impact significance.

Table V.9. Assessment of Impacts on Air Quality

Affected Impact Definition of Type of Ecosystem Source of Impact Project Phase Significance Potential Impact Impact Component Before Mitigation Exhaust gas emissions from construction Change of air Construction Negative Low machinery and dust quality generation Air Less dust Recultivation of the site formation and Beneficial / will lower its dust Operation - increased air Positive generation potential quality

V.3.4. Impacts of Noise

Emission limits for noise generated through the operation of machinery in the open spaces are determined by the EU Directives (2000/14/EC and 2006/42/EC) and they have been applied in this Project. Law on Environmental Noise Protection (“Official Gazette of Montenegro, No. 28/11, 28/12 and 1/14) and the Rulebook on threshold values of environmental noise, the method of determining the noise indicators and acoustic zones and methods of assessing the harmful effects of noise (“Official Gazette of Montenegro, No. 60/11) were applied for the assessment of potential noise impacts.

According to the Rulebook on threshold values of environmental noise, the method of determining the noise indicators and acoustic zones and methods of assessing the harmful effects of noise (“Official Gazette of Montenegro”, No. 60/11) and the Decision on determining the acoustic zones in Pljevlja, the tailings pond site area belongs to the Industrial zone.

In addition to the EU Directives and Montenegrin legislation, noise limit levels are also described under, Environmental, Health and Safety (EHS) Guidelines, General EHS Guidelines: Environmental Noise. The noise limit values are based on World Health Organization Guidelines for Community Noise. Noise levels defined by WBG are presented in Table V.10.

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Table V.10. Noise Level Guidelines of IFC

One Hour LAeq (dBA) Receptor Daytime 07:00 – 22:00 Nighttime 22:00 – 07:00 Residential, institutional, educational 55 45 Industrial, commercial 70 70

Noise generation from machinery and equipment to be used on the site during the land preparation and construction phase is quite possible. The list of machinery and equipment, which will be used during the land preparation and construction phase and are likely to cause noise, and their number and noise intensity levels are presented in Table V.11.

Table V.11. Machinery and Equipment and their Noise Intensity Levels (Lw)

Machinery and Equipment Number Noise Intensity Level (dBA) Truck 4 85 Pickup Truck 2 101 Trencher 1 115 Loader 1 115 Bulldozer 1 88 Compactor 1 111 Rubber-wheeled Roller 1 80 Grader 1 112

In order to assess the noise impacts of the activities that will be conducted during construction phase, the total noise generations should be calculated for the worst-case scenario and should be compared with the legislative and WBG requirements in order to have an idea. To satisfy this need, noise generation calculation is performed below with the assumption of worst- case scenario. The worst-case scenario assumes that all machines and equipment operate simultaneously at maximum noise intensity levels at the same location (at the center of the tailings pond site) in the Project Area.

The formulas given below were used for the calculation of noise levels regarding land preparation and construction phase of the Project. Formula (1) is used to calculate total noise level at the source according to noise intensity level of each equipment, Formula (2) is used to calculate the noise level that reaches a definite distance (Lpt), and Formula (3) used to include topographical absorption effect into consideration.

푛 wi/10 Lwt = 10 log ∑푖=1 10L (1) 2 Lpt = Lwt + 10log (Q/4πr ) (2) C1 = 5xlog(do/d) (3)

Lwt : Noise level at the source Lpt : Noise level that reaches a defined distance Q : Orientation coefficient/atmospheric reduction factor (assumed as 1) r : Distance from the source C1 : Topographical noise absorption d : Distance

As it is mentioned before, in the equations given above, it is accepted that construction equipment and machinery are used at the same physical location (at the center of the tailings pond site area), non-stop at maximum noise intensity levels (worst case scenario). Therefore, it is expected that in reality noise level caused by construction activities will be much smaller than the worst-case scenario calculation result.

푛 wi/10 Lwt = 10 log ∑푖=1 10L = 10 log (4x108.5+2x1010.1+1x1011.5+1x1011.5+1x108.8+1x1011.1+1x1011.2+1x108.8) DEVELOPMENT OF EIA AND UPDATE OF ESIA REPORTS FOR THE MINE TAILINGS DISPOSAL FACILITY GRADAC, PLJEVLJA Chapter V - Pg. 87/112 ESIA REPORT

Lwt = 119.7 dBA

The calculation of noise level that reaches to the nearest building (which is 250 m away from the center of the talings pond site) is as follows:

2 Lpt = Lwt + log (Q/4πr ) 2 Lpt (100m) = 119.7+10 log(1/4x3.14x250 ) Lpt (100m) = 60.8 dBA

Topographical absorption for 250 m:

C1 = 5xlog(do/d) C1 = 5xlog(1/250) C1 =-12 dBA

Lpt at 100 m by taking into consideration of topographical absorption

Lpt (250m) total= Lpt (250m) + C1 Lpt (250m) total= 60.8 dBA -12 dBA Lpt (250m) total= 48.8 dBA

The distribution of noise with respect to distance from the source is presented in tabular format in Table V.12 and graphically in Figure V.2. Environmental noise level decreases below the limit value defined for construction activities (70 dBA) at a distance about 52 m from the source. The closest receptor, which is a settlement, is located about 250 meters southeast of the center of the tailings pond site.

Table V.12. Distribution of Noise Generated Relative to Distance

Lpt with topographical Lpt with topographical Distance (m) Lpt (dBA) Distance (m) Lpt (dBA) absorption (dBA) absorption (dBA)

15 85.2 79.4 500 54.8 41.3

50 74.8 66.3 600 53.2 39.3

100 68.8 58.8 700 51.9 37.6

150 65.2 54.4 800 50.7 36.2

200 62.7 51.2 900 49.7 34.9

250 60.8 48.8 1000 48.8 33.8

300 59.2 46.8 1150 47.5 32.2

400 56.7 43.7 1300 46.5 30.9

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90,0 80,0 70,0 60,0 50,0 40,0 30,0 20,0 10,0 0,0 0 100 200 300 400 500 600 700 800 900 1000 1100 1200 1300

WBG Limit Value Lpt w/ Topography Absorption

Figure V.2. Distribution of Noise Generated in the Project Area with respect to Distance

As seen from the above, under the worst-case conditions, noise level near the closest building to the center of the tailings pond site caused by the construction phase of the Project is below WBG limit values. Moreover, it is unlikely in reality that all construction machinery and equipment are used at the same physical location and non-stop at maximum noise intensity levels (worst case scenario). In addition, as the construction activities will occur outdoors, it is expected that there will be a decrease in noise level depending on the distance due to the atmospheric reduction in real conditions. Similarly, massif structure enclosing the tailings pond site and vegetation cover are also among the factors that could reduce the impact during the dispersion of noise. However, since calculations are based on the worst-case approach, factors such as effect of location, atmospheric reduction, vegetation cover, etc. have not been taken into consideration. According to all these evaluations, it is expected that in real terms the noise level at the nearest building will be lower than the calculated value during the construction activities of the Project.

The proposed project activities would use limited number of construction equipment and would be conducted in a limited area, so vibration would be generated rather locally. Therefore, any impact of vibration would be rather insignificant and would not be felt by the nearby settlements.

The assessment of noise impacts majorly to be observed during the construction phase of the Project is summarised in Table V.13.

Table V.13. Assessment on Noise Impacts

Impact Affected Project Definition of Type of Significance Ecosystem Source of Impact Phase Potential Impact Impact Before Component Mitigation Local Construction Increase in noise Construction Negative Low Communities machinery/equipment levels

V.3.5. Impacts of Waste Generation

During the construction phase of the Project, there will be municipal waste generation including the wastes related with the construction machinery/equipment such as waste oil, oil filters, batteries/accumulators etc. There will be no excavation waste.

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On the basis of data on the machinery, which will be engaged at the project site, the following types and quantities of waste can be produced annually:

 waste engine oils (13 02 06* synthetic motor oils, gearbox and lubricating oils): 360 litres (approx. 315 kg)  oil filters (16 01 07*oil filters): 15-20 kg  batteries (16 06 01* lead-acid batteries): 120 kg  absorbents and wiping cloths (15 02 02* absorbents, filter materials (including oil filters that are not otherwise specified) wiping cloths, protective clothing, which are contaminated with hazardous substances): up to 30 kg  antifreeze (16 01 14*antifreeze which containing dangerous substances): 60 litres (approx. 68 kg)  brake fluid (16 01 13*brake fluid): 8 liters (approx. 7.8 kg)

The wastes arising from the Project activities would be disposed to the existing landfills or an authorized waste company would be engaged for their disposal, except for excess rock and soil, which will be disposed on-site, in accordance with the specifications of the municipality.

From this it can be concluded that the types and volumes waste generated during the construction phase of the Project will be small. Occasional hazardous wastes may arise from maintenance operations, clearance of drainage facilities and separators, and clean-up of accidental spills. The management of mentioned types of waste will be carried out in accordance with the construction contractor’s environmental and social management system (ESMS) documentation, which are needed to be in line with both IFC PS1 and WBG OP 4.01 standards and requirements. No significant impact is predicted to arise from resource use or waste disposal during operation in regard to maintenance of the landfill. Table V.14 summarizes the potential impacts and impact significance of waste generation.

Table V.14. Assessment of Impacts of Waste Generation

Impact Affected Definition of Type of Significance Ecosystem Source of Impact Project Phase Potential Impact Impact Before Component Mitigation Local Domestic waste and waste Communities Generation and generated due to use of Construction Negative Low and disposal of wastes machinery Environment

V.3.6. Impacts on Landscape Characteristics

The tailings disposal site has been in use for many years, which caused loss of land and change in landscape characteristics. The current landscape characteristics of the Project Area and its surroundings are presented in Chapter IV. Already imposed impacts of the site on the landscape and visual and aesthetic effect would be restored by recultivation of the entire site. In the construction phase of the Project, active works to be performed on site will create some adverse impacts on landscape, but it would not be more powerful than the current poor aesthetics of the landfill. Together with the completion of stabilization and recultivation works, the poor aesthetic image created by site itself will be eliminated. Overall, it can be said that the Project will have a beneficial/positive impact on the landscape characteristics of the region.

Table V.15 presents the potential impacts on Landscape and impact significance.

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Table V.15. Assessment of Impacts on Landscape

Impact Affected Project Definition of Potential Type of Significance Ecosystem Actual impact Phase Impact Impact Before Component Mitigation Visual impacts of Construction Negative Low construction activities Already realized impacts on the landscape will be Loss of land and visual Landscape reversed and, depending impacts Beneficial / Operation on the quality of - Positive restoration work, the area could gain significant value

V.3.7. Impact of Radioactivity

Although 2009 study performed by CETI on the measurement of radioactivity around the tailings pond site showed a compliance with the regulatory limit values, the stabilization and recultivation of the site will create positive impacts on the surrounding area, especially for river Ćehotina. The realization of the Project will prevent reach of stored material to river Ćehotina by erosion and surface run-offs; therefore, less radionuclides would reach to the river. Table V.16 presents the summary of the impacts of radioactivity.

Table V.16. Assessment of Impacts on Contents of Radionuclides in Surface Waters

Impact Affected Definition of Type of Significance Ecosystem Source of Impact Project Phase Potential Impact Before Component Impact Mitigation Less Content of radionuclide Beneficial / radionuclides in Stabilization and recultivation of the site Operation - reach to the river Positive surface waters Ćehotina

V.4. Impacts on Biological Environment

In this section, potential impacts of the Project on the biological environment are considered. Potential impacts will affect terrestrial flora-fauna and aquatic ecosystems directly or indirectly. Therefore, impacts of project activities can be further divided into the target group of biological elements as terrestrial and aquatic.

The following subsections define the potential impacts of the project considering the foreseen project activities during construction and operation. The potential impacts are assessed for terrestrial flora, terrestrial fauna, and aquatic environment, respectively. Mitigation measures to be taken in order minimize these impacts are also included in the assessments.

The impact of project activities on ecological components is related to the size of the impact and the vulnerability of the recipient. For terrestrial and aquatic flora-fauna species, size and significance of the effects according to the matrices presented below have been determined in accordance with the criteria determined according to the ecological sensitivities of the species. It is known that the features of each step in the systematic classification of species are different from each other and accordingly the shapes and dimensions of the influence from the Project will vary within themselves. Sensitivities of terrestrial flora and fauna species determined within the Project Area are explained in detail in the report. Criteria for significance for ecological components are explained in following topic.

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Impact Assessment Criteria

The impact assessment criteria for the impacts on ecology and biodiversity were determined, as high, moderate or low, based on the evaluation of magnitude of impact and sensitivity/value of the receptors/resources. IFC and OP 4.04 definitions are used in habitat and species assessments. These definitions are explained step-by-step.

According to OP 4.04, Annex A, Natural Habitats, Critical Natural habitats, Significance conversion and Degradation defined as:

“Natural habitats are land and water areas where (i) the ecosystems' bio-logical communities are formed largely by native plant and animal species, and (ii) human activity has not essentially modified the area's primary ecological functions. All natural habitats have important biological, social, economic, and existence value. Important natural habitats may occur in tropical humid, dry, and cloud forests; temperate and boreal forests; mediterranean-type shrub lands; natural arid and semi-arid lands; mangrove swamps, coastal marshes, and other wetlands; estuaries; sea grass beds; coral reefs; freshwater lakes and rivers; alpine and sub alpine environments, including herb fields, grasslands, and paramos; and tropical and temperate grasslands. “

“Critical Natural habitats: (i) existing protected areas and areas officially proposed by governments as protected areas (e.g., reserves that meet the criteria of the World Conservation Union [IUCN] classifications), areas initially recognized as protected by traditional local communities (e.g., sacred groves), and sites that maintain conditions vital for the viability of these protected areas (as determined by the environ-mental assessment process); or (ii) sites identified on supplementary lists prepared by the Bank or an authoritative source determined by the Regional environment sector unit (RESU). “

Significance conversion: Such sites may include areas recognized by traditional local communities (e.g., sacred groves); areas with known high suitability for bio-diversity conservation; and sites that are critical for rare, vulnerable, migratory, or endangered species.

Listings are based on systematic evaluations of such factors as species richness; the degree of endemism, rarity, and vulnerability of component species; representativeness; and integrity of ecosystem processes.

Significant conversion may include, for example, land clearing; replacement of natural vegetation (e.g., by crops or tree plantations); permanent flooding (e.g., by a reservoir); drainage, dredging, filling, or channelization of wetlands; or surface mining. In both terrestrial and aquatic ecosystems, conversion of natural habitats can occur as the result of severe pollution.

Conversion can result directly from the action of a project or through an indirect mechanism (e.g., through induced settlement along a road).

Degradation is modification of a critical or other natural habitat that substantially reduces the habitat's ability to maintain viable populations of its native species.”

The IFC Performance Standard 6 (IFC, 2012), Biodiversity Conservation and Sustainable Living Revenue Natural Resource Management rules were used to identify Critical Living Area in the study area. IFC criteria for identifying Critical Habitats include:

 Criterion 1: Habitats important for critical and/or endangered species;  Criterion 2: Habitats of significant importance to endemic and/or restricted species;  Criterion 3: Habitats containing significant intensive species or migrating species and/or indigenous species in the global sense;  Criterion 4: Highly threatened and/or unique ecosystems;  Criterion 5: Key evolutionary processes.

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Based on these criteria, sensitivity criteria for ecological components within the scope of the project have been determined.

V.4.1. Impacts on Internationally Recognised Areas within the Region of the Project Area

IFC PS6 states that internationally and/or nationally recognized areas of high biodiversity value are likely qualified as critical habitat. The project area is located in Ćehotina Valley as a candidate Emerald Network Sites. However, the scope of the project landfill actions will be rehabilitated and destruction of the landfill on biodiversity will recover. Also, Ćehotina River which were affected by landfill area in terms of water contamination will stop the negative impacts. The seepage of leachate into Ćehotina River will stop from landfill, which will stop the negative impacts on that Emerald area’s aquatic ecosystems. In the wider area there is the Ljubisnja Mountain as a potential Emerald and KBA area. The Project will not have any impact on this area, which is 9.6 km away from the Project site. Therefore, the internationally recognized area as assessed as being negligible. Therefore, no negative impact is expected on this site during execution of the Project. Significant indirect positive impact is expected on this zone.

V.4.2. Impacts on Terrestrial Habitat and Flora-Fauna

The tailings pond site has been in operation since 1954, which had already affected the vegetation and flora-fauna species. Because of the landfill, all habitat is lost and terrestrial fauna move away from the landfill. When rehabilitation activities will be done, ecosystems of the area would be recovering over the years.

There will be no loss of vegetation outside the project boundaries. The possible impact will be the opening of new access roads. However, this effect will already be eliminated by using the existing means of transport. Another direct impact of construction phase will be the vehicle traffic for construction. The fauna species, which have limited mobility, might be faced with fauna mortality. The risk of crushing will increase as the animals crossing the road. Some of the expected indirect impacts will be as follow;

 Alien species invading the altered ecosystems,  Changes in the composition of soil and water quality  Changes in air quality (dust generation, etc.),  Solid and hazardous wastes to be generated due to project activities,  Noise pollution that might impact species’ behaviour especially that of fauna elements.

Magnitude, severity and significance of impacts for terrestrial habitats and flora-fauna are shown in Table V.17.

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Table V.17. Assessment of Impacts on Terrestrial Habitats and Flora/Fauna

Impact Affected Definition of Type of Significance Ecosystem Source of Impact Project Phase Potential Impact Impact Before Component Mitigation The risk of crushing will increase as the animals crossing the road

Alien species invading the altered ecosystems Disturbance of fauna Changes in the composition of species in the vicinity soil and water quality of the Project area

Changes in air quality (dust Construction Negative Low Loss of flora generation, etc.) populations in the

Solid and hazardous wastes to vicinity of the Project area Terrestrial be generated due to project Habitats and activities Flora/Fauna Noise pollution that might impact species’ behaviour especially that of fauna elements Landfill already converted the Formation of new modified habitat (loss of vegetation on the vegetation) and due to the high Project area anthropogenic elements in the area the fauna species moved Creation of new Beneficial / Operation - away from the site. With the habitats for fauna Positive implementation of the project, species. biodiversity will improve and the ecosystem balance will be To reach ecological restored. balance

V.4.3. Impacts on Aquatic Environment

Ćehotina River, which passes under the landfill area on the north-northwest border, has important biodiversity features. Deposited tailings contaminate the river by erosion and mixing with precipitation. These issues affect both the water quality and the bottom structure of the river negatively. Therefore, the biodiversity of the river is currently under threat due to the tailings pond site.

Mine wastes will not be discharged anymore to the area after the project is realized. Therefore, the pollutants reaching into the river due to wastes will be eliminated. This will have a positive impact on the river. During construction, the impacts on river Ćehotina might be as follows;

 Water pollution due to discharge of construction wastes into the river  Intervention of the river flow and deterioration of the bottom structure of the river  Increased sedimentation  Discharging chemical wastes to the river during construction  Construction equipment to pass over the river to contaminated the water quality of the river and to destroy the bottom structure  Magnitude, severity and significance of impacts for aquatic habitats and flora-fauna are shown in Table V.18.

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Table V.18. Assessment of Impacts on Aquatic Habitats and Flora/Fauna

Impact Affected Definition of Potential Type of Significance Ecosystem Source of Impact Project Phase Impact Impact Before Component Mitigation Disturbance for freshwater fish species The pollutants are mixed with

rainwater and reaches to Construction Changes in the Negative Low Aquatic Ćehotina River and/or composition of sediment Habitats and contaminate the river by erosion and water quality of the Flora/Fauna Ćehotina River Reach of pollutants into the river Improved conditions for Beneficial / due to deposited material will be Operation aquatic habitats in - Positive eliminated Ćehotina River

V.5. Impacts on Socio-economic Environment

V.5.1. Impacts on the Local Population

The socio-economic situation of the local people of Gradac had become very difficult after the closure of Šuplja Stijena and the locals who became unemployed had to migrate from the region. Currently, about ten households reside in Gradac. In addition, residents of Gradac are exposed to toxic dust and contaminated groundwater in the environment. Since the environmental conditions will improve when the project is realized, it is foreseen that local residents will be in a more comfortable environment. The improvement in the environmental conditions might attract new residents to the region.

V.5.2. Impacts on Economy and Livelihoods

Although the project will not create many job opportunities, in such a case the priority for employment during the construction phase of the remediation will be given to local people. This will lead to an increase in local employment potential. In addition to that, consideration of local sources in the procurement processes might also have positive impacts on the local economy.

The construction work related to the remediation can be tendered nationally or internationally according the WB procurement procedure. It is expected that national procedure will result in more input from companies located in Montenegro whereas the exchange of knowhow will be less. Impacts on economy and livelihoods are summarized in Table V.19.

Table V.19. Assessment of Impacts on Economy and Livelihoods

Impact Affected Project Definition of Potential Type of Significance Ecosystem Source of impact Phase Impact Impact Before Component Mitigation Employment and trade Construction works Construction Positive - opportunities

Opportunity of having Local economy clean environment and the Stabilization and and livelihoods improvement in the recultivation of tailing pond Operation Positive - environmental conditions site might attract new residents to the region

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V.5.3. Impacts on Local Public Infrastructure

The proposed Project would not have any significant impact on public infrastructure. There would not be any damage to such infrastructure and use of the infrastructure for project activities would not cause any adverse impact on other users.

V.5.4. Community Health and Safety

Key identified reasons for potential negative effects on community health and safety will be seen in air, soil and water pollution as well as noise. Previous sections presented the results of relevant assessments and it could be seen that the proposed Project would not have significant effects on the health and safety of the community. The only negative impact of the Project on community health and safety would be related with the use of construction machinery and traffic related risks. In order to manage the traffic impacts, the construction contractor would be advised to prepare a Traffic Management Plan that will be in line with IFC PS1 and PS4. Moreover, once the Project’s construction phase ends, the traffic impacts will disappear.

In the operation phase of the Project, together with the anticipated improvements in the environmental characteristics of the region, the current community health and safety threats that the tailings pond site creates will be eliminated. However, any emergency situation to be experienced during the operation phase should be considered prior the commencement of works for the Project.

The overall assessment of the impacts on community health and safety is presented in Table V.20.

Table V.20. Assessment of Impacts on Community Health and Safety

Impact Affected Definition of Type of Significance Ecosystem Source of impact Project Phase Potential Impact Impact Before Component Mitigation Vehicle movements and traffic Construction Traffic accidents Negative Low Emergency situations Community Emergencies (natural should be managed in Health and Construction / disasters, failures, accidents order to prevent Negative Low Safety Operation etc.) community health and safety risks

V.6. Impacts on Cultural Heritage

Natural resources, which have specific values, are located in the wider area regarding the project site. Although any impacts are not anticipated regarding the Project on cultural heritage, possible interactions with chance finds are possible during the construction phase. In such a case, construction works will be stopped immediately. In case of result of any damage on protected areas or cultural assets due to the Project during construction and operation phases, the damage will be compensated by the construction contractor. In case of a chance find, the communication with the relevant stakeholders will be performed. In addition to the national legislation, the provisions of IFC PS8 and WB OP 4.11 will be followed and complied during all phases of the Project.

V.7. Occupational/Workers Health and Safety

Regarding the context of the Project, OHS is an issue only related the construction phase and is an integral part of project management. The project owner has already established procedures and practices related to the OHS requirements in line with national legislation and international practices as a part of its management system. During the realization of the project potential OHS impacts would be mainly the risk of accidents associated with construction works, DEVELOPMENT OF EIA AND UPDATE OF ESIA REPORTS FOR THE MINE TAILINGS DISPOSAL FACILITY GRADAC, PLJEVLJA Chapter V - Pg. 96/112 ESIA REPORT

therefore the construction contractor is needed to have a management plan for the OHS that is in line with national and international standards and the management system of the project owner. These impacts are summarized in Table V.21 together with their significance.

Table V.21. Assessment of Impacts on Occupational Health and Safety

Impact Affected Definition of Type of Significance Ecosystem Source of impact Project Phase Potential Impact Before Component Impact Mitigation Workers Construction activities Construction Incidents Negative Medium

V.8. Summary of the Environmental and Social Impacts and Mitigation Measures

In the present situation, the tailings pond site Gradac has various adverse environmental and social impacts. As a result of the implementation of the Project, an overall significant positive impact on the environment is expected. However, during the construction works; there would be rather short term, temporary negative impacts with low to medium significance as provided in the previous sections. There would not be any cumulative or transboundary impacts due to the Project in the scope and location of the Project. There would be temporary positive social impacts (such as employment) during the construction phase as well.

In terms of biological impacts, negative biological impacts would have a low significance while some significant positive impacts would also be expected primarily with regard to reducing the pollution of the Ćehotina River valley. Table V.19 summarizes the potential adverse impacts and proposed mitigation measures together with significance for the potential and residual impacts. The expected positive impacts, the subjects where no impacts (i.e. cumulative and transboundary impacts) are expected and the negligible negative impacts are not included in Table V.22.

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Table V.22. Summary of the Impact Assessment and Mitigation Measures (before and after Project Implementation)

Impact Significance Environmental and Significance Mitigation Measures of Residual Social Factor Before Mitigation Impacts Land Preparation and Construction Phase  Slopes of the tailings pond site would be stabilized, strengthened with gabions and recultivated to reduce potential for surface erosion in accordance to the design. Erosion, Landslide and Medium  During geotechnical works, permanent surface protection (i.e. covering with protective film) of the slopes will be ensured. Low Land Use  Suitable warning signs (landslide risk, slippery conditions, etc.) and reflective markings indicating steep slopes would be located in line with good engineering practice or as agreed with the local authorities.  Driving of machinery within surface water, streams or on their banks will be prevented.  Maintaining, refuelling and cleaning of construction machinery will be carried out at dedicated locations with proper containment and drainage and related waste material would be stored at a controlled area.  Training will be provided to machine operators regarding sensitivities and working procedures in works near water. Surface and  All machines and equipment will be checked for leaks prior to use. Groundwater Resources Medium  Oil and fuel will be stored in places with secondary containment. No drums will be placed directly on the ground. Low (Water Quality)  Storage and handling of fuels, oils and other hydrocarbons will be controlled, involving measures to prevent soil and water contamination. Designs will include storage on sealed surfaces and within secondary containment and refuelling of all plant, vehicles and machinery will not be allowed within 50 m of any watercourse.  Precautions such as planting against erosion will be taken.  Preparing site specific emergency plans to respond to any incidents or spillages of hazardous material to water environment.  Limiting the construction area/work sites  Parking, washing, maintenance and fuelling of the construction machinery would be done at designated sites with concrete ground and in the event that soil is contaminated by spillage, affected layer would be removed in line with the relevant regulation and internal management plans.  All packaging waste material for oil and other petroleum derivatives would be stored at a designated area. Soil Quality Low/Medium  Storage and handling of fuels, oils and other hydrocarbons would be done at designated areas with solid grounds (not soil) Low and located at least 50 m away from any watercourse.  Opening of non-controlled and unplanned access roads to any part of the Project site will be forbidden  Systematic collection of solid waste during construction (including food and material packaging, and other types of waste) would be undertaken and wastes would be disposed at licensed facilities specified by national authorities  Drainage channels will be constructed in accordance with the topographical conditions of the Project Area. Since the impact significance is low standard mitigation measures would be employed:  Frequent watering of work grounds will be done during dry periods and water intended for this purpose must be used in quantities that will not result in generation of run-off  Speed limits will be enforced on the Project area and public roads to limit the levels of dust generation. Air Quality Low  Vehicles delivering material will be covered. Low  All vehicles, equipment and machinery used for construction will be regularly maintained and inspected/certificated to ensure that the exhaust emission levels conform to the standards prescribed.  No works causing dust formation are allowed when strong wind is blowing in the direction of the settlement Gradac.  Loading and unloading will be carried out without scattering

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Impact Significance Environmental and Significance Mitigation Measures of Residual Social Factor Before Mitigation Impacts Since the impact significance is low standard mitigation measures would be employed:  Raising workers awareness on the noisy activities  Construction time will be limited to day-hours (07.00 to 19.00)  Use of modern equipment and machines with noise suppressors  Regular maintenance of construction vehicles and equipment Noise Low Low  Avoiding the simultaneous operation of several noisy machines, when possible  Using natural acoustic barriers or screens around the machines, such as trees and topographical factors, in case of a grievance  Regular maintenance of access and temporary roads and limiting the speed of vehicles  Leaving engines idling at the site will be avoided unless absolutely necessary. Since the impact significance is low standard mitigation measures would be employed:  Systematic collection of solid waste during construction (including food and material packaging, and other types of waste) Wastes Low Low would be undertaken and wastes would be disposed at licensed facilities specified by national authorities  All packaging waste material for oil and other petroleum derivatives would be stored at a controlled area.  Preparation of a landscape restoration plan in line with the remediation design including the realistic requirements to Landscape Low Low minimize short term visual impacts from the site operations and to maximize the long-term recovery potential of the landscape  Clearing up and removal of vegetation will be minimized to the extent necessary for the execution of works, including riparian vegetation along the river Ćehotina  Proper implementation of rehabilitation measures from the design which envisage the complete isolation of the deposited toxic material by a waterproofing layer (with humus) in order to restore the flora and then the fauna of the site  Perform a permanent covering of cut parts of landfill body with protective film in order to avoid a rinsing of the polluted loose material towards surrounded habitats.  Restoring the site with native plants Terrestrial and Aquatic Low Low Flora and Fauna  Set established rules for the workers on the ban on lighting fires, collecting birds' eggs, disturbing and hunting of wild animals and birds, destroying of floral species and similar  Scattering of wastes with the wind within and out of the project area will be prevented by collecting and temporary storage of waste at designated areas.  Vehicle speeds will be limited to prevent any accidents causing animal death and no new roads would be opened unless approved by relevant authority.  Incineration or burying of wastes by any means at site and/or dumping of wastes to nearby roads or water resources will be absolutely prohibited. Community Health and Low  The construction contractor will develop and implement a Traffic Management Plan to manage traffic related risks Low Safety  Limited working hours ( 07 - 19 h) to avoid nuisance of the population living near the tailing pond Gradac  The excavation and similar works should not be performed during strong wind to avoid the spreading of the dust toward the settlement Gradac Social issues Positive Positive  Waste disposal or storage near the settlement must be avoided  Locals will be given priority for temporary employment during construction  Appropriate disclosure of information and consultation with affected persons and community will be implemented.

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Impact Significance Environmental and Significance Mitigation Measures of Residual Social Factor Before Mitigation Impacts Since the impact significance is low, standard mitigation measures would be employed:  Contractor will follow the national requirements with respect to “chance finds” which may emerge during construction.  Contractor is not allowed to perform excavation, demolition, alteration or any works that may harm the properties of any Cultural Heritage Low Low cultural monument.  In case of chance finds, the Contractor shall mark and secure new identified sites (with a protective railing or other means of protection) to avoid damage and immediately notify the relevant authority.  Include both management measures and reporting and investigating any incidents, i.e. Implement international HSE standards in all contracts  Identify potential risks before commencement of works. The emergency response provisions will include an OHS Management Plan, which will also indicate a contact person available in the event of an accident. OHS Management Plan will be submitted to the project owner for approval. Contractor will ensure the following in terms of workers/occupational health and safety:  Drugs and alcohol usage are forbidden on site. Workers (Occupational) Medium  Contractor is to include a provision for safe working environment and safety measures and personal protective equipment Low Health and Safety (PPE) for all workers in its OHS Management Plan, including gloves, hard hats, goggles, ear protection and safety footwear.  OHS Management Plan is to include a provision for first aid to be administered on site and a trained person must be engaged in line with the Law on Occupational Health and Safety (Official Gazette of Montenegro, No. 034/14).  Contractor shall provide to his workers potable water supply, toilets and water supply for washing.  Safety Labour Management Plan (SLMP) is required to ensure health and safety provisions  Contractor shall perform all project activities following the SLMP and all Montenegrin laws and by-laws Operation Phase Water quality (surface None/Negligible  Regular cleaning and maintenance of the water drainage system None/Negligible and ground water)  Checking and recording germination success of planted areas Flora (planted surface) None/Negligible None/Negligible  If it is necessary, repeat sealing and planting by using of native species Erosion and land None/Negligible  Maintenance of the slopes when necessary None/Negligible stability  The project owner should develop and implement the Emergency Action Plan for all potential natural disasters, failures and Emergency situations accidents, also covering community health and safety aspects. Low Low (e.g. accidents)  To avoid landslides on the slopes and embankments, technical requirements in line with the Main Design and Emergency Action Plan will be implemented Other Environmental  In the operation phase of the Project, no adverse/negative impacts are anticipated other than the emergency situations. For and Social - the operation phase, mostly monitoring activities are suggested and these are presented in the Environmental and Social Management - Characteristics Plan (Chapter VII).

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VI. PROJECT ALTERNATIVES

This section discusses the remediation of the Gradac disposal site planned to reduce contamination of natural resources and health risks and further process alternatives for the mine tailings disposal facility, where the Project assessed in this ESIA is a part of the preferred alternative. Following this discussion, the alternatives in the Project are evaluated; including alternative methods for construction, and alternative methods of remediation of the dump site. In this context the reasons for selecting the preferred/proposed alternative is also provided. Before the discussion on how to proceed with the proposed activities, the “no action” alternative, which represents the continuation of the current status without any intervention, is presented as well.

VI.1. No Action/Project Alternative

This scenario implies the situation in which the current activities continue as usual, without any action to minimize the current or future negative impacts or risks.

In case of the project is not actualized, the situation will continue and the current negative impacts from the site and the risk of dam collapsing will continuously represent a risk for the environment and for humans. Therefore, considering the aspects of environmental quality and public health, the “no action” alternative is not considered as a reasonable alternative.

VI.2. Remediation Alternatives

1. Excavation of the tailing material and re-disposal at another dump site; 2. Minimizing the erosion effects by partial heightening of the dam and constant water cover of the pond; 3. Geotechnical securing and sealing of the tailings slopes, surface sealing and installation of a drainage system for snowmelt and precipitation water and construction of adequate drainage channels at the upper boundary area of the tailings pond.

VI.2.1. Alternative 1: Excavation

This alternative includes a complete excavation of the tailing material and re-disposal at another dump site either inland or abroad. The excavation of the dumped material would have taken several years and during the excavation, the material would have been exposed to constantly changing weather conditions. The excavation and re-disposal are very costly and would require further geotechnical investigations and planning.

VI.2.2. Alternative 2: Minimizing the Erosion Effects

This alternative is a geotechnical securing measure which involves partial heightening of the dam to ensure protection against erosion. Alternative 2 also includes constant water coverage of the pond to prevent spreading of contaminated dust particles but no measures to prevent leaching processes by seepage water percolating through the dump body.

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VI.2.3. Selected Alternative 3: Sustainable and Long-Term Securing of the Tailings Dumpsite

This alternative aims for the safe enclosure of the contaminated flotation material to eliminate any release of contaminated material (seepage water, eroded material) into the environment. It includes the geotechnical securing and sealing of the tailings slopes, a surface sealing and installation of a drainage system for melt and precipitation water.

The inflow of melt and rain water from the surrounding mountains on the tailings pond will be minimized by constructing adequate drainage channels. These channels will be installed at the upper boundary area of the tailings pond in form of a ring channel.

In summary, this remediation alternative includes:

1-Geotechnical securing of the slopes 2-Surface sealing 3-Installation of a drainage system for melt water and precipitation 4-Recultivation of the top layer (optional)

Geotechnical securing of tailing slopes

In order to reduce erosion/landslide risks and to ensure the efficiency of the surface sealing, the slopes have to be reshaped and sealed. To avoid damage to the sealing membranes a combination of a protection layer and a geotextile will be applied. In addition, during high -water events gabions will be installed at the foot of the slopes in order to protect the reshaped slopes.

Alternatives for shaping of the slopes

The slopes need to be reshaped in order to prevent the ingress of the precipitation water via slopes. The slopes can be reshaped in two ways:

1-Shaping the slopes with flotation material (removal of slope material and backfilling of the erosion rills with recovered material)

2- Backfilling the erosion rills with material or smaller grain-sizes (e.g. sand, limestone grit)

Surface Sealing

The tailings consist of very fine silty material and are therefore easily eroded by water and wind. A sealing layer comprising of a plastic liner has been recommended to prevent contaminated material from being spread to nearby areas by wind erosion

Drainage System

Drainage system with the ring channel construction is necessary to prevent surface runoff, such as melt and rainwater, from surrounding mountains from flowing onto the tailing ponds. This will reduce the risk of erosion/landslides.

Advantages and disadvantages of the selected remediation alternative are given in Table VI.1 below:

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Table VI.1. Advantages and Disadvantages of the Selected Alternative

Advantages Disadvantages  Flotation material can stay on-site  Costs for the construction measure  No costs for disposal of the contaminated tailings  Proof must be provided for the stability of the material existing dams and embankments  Melt water and rain water will be led off in a  Further geotechnical investigation and planning controlled manner necessary  Minimization of erosion effects (wind, heavy rain  Availability of suitable brown coal ash must be events secured  Elimination of seepage water flowing through the  Preliminary testing of the stabilizing properties of tailings body the chosen brown coal ash is necessary  Continuous reduction of drainage water outflow at  Future monitoring is necessary the dump foot until near cessation  Drying-out of the tailings over the years  Lower costs for the additional construction measures compared to alternative 1  Smooth and sound use of brown coal ash from the Thermal Power Plant Pljevlja (if applicable)  No additional costs for amendment material (if applicable)  Recultivation of the tailings pond surface and subsequent use is possible

VI.3. Comparison and Assessment of Alternatives

In the scope of the Gradac landfill remediation project, a multi criteria decision analysis has been conducted during the comparison of remediation alternatives considered for the Project. The following criteria have been taken into consideration in order to select the most convenient alternative among three proposed alternatives. Multi criteria decision analysis which includes criteria which have been taken into consideration during assessment of alternatives is shown in Table VI.2 below:

Table VI.2. Multi -Criteria Decision Analysis

Criteria Evaluation Environmental and Social merits and risk Environmental risks reduction and nuisance for local inhabitants Technical feasibility and risks The availability for realization of works Operational feasibility The level of complexity of remediation works and logistics Legal feasibility The risk of not getting required permits and permissions Duration of the work Estimated execution time till completion of the remediation Costs Estimated costs

These criteria are graded according to importance by weighted percentage and percentile. According to the treatment technology, each criterion is given between 0 and 5 points (5 best points, 1 weakest point, 0 ineffective points). Weighted scores were obtained by multiplying the importance grade and the technology score, and the total score was obtained by their aggregation. It is accepted that the technology alternative with the highest total score is the most feasible option. Table VI.3 shows the results of the evaluation.

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Table VI.3. Comparison of Remediation Alternatives

Concept Significance Level Alternative 1 Alternative 2 Alternative 3

Environmental and social merits and risks 20 3 3 4 Technical feasibility and risks 10 3 4 5 Operational feasibility 10 3 4 4 Legal feasibility 15 3 4 4 Duration of the work 10 3 5 5 Costs 20 4 4 5 Total (weighted score) 100 2.77 3.30 3.80

Table VI.3 compares the advantages and disadvantages of the three different alternatives. In the scope of environmental and social merits and risks, Alternative 3 achieves several important goals for providing a flotation pit at the site and causes steep slopes to be re-shaped to stop the current erosion effect, especially during heavy precipitation and high-water levels. When compared to other alternatives it is more feasible in terms of environmental and social risks.

In terms of technical feasibility, Alternative 1 is hardly feasible since there is no landfill for hazardous waste in Montenegro, and the export is extremely expensive.

Since there is no location for the disposal of hazardous waste in Montenegro, Alternative 1 is hardly feasible in terms of operation when compared to Alternative 2 and Alternative 3.

As a result of the analysis of all of the criteria and evaluation of the feasibilities of the three alternatives, Alternative 3 was selected as the most convenient alternative for the remediation of Gradac landfill.

VI.4. Environmental and Social Assessment of Alternatives

The Project (being assessed in this ESIA report) has been covered in alternative 3, which is the preferred option. As the option chosen for remediation, alternative 3 provides the safe enclosure of the tailings and eliminate release of contaminants into environment. In the scope of the project, drainage water discharge at the dump foot will be reduced and risk of groundwater contamination will be minimized. Since envisaged channel and drainage system will collect snowmelt and rain water in a controlled manner, percolation of seepage through the tailings body will be prevented. Costs for re-location and disposal of the contaminated tailings material are saved. Table VI.4 summarizes main environmental and social impacts of these three alternatives.

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Table VI.4. Environmental and Social Impacts of Alternative Projects

Alternative Impact 0. No project alternative Significant negative impact for human and environmental exposure Significant negative impact on the local community due to heavy traffic Significant negative impact on the local community due to release of potentially contaminated dust particle during the excavation Significant negative impact due to risk of mobilizing the contamination 1. Excavation of the tailings and re-disposal at during the excavation with potential for impact on surface water and another dump site groundwater Significant positive impact on the environment as the contamination is removed Significant positive impact as risk of dam collapse is eliminated

Positive impacts on minimizing the risk of release of potentially 2. Minimizing the erosion effects by partial contaminated dust particles heightening of the dam and constant water cover The existing negative impact on surface water and groundwater will of the pond remain Significant positive impact as the risk of dam collapse is eliminated

3. Geotechnical securing and sealing of the Negative impacts on the air quality and noise due to construction works tailings slopes, surface sealing and installation of Possibility of negative impacts on water quality during the construction a drainage system for melt and precipitation works water and construction of adequate drainage Significant positive impacts on erosion and landslide problems of the site channels at the upper boundary area of the once the construction phase finished tailings pond. Significant positive impacts on environmental characteristics of the region

In addition to the abovementioned considerations, the main factors associated with the Gradac site were also determined. These factors are:

1-Remote location 2-Composition of the material 3-High potential risks for erosion and landslides, and 4-Contaminant dispersion by wind erosion

The consideration of all alternatives showed that the alternative 3 is the most suitable method as it provides a sustainable and long-term solution for the Gradac site.

Significant positive impact on environment is expected when the remediation measures have been implemented. Impacts associated with soil erosion and exposure to contamination with direct contact with soil is mitigated with surface sealing. Exposure to contaminated dust and air is reduced also by surface sealing.

The remediation will have a positive impact on the local environment at Gradac Donji: Some residents may find short-term employment with the contractor responsible for the remediation, and there may be minor increase in economic activity and skills development for the local community.

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VII. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

Environmental and Social Management Plan (ESMP) is mainly based on mitigation and performance improvement measures and actions that address the identified environmental and social issues, impacts and opportunities. Within the scope of the plan, mitigation measures and actions are identified at the all stages of the project (i.e. land preparation and construction, and operation phases) in compliance with the relevant Montenegro Legislations and international requirements.

The major purpose of ESMP is to document key environmental issues, the actions to be taken to address them adequately, as well as any actions to maximize environmental benefits, the schedule and person/unit responsible for implementation and monitoring, and an estimate of the associated costs. For each of the component of the ESMP, a framework for the related management plan is provided in this chapter. Detailed management plans will be prepared within the scope of the project, in accordance with these frameworks. In Annex-2, ESMP for construction and operation phases of the project in addition to relevant monitoring activities are provided.

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VIII. PUBLIC PARTICIPATION AND INFORMATION DISCLOSURE

For the purpose of the project, ESIA and ESMP studies are being carried out and public consultation will be organized in accordance with the WB’s safeguard policies and procedures OP/BP 4.01 on Environmental Assessment, whereby mine tailings pond site Gradac shall meet requirements of the environmental Category A – type investment standards.

VIII.1. Previous Public Consultation for ESIA of Remediation of Five Contaminated Sites

Component 1 of the IWMCP is comprised of investigation and subsequent remediation of the five selected contaminated industrial sites. The following sites were selected for this purpose:

 Aluminium Plant Podgorica  Steel Plant Nikšić  Thermal Power Plant Pljevlja  Adriatic Shipyard Bijela  Gradac flotation tailings pond.

In the scope of IWMCP activities and following activities of the tailings disposal site on various studies and associated public consultation activities were conducted. These activities are listed chronologically and summarized in Table VIII.1.

Table VIII.1. Chronological Overview of Development of Previous Documentation

Public Discussion Venue / Mode of No. Date Conclusions Informing ESIA of Remediation of Five Contaminated Sites 1 10 April 2012 Local Municipality Hall Gradac First Public consultation 2 12 July 2012 Municipal Administrative Unit Gradac Second Public consultation

The second public discussion was held at the municipal administrative unit in Gradac on 12 July 2012, at15:30. The consultations were attended by six people, apart from four representatives of the NEPA and six representatives of the Developers (COWI and CDM-Consultants) who led the public discussion. Minutes were taken during both public discussions. Reports on the public consultations which were held represent one of the components of the final version of the document “ESIA for the purpose of remediation of 5 ecological black spots”.

VIII.2. General Approach for Public Consultation

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During an ESIA, public consultation and disclosure of information are conducted to ensure collaboration of local authorities, local non-governmental organizations and local affected community in the project area. Community’s involvement is one of basic conditions to ensure local support and it also represents viewpoint of local authority and community on the project. By public consultation, some undefined advert impacts and mitigation measures can be identified and added in the Second Draft ESIA/ESMP Report. In practice, it will be better for information exchange and update between project’s implementer and the community if there is public involvement from the project preparation. In that case, the project can get valuable idea contribution from local community. In this context objectives of the Public Consultation are:

 To share all information on the activities of the project with Stakeholders (local communities and local authorities;  To gather opinions/comments and concerns from local authorities and the community on local particularities and environmentally sensitive matters in the project area, especially those one that the environmental assessment impact group has not been aware of. On such basis, the concerns of the local community may be proposed for proper settlement during the selection of project design options;  To collect opinions/comments from the local community on the project’s tasks in the preparation of the ESIA as well as comments on the First Draft ESIA/ESMP to adequately and precisely assess environmental impacts and propose the most effective and feasible mitigation measures for negative environmental impacts.

Stakeholders are considered to include all organizations and individuals who may be affected by these investments and associated infrastructure or who have an interest in them. These may include elected representatives, government authorities and other public bodies, affected people and their representatives, commercial and community enterprises, NGOs representing environmental, social, labour, commercial and other interests, academic and research organizations, international bodies, representatives of civil society and the public.

Specifically, public involvement is a valuable source of information on key impacts, potential mitigation measures and the identification and selection of alternatives. It also ensures the ESIA process is open, transparent and robust, characterized by defensible analysis. At a minimum, public involvement must provide an opportunity for those directly affected by a proposal to express their views regarding the proposal and its environmental and social impacts.

Public participation is an active and constructive exchange of information, meanings, and opinions. The public has many roles such as:

 Provide data and information that is essential for the assessment of impacts on the physical and social environment  Reduce conflicts through the early identification of contentious issues  Help to identify local citizens and groups with special expertise  Identify local and regional issues  Provide historical perspective to current environmental conditions  Help to generate field data  Provide criteria for evaluating the significance of identified impacts  Suggest forms and help organizing mechanisms for public participation  Help to define the scope of work and schedule for the overall assessment process  Provide a link between the assessment team members and key organizations  Identify and evaluate potential mitigation measures  Increase public confidence in the ESIA process.

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The main principles of effective stakeholder engagement include:

 Providing full and meaningful information in a format and language that is readily understandable and tailored to the needs and culture(s) of the target stakeholder group(s);  Providing information in advance of consultation activities and decision-making;  Disseminating information in ways and locations that make it easy for stakeholders to access;  Respect for local traditions, languages, time frames, and decision-making processes;  Multi-directional dialogue that gives all sides the opportunity to exchange views and information, to listen, and to have their issues heard and addressed;  Inclusiveness in representation of views, including women, vulnerable persons and/or minority groups;  Processes free of intimidation or coercion;  Inclusive engagement and meaningful participation of those directly affected;  Clear mechanisms for responding to people’s concerns, suggestions, and grievances; and  Incorporating feedback into project or program design, and reporting back to stakeholders.

VIII.3. Public Consultation for ESIA/EIA Elaborate

The Public participation and information disclosure aims to ensure that the environmental and social impacts expected from remediation of the mine tailings disposal facility in Gradac- Pljevlja, described in this First Draft ESIA/ESMP including all the mitigation measures proposed, are communicated to and understood by all those concerned and that stakeholders are consulted on issues that directly affect them.

In this regard, the Stakeholders will be categorized into two groups: primary and secondary stakeholders. Primary stakeholders are those one directly affected by the development intervention either positively or negatively (citizens of Gradac and surroundings). The Consultant should pay special attention to their comments and needs. Secondary stakeholders are those who influence a development intervention or those that are affected indirectly by the proposed project (see Table VIII.2).

After the approval for the First draft ESIA/ESMP, the Investor – NEPA IWMCP PMU, will inform authorities, organizations and the public concerned about the manner, time and venue for public access to the reports, submission of opinions and remarks, as well as the time and venue for holding the public meeting on the ESIA. The public debate may not be held sooner than 7-10 days from the day when the authorities, organizations and the public concerned were informed and documents made available. The information about the public participation and disclosure of the documents will be published in one printed media, on the web site of the IWMCP, and direct invitations will be in place (mostly send via email) to the stakeholders identified in the below Table VIII.2. Hard copies will be made available in the NEPA.

The information about the public debate will be also printed and posted at the Gradac community board. Public participation meeting shall be organised and chaired by the IWMCP management and Competent Authority. The project developer and at least one person who participated in the ESIA/EIA report shall participate in the public debate. Presentation of the ESIA and findings, collection and appropriate address of the comments and remarks during the debate, report on the process and public participation meeting, and integration of the findings from PPM will be responsibility of the ESIA Consultant. Minutes including questions and answers from this meeting should be included in final ESIA report.

In the case the public consultation is organised together with the public meeting envisaged for the EIA elaborate, the provisions of the EIA law on the public participation should be respected (Law on Environmental Impact Assessment; Official Gazette of Montenegro No. 75/18).

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The approach (method) of communication should not be intrusive and should be sensitive to the customs and lifestyle of the local people. They should have the opportunity to contribute through their traditional knowledge. The communication with the local people that are familiar with traditional knowledge should be established at the very beginning. Their information about the site could be precious, and their early involvement could be to the mutual benefit.

After PPM, ESIA consultant shall submit the Public participation report to the IWMCP PMU for approval, and consequently second draft ESIA with integrated findings from the participative process.

Within seven days from the public debate, the Competent Authority shall submit the EIA to the Environmental Impact Assessment Commission together with the remarks and opinions obtained during the public consultations.

VIII.4. Public Consultation after Completion of the First Draft ESIA/ESMP

During the process of ESIA/ESMP preparation a public consultation meeting (PCM) will be planned in line with the WB OP/BP 4.01, following the completion of the draft ESIA/ESMP. The Public consultation was open to all interested parties/stakeholders. For the Project, main stakeholder groups are provided in below:

 Citizens of Gradac and surroundings  Local Government of Pljevlja  MORT - Ministry of Sustainable Development and Tourism  NEPA - Nature and Environment Protection Agency  Ministry of Agriculture and Rural Development (Water Resource Unit)  Ministry of Economy (Mining Unit)  NGOs

Stakeholders were defined as those people and organizations who may affect, be affected by, or perceive themselves to be affected by, a decision or activity. The contact information and communication methods for relevant stakeholders for the Project are given in Table VIII.2.

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Table VIII.2. Stakeholder Groups and Methods of Communication

Consultatio No. Stakeholders Group Contact Details Interests in the Project n Method Key-Stakeholders Nature and IV Proleterske 19, 81000 Podgorica, Environment Montenegro Information for decision 1 Official letter Protection Agency E-mail: [email protected] making (NEPA) IV Proleterske brigade 19, 81000 Ministry of Podgorica, Montenegro Sustainable Information for process of 2 E-mail: [email protected] Official letter Development and ESIA Tel: +382 20 446 200; +382 20 446 Tourism (MORT) 339; Fax: +382 20 446 215 Kralja Petra 36, 84 210 Pljevlja, Municipality of Montenegro Pljevlja, Secretariat E-mail: [email protected] Information about project in the 3 for Spatial Planning Official letter [email protected] territory of municipality - Environmental Tel: +382 (0) 52 321 305; +382 (0) 52 Service 323 010 Municipality of Kralja Petra 36, 84 210 Pljevlja, Pljevlja, Secretariat Montenegro Information about project in the 4 for Housing, E-mail: [email protected] Official letter territory of municipality Utilities, Roads and [email protected] Waters Tel: +382 (0) 52 300 209 Ministry of Rimski Trg 46, 81000 Podgorica Agriculture and Telefon:+382 20 234-105 Information about project that 5 Rural Development E-mail: [email protected] Official letter can improve a quality of water (Water Resource Fax:+382 20 482 109 Unit) Rimski Trg 46, 81000 Podgorica Ministry of Tel.: (+382)20 482 255; 234 124; Information about project that 6 Economy (Mining Fax: (+382)20 234 027 will rehabilitated the tailings of Official letter Unit) E-mail: [email protected] the mine

NGOs Dalmatinska 78, 81000 Podgorica Tel: +382 20 609 375 Monitoring the implementation 7 Green Home Fax: +382 20 609 376 Official letter process, Information E-mail: [email protected] Sutjeska bb, Pljevlja, Tel: +382 67/ 819 900 Monitoring the implementation 8 Breznica Official letter E-mail: [email protected], process, Information [email protected] Serdara Jola Piletića bb, 81400 Nikšić Monitoring the implementation 9 Ozon Tel/Fax: +382 40 206 564 Official letter process, Information E-mail: [email protected] Tel: 382(0)68 463 445 Rural/village development and 10 Da zazivi selo Official letter E-mail: [email protected] environmental protection Other Stakeholders Information on benefits for Citizens of Gradac Grdac bb, 84210 11 environment, monitoring the Official letter (Local Community) Facebook: @gradackodpljevalja implementation process Information on benefits for Citizens of Šula Šula bb, 84210 12 environment, monitoring the Official letter (Local Community) Facebook: @mjesnazajednicasulapv implementation process

The Nature and Environmental Protection Agency (NEPA), is identified as the project implementation agency for the project, and would have the overall responsibility for project implementation including information disclosure.

In this regard, the First Draft ESIA/ESMP will be published in the archive of the project’s web-site for public disclosure. Through this platform, citizens, local communities and authorities can get the project information and contribute their opinions/comments on environmental and social issues. Also printed material will be made available at the IWMCP PMU offices at NEPA/Ministry of Sustainable Development and Tourism. DEVELOPMENT OF EIA AND UPDATE OF ESIA REPORTS FOR THE MINE TAILINGS DISPOSAL FACILITY GRADAC, PLJEVLJA Chapter VIII - Pg. 111/112 ESIA REPORT

The comments will be carefully reviewed and the Second Draft ESIA/ESMP will be integrated with remarks and comments received both from Public Consultation Meeting and project’s web-site.

Once the Second Draft ESIA/ESMP will be approved, the Final ESIA/ESMP Report will be finalized and also finally disclosed.

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REFERENCES

 Rulebook on the closer content of the documentation submitted with the application for issuing the license for import, export and transit of waste, and waste classification list (Official Gazette of Montenegro, No. 71/10)  Rulebook on keeping records of waste and content of forms on waste transport (Official Gazette of Montenegro, No. 50/12)  Law on Spatial Planning and Construction of Facilities (Official Gazette of Montenegro No. 51/08, 34/11, 40/11, 47/11, 35/13, 39/13 and 33/14)  Rulebook on the manner of making, the scale and the close content of technical documentation (Official Gazette of Montenegro, No. 23/14)  Ordinance on the closer content and method of drafting waste management plan of waste producers (Official Gazette of Montenegro, No. 5/13)  Rulebook on waste classification and waste catalogue (Official Gazette of Montenegro, No. 59/13)  Law on Protection and Health at Work (Official Gazette of Montenegro, No. 34/14)  Official Gazette of Montenegro No.46/14, Ordinance on the manner and procedure for issuing and withdrawing a license from a foreign subject  Official Gazette of Montenegro No.6/09, Rulebook on the manner and procedure for performing expert supervision  Official Gazette of Montenegro No. 28/93, 27/94, 26/07, Law on Geological Surveys  Official Gazette No.MC 28/11, Law on Amendments to the Law on Geological Surveys  Law on the Environment of Montenegro (Official Gazette of Montenegro, No. 12/96, Official Gazette of Montenegro No. 52/16)  Law on Waste Management (Official Gazette of Montenegro, No. 64/11, 39/16), with accompanying regulations  Ordinance on the closer content and method of drafting waste management plan of waste producers (Official Gazette of Montenegro, No. 5/13)  Law on Waters (Official Gazette of Montenegro No.052 / 16)  Law on Nature Protection (Official Gazette of Montenegro No.054 / 16)  Law on Environmental Impact Assessment (Official Gazette of Montenegro No.052 / 16 and 75/18  Law on Air Protection (Official Gazette of Montenegro No.043 / 15)  Law on Strategic Impact Assessment (Official Gazette of Montenegro No. 052/16)  Official Gazette of Montenegro No .42/98, (Ordinance on hygienic correctness of drinking water) (provision of subsoil water intended for water supply)  Official Gazette of Montenegro. No .14/96, and 02/07 Decree on classification and categorization of waters  Official Gazette No. 10/97, 59/13 Ordinance on the quality of wastewater and the manner of their discharge into the public sewage system and natural recipient.  Regulation Official Gazette No .18/97, Ordinance on permitted quantities of hazardous and harmful substances in soil and methods for their investigation (soil quality).  Rulebook on limit values of noise levels in environment (Official Gazette of the Republic of Montenegro No. 75/06)  Rulebook on limits of the radioactive contamination in environment and on implementation the decontamination (Official Gazette of FRY No. 9/99).  Directive 2008/98/EC on waste  Directive 91/689/EEC on hazardous waste (as amended by Directive 94/31/EC)  Directive (EC) 166/2006) on hazardous waste  Regulation (EC) No 1013/2006 on shipments of waste  International permits, notifications and/or certifications  Operational Policy/Bank Procedure (OP/BP) 4.01 Environmental Assessment “OP/BP 4.04 Natural Habitat”. The objective is to promote environmentally sustainable development by supporting the protection, conservation, maintenance and rehabilitation of natural habitats and their functions.

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 “OP/BP 4.09 Physical Cultural Resources”  “OP/BP 4.12 Involuntary Resettlement”  “OP/BP 4.37 Safety of Dams”  OP/BP 7.05 Projects on International Waterways”  CETI, September 20, 2011, book I-III in the framework of the research CDM Europe GmbH-Alsbach - Germany / Hydroinzinjiring Ltd Ljubljana-Slovenia  The Environmental Impact Assessment and Society Study, Book 1, Internal Document, 2011  COWI A / S (2012): Environmental and Social Impact Assessment of the Remediation of Five Contaminated Sites. World Bank ESIA and safeguard studies for contaminated industrial sites remediation for the Ministry of Sustainable Development and Tourism, Environmental Protection Agency  Consortium CDM Europe & Hydro-engineering (2013); Site Investigations and Preparation Study for the Remediation of Industrial Waste Disposal Sites in Montenegro - IWMCP- PPF-CS1  Popović M., Medjedović N. (2018) Report on detailed geological and geotechnical investigations of tailing from the mine "Šuplja Stijena", Gradac, Pljevlja. Geoptojekt Ltd., Podgorica  Local Ecological Action Program (LEAP) .ERICo Velenje, Slovenia, 2009.  Mirković M., Živaljević M, Đokić V., Perović Z., Kalezić M., Pajović M. (1985): Geological map of Montenegro 1: 200.000. Institute for Geological Research of the Republic of Montenegro, OOUR for Regional Geology and Mineral Raw Materials, Titograd  Popović M., Medjedović N. (2018) Elaborate of detailed geological and geotechnical investigations of the flotation pit mine "Šuplja Stijena", Gradac in the Municipality of Pljevlja. Geoprojekt, Podgorica  CETI, Land Quality Report (for Gradac) 2011, 2012 and 2013 for the Environmental Protection Agency - Monitoring of Hazardous Substances.  Waste analysis reports - tailings from the mining of lead and zinc ore from the "Hollow Rock" mine - composite sample, soil samples at 200 and 350m from pit and kop, CETI, for Gradir Montenegro, 2012  Study "0" of the conditions of lead and zinc mine "Šuplja stijena", CETI 2009  Conceptual (conceptual solution) - The main project for the reconstruction of the flotation pit of the "Šuplja stijena" mine, Gradac in the municipality of Pljevlja, K.P. No. 5150. KO. Gradac, Municipality of Pljevlja, 2018, Institute for Mining and Metallurgy-Bor and Nik Com- Niksic.  Energy Development Strategy until 2025. The government of Montenegro, Podgorica, 2014  Radojičić B. (2008) Geography of Montenegro, Natural basis, Book 1, DANU, pp. 1-121, Podgorica  Baseline studies for a detailed spatial plan of the thermal power plant in Pljevlja, Ministry of Sustainable Development and Tourism, Podgorica, 2013  Strategic environmental assessment (SEA) for detailed spatial plan of the thermal power plant in Pljevlja, Ministry of Sustainable Development and Tourism, Podgorica, 2013.  Environmental Impact Assessment Thermo Power Plant in Pljevlja, Ministry of Sustainable Development and Tourism, Podgorica, 2015  EMERALD Database Institute for the Protection of Nature of Montenegro. Version of 31 May 2011.  Important plant habitats in Montenegro - IPA project. Podgorica, 2009.  Strategic plan for the development of the municipality of Pljevlja, 2013-2018.

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ANNEXES

ANNEX-1: Contributors ANNEX-2: Environmental and Social Management Plan (ESMP)

ANNEX-1 CONTRIBUTORS

CONTRIBUTORS

Name-Surname Profession

I. Haluk CERIBASI, Ph.D. Team Leader, Environmental Engineer

Huseyin TEKIN Environmental and Social Expert

Dr. Okan BILKAY Mechanical Engineer

Tolga BALTA Environmental Engineer

Asli KARABACAK Environmental Engineer

Cagdas CENGIZ Environmental Engineer

Fatma Nehir YILDIZ Biologist

Nazan Duygu YIGITER Urban Planner

Nadire DURMUSOGLU Chemist

Erhan AGCA Landscape Architect

Arzu GURBUZ Landscape Architect

Fatih M. ALPAY Agricultural Engineer

Gokay SAYGUN Economist

Milica DAKOVIC Social Expert

Ilinka BAETOVIC Environmental Expert

Maida MURATOVIC Environmental Expert

Marija SINDIC Local Expert

ANNEX-2 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

Development of EIA and Update of ESIA Reports for the Mine Tailings Disposal Facility Gradac Pljevlja, Montenegro

ANNEX-2 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

JUNE 2019

TABLE OF CONTENTS

Page

1. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) 1 2. MITIGATION MEASURES WITHIN THE CONCEPTUAL DESIGN 1 2.1. Mitigation Measures to Prevent Impacts on Air Quality 1 2.2. Mitigation Measures to Prevent Impacts on Surface Water and 1 Groundwater 2.3. Mitigation Measures to Prevent Impacts on Landfill Slopes 1 2.4. Mitigation Measures to Prevent Impacts on Biodiversity 3 3. ENVIRONMENTAL AND SOCIAL MITIGATION AND MONITORING PLAN 4 4. INSTITUTIONAL ARRANGEMENTS 12

LIST OF TABLES

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Table 1 Environmental and Social Mitigation Plan 5 Table 2 Environmental and Social Monitoring Plan 9

LIST OF FIGURES

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Figure 1 Proposal for the Rehabilitation of the Slopes at the Gradac Landfill 2 (Conceptual Design, 2018) Figure 2 Detailed View of the Proposal for the Rehabilitation of the Slopes at 2 the Gradac Landfill (Conceptual Design, 2018) Figure 3 Detailed View of the Planed Recultivation of the Upper Part of 3 Gradac Landfill (Conceptual Design, 2018)

LIST OF ABBREVIATIONS

ESMP Environmental and Social Management Plan CEMP Construction Environmental Management Plan HASP Health and Safety Plan PPE Personal Protective Equipment OHS Occupational Health and Safety SLMP Safety Labour Management Plan PIU Project Implementation Agency NEPA Nature and Environmental Protection Agency of Montenegro

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1. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

The purpose of the Environmental and Social Management Plan (ESMP) for the remediation of Gradac tailings pond site is to ensure that all adverse environmental impacts fall within the acceptable levels, according to subsequently prevention, control, monitoring and mitigation. The ESMP is set out to ensure that all aspects of the remediation works comply with the relevant legislation, permit conditions and good practice, and that measures to mitigate the negative impacts identified in the ESIA are implemented. The ESMP aimed to implement appropriate environmental controls and monitoring procedures during construction and is the basis for fulfilling the requirements under Montenegrin legislation. In a later phase, the Nature and Environmental Protection Agency will require all construction contractors to develop a detailed Construction Environmental Management Plan (CEMP) for their respective activities. The detailed CEMP should include detailed method statements, environmental control procedures and environmental compliance monitoring to be carried out during the construction works. The Health and Safety measures and monitoring are specified in the preliminary Health and Safety Plan (HASP).

2. MITIGATION MEASURES WITHIN THE CONCEPTUAL DESIGN

The objective of the project of remediation of Gradac tailing pond is to limit the negative impact of contaminated dumpsite and to ensure significant positive impact on the environment. The Conceptual Design envisages a set of technical measures for mitigation of negative impact on air, water, soil and biodiversity quality including land stability. All measures and works will be defined in details in the Main Design.

2.1. Mitigation Measures to Prevent Impacts on Air Quality

The plan for preventing the discharge of dust from waste landfills and reducing pollution refers to the stabilization of the landfill and capping. The plan encompasses greening of the surface as well as slope rehabilitation, which will prevent further spreading of fine grain toxic materials.

2.2. Mitigation Measures to Prevent Impacts on Surface Water and Groundwater

According to the Conceptual design, appropriate impermeable layers with the installation of a drainage system should cover entire landfill body, so that no further filtration of the storm water through the body of the landfill may occur. Storm water will be drained by the installed pipes to the drainage channel at the foot of the dump slopes through which unpolluted water will flow to Ćehotina River. The slopes of the landfill should be covered with appropriate materials of a total thickness of 2 m, and the upper part of the landfill with materials with a total thickness of 5 m (Figures 1, 2 and 3).

2.3. Mitigation Measures to Prevent Impacts on Landfill Slopes

The Conceptual design envisages the remediation of the slopes of the landfill, which includes reshaping of slopes, sealing the landfill surface and building a retaining wall of gabions. It is planned to form the slope of gradient 1:3 with two barges (5 m wide) placed at every 7 m of height. In some parts of the slope, there will be a need for cut, while in other parts there will be a need for embankment and filling of existing gullies. The newly formed slopes will be covered with a multilayer protective material with a total thickness of about 2 m, which will be cultivated in the surface area. The retaining wall, composed of gabions filled with stones, will be about 4 m high. Gabions have a dual function, to stabilize the slope and prevent its erosion by the high levels of Ćehotina River.

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In order to avoid unwanted events such as landslides and increased erosion, the measures prescribed by the design should be respected and constant geotechnical supervision should be undertaken during the entire construction phase in order to prevent instability phenomena and intense erosive processes. Such occurrences, which are unlikely if the prescribed measures and rules are respected, could cause contamination of Ćehotina River.

Figure 1. Proposal for the Rehabilitation of the Slopes at the Gradac Landfill (Conceptual Design, 2018)

Figure 2. Detailed View of the Proposal for the Rehabilitation of the Slopes at the Gradac Landfill (Conceptual Design, 2018)

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Figure 3. Detailed View of the Planed Recultivation of the Upper Part of Gradac Landfill (Conceptual Design, 2018)

2.4. Mitigation Measures to Prevent Impacts on Biodiversity

Taking into account that the disposal of acid and toxic flotation material has completely destroyed the flora and fauna of the site, the planed rehabilitation works will have positive impact to the biodiversity. The main measure is closing and sealing of entire landfill surface, so it will prevent the exposure of animals to contaminated land by direct contact. In addition, re-cultivation of the landfill surface will significantly prevent the transport of landfill dust by wind, avoiding the deterioration and the quality of ecosystems.

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3. ENVIRONMENTAL AND SOCIAL MITIGATION AND MONITORING PLAN

The Contractor's obligations are to comply with, and apply mitigation measures as it is given both in the Conceptual/Main Design and in the ESMP. All of these measures proposed to mitigate the impact of the dump must be strictly respected.

The ESMP is divided into two functional groups which are Mitigation Plan and Monitoring Plan, Table 1 and Table 2 below. The major purpose of ESMP is to document key environmental and social issues, the actions to be taken to address them adequately, as well as the schedule and person/unit responsible for implementation and monitoring.

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Table 1. Environmental and Social Mitigation Plan

Installation Operation Installation Operation Issue Mitigation Measures cost cost responsibility responsibility Preparatory and Construction Phase  Frequent watering of work grounds will be done during dry periods and water intended for this purpose must be used in quantities that will not result in generation of run-off  Speed limits will be enforced on the Project area and public roads to limit the levels of dust generation. Contractor Contractor Included in  Vehicles delivering material will be covered. supervised by supervised by Included in the the Air quality/Dust  All vehicles, equipment and machinery used for construction will be regularly maintained NEPA and NEPA and Contractor’s bid Contractor’s Supervising Supervising and inspected/certificated to ensure that the exhaust emission levels conform to the bid standards prescribed. Engineer Engineer  No works causing dust formation are allowed when strong wind is blowing in the direction of the settlement Gradac.  Loading and unloading will be carried out without scattering  Limiting the construction area/work sites  Parking, washing, maintenance and fuelling of the construction machinery would be done at designated sites with concrete ground and in the event that soil is contaminated by spillage, affected layer would be removed in line with the relevant regulation and internal management plans.  All packaging waste material for oil and other petroleum derivatives would be stored at a designated area.  Storage and handling of fuels, oils and other hydrocarbons would be done at designated Soil quality As above As above As above As above areas with solid grounds (not soil) and located at least 50 m away from any watercourse.  Opening of non-controlled and unplanned access roads to any part of the Project site will be forbidden  Systematic collection of solid waste during construction (including food and material packaging, and other types of waste) would be undertaken and wastes would be disposed at licensed facilities specified by national authorities  Drainage channels will be constructed in accordance with the topographical conditions of the Project Area.  Driving of machinery within surface water, streams or on their banks will be prevented.  Maintaining, refuelling and cleaning of construction machinery will be carried out at dedicated locations with proper containment and drainage and related waste material would be stored at a controlled area.  Training will be provided to machine operators regarding sensitivities and working Water quality (surface procedures in works near water. As above As above As above As above and ground water)  All machines and equipment will be checked for leaks prior to use.  Oil and fuel will be stored in places with secondary containment. No drums will be placed directly on the ground.  Storage and handling of fuels, oils and other hydrocarbons will be controlled, involving measures to prevent soil and water contamination. Designs will include storage on sealed surfaces and within secondary containment and refuelling of all plant, vehicles and

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Installation Operation Installation Operation Issue Mitigation Measures cost cost responsibility responsibility machinery will not be allowed within 50 m of any watercourse.  Precautions such as planting against erosion will be taken.  Preparing site specific emergency plans to respond to any incidents or spillages of hazardous material to water environment.  Slopes of the tailings pond site would be stabilized, strengthened with gabions and recultivated to reduce potential for surface erosion in accordance to the design.  During geotechnical works, permanent surface protection (i.e. covering with protective Erosion and land stability film) of the slopes will be ensured. As above As above As above As above  Suitable warning signs (landslide risk, slippery conditions, etc.) and reflective markings indicating steep slopes would be located in line with good engineering practice or as agreed with the local authorities.  Raising workers awareness on the noisy activities  Construction time will be limited to day-hours (07.00 to 19.00)  Use of modern equipment and machines with noise suppressors  Regular maintenance of construction vehicles and equipment Noise  Avoiding the simultaneous operation of several noisy machines, when possible As above As above As above As above  Using natural acoustic barriers or screens around the machines, such as trees and topographical factors, in case of a grievance  Regular maintenance of access and temporary roads and limiting the speed of vehicles  Leaving engines idling at the site will be avoided unless absolutely necessary.  Clearing up and removal of vegetation will be minimized to the extent necessary for the execution of works, including riparian vegetation along the river Ćehotina  Proper implementation of rehabilitation measures from the design which envisage the complete isolation of the deposited toxic material by a waterproofing layer (with humus) in order to restore the flora and then the fauna of the site  Perform a permanent covering of cut parts of landfill body with protective film in order to avoid a rinsing of the polluted loose material towards surrounded habitats. Biodiversity/Flora and  Restoring the site with native plants As above As above As above As above fauna  Set established rules for the workers on the ban on lighting fires, collecting birds' eggs, disturbing and hunting of wild animals and birds, destroying of floral species and similar  Scattering of wastes with the wind within and out of the project area will be prevented by collecting and temporary storage of waste at designated areas.  Vehicle speeds will be limited to prevent any accidents causing animal death and no new roads would be opened unless approved by relevant authority.  Incineration or burying of wastes by any means at site and/or dumping of wastes to nearby roads or water resources will be absolutely prohibited.  Preparation of a landscape restoration plan in line with the remediation design including Landscape the realistic requirements to minimize short term visual impacts from the site operations As above As above As above As above and to maximize the long-term recovery potential of the landscape  Systematic collection of solid waste during construction (including food and material Wastes packaging, and other types of waste) would be undertaken and wastes would be disposed As above As above As above As above at licensed facilities specified by national authorities

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Installation Operation Installation Operation Issue Mitigation Measures cost cost responsibility responsibility  All packaging waste material for oil and other petroleum derivatives would be stored at a controlled area. Community Health and  The construction contractor will develop and implement a Traffic Management Plan to

Safety manage traffic related risks  Limited working hours ( 07 - 19 h) to avoid nuisance of the population living near the tailing pond Gradac  The excavation and similar works should not be performed during strong wind to avoid the spreading of the dust toward the settlement Gradac Social issues As above As above As above As above  Waste disposal or storage near the settlement must be avoided  Locals will be given priority for temporary employment during construction  Appropriate disclosure of information and consultation with affected persons and community will be implemented  Contractor will follow the national requirements with respect to “chance finds” which may emerge during construction.  Contractor is not allowed to perform excavation, demolition, alteration or any works that Cultural heritage may harm the properties of any cultural monument. As above As above As above As above  In case of chance finds, the Contractor shall mark and secure new identified sites (with a protective railing or other means of protection) to avoid damage and immediately notify the relevant authority.  Include both management measures and reporting and investigating any incidents, i.e. Implement international HSE standards in all contracts  Identify potential risks before commencement of works. The emergency response provisions will include an OHS Management Plan, which will also indicate a contact person available in the event of an accident. OHS Management Plan will be submitted to the project owner for approval. Contractor will ensure the following in terms of workers/occupational health and safety:  Drugs and alcohol usage are forbidden on site.  Contractor is to include a provision for safe working environment and safety measures and personal protective equipment (PPE) for all workers in its OHS Management Plan, Workers (Occupational) including gloves, hard hats, goggles, ear protection and safety footwear. As above As above As above As above Health and Safety  OHS Management Plan is to include a provision for first aid to be administered on site and a trained person must be engaged in line with the Law on Occupational Health and Safety (Official Gazette of Montenegro, No. 034/14).  Contractor shall provide to his workers potable water supply, toilets and water supply for washing.  Safety Labour Management Plan (SLMP) is required to ensure health and safety provisions  Contractor shall perform all project activities following the SLMP and all Montenegrin laws and by-laws

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Installation Operation Installation Operation Issue Mitigation Measures cost cost responsibility responsibility Operation Phase Included in Contractor or the Included in the Water quality (surface Maintenance future owner  Regular cleaning and maintenance of the water drainage system Contractor’s Contractor’s or and ground water) Contractor supervised by or Owner’s Owner’s bid NEPA bid  Checking and recording germination success of planted areas Flora (planted surface) As above As above As above As above  If it is necessary, repeat sealing and planting by using of native species Erosion and land stability  Maintenance of the slopes when necessary As above As above As above As above  The construction contractor should develop and implement the Emergency Action Plan for all phases of the Project for all potential natural disasters, failures and accidents, also Emergency covering community health and safety aspects. As above As above As above As above  To avoid landslides on the slopes and embankments, technical requirements in line with the Main Design and Emergency Action Plan will be implemented  In the operation phase of the Project, no adverse/negative impacts are anticipated other Other Environmental and than the emergency situations. For the operation phase, mostly monitoring activities are - - - - Social Characteristics suggested and these are presented in the Environmental and Social Management Plan (ESIA-Chapter VII).

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Table 2. Environmental and Social Monitoring Plan

Responsibility for the Issue Parameter Frequency Location Equipment costs Operational costs implementation of monitoring (provision of funds) Pre-Construction Phase Once before the Within the construction site and TSP, PM10 and content of commencement of beyond it, Involved in offer Involved in offer Contractors, under control Air quality heavy metals construction by the downstream direction of the wind, Contractor Contractor of Supervision Engineer and NEPA accredited institution and closest settlement 10 samples at a distance of 0 - 200 m from the contaminated site, Once before it is necessary to examine the Contamination control of commencement of the contents of the minimum of the Involved in offer Involved in offer Contractors, under control Soil quality surface layer in the vicinity construction by the following parameters: arsenic, Contractor Contractor of Supervision Engineer and NEPA of the site accredited institution copper, zinc, fluorine, chromium, nickel, lead, total hydrocarbons TPH, mercury and CN. Before commencement of Groundwater construction, once in the Quality pH, Conductivity, CN, Involved in offer Involved in offer Contractors, under control period of low and once in Boreholes B2, B10 and B13 (Piezometric heavy metals Contractor Contractor of Supervision Engineer and NEPA the period of high waters wells) by an accredited institution In accordance with the Before start of Cehotina river at the location Surface water Regulation on construction, once in the Gradac before the landfill and Involved in offer Involved in offer Contractors, under control quality Classification of Surface period of low and once in after the landfill and before the Contractor Contractor of Supervision Engineer and NEPA (Cehotina) and Groundwater (Official the period of high waters tunnel. Gazette of MNE No.02/07) by an accredited institution All the parameters from the Ordinance on MPL of Deposited Just before the start of 10 points at the landfill, at the Involved in offer Involved in offer Contractors, under control the Hazardous Substances materials remediation locations of the tests so far. Contractor Contractor of Supervision Engineer and NEPA in soil (Official Gazette of MNE No. 18/1997) Construction Phase TSP, PM10, and Heavy Once a month by an Within the site and beyond it Involved in offer Involved in offer Contractors, under control Air quality Metal Content in TSP accredited institution wind direction and settlements Contractor Contractor of Supervision Engineer and NEPA All the parameters from the Ordinance on MPL of Deposited Once at the end of the 10 points at the landfill, at the Involved in offer Involved in offer Contractors, under control the Hazardous Substances materials remediation locations of the tests so far Contractor Contractor of Supervision Engineer and NEPA in soil (Official Gazette of MNE No.18/1997) Noise level Work hours On a daily basis At the boundaries of the work site Minor Involved in Contractors, under control

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Responsibility for the Issue Parameter Frequency Location Equipment costs Operational costs implementation of monitoring (provision of funds) Noise level Subjective offer of Supervision Engineer and NEPA Contractor Surrounding population Interviews during the Involved in Social Contractors, under control satisfaction with realized construction and at the Local municipality/Gradac Minor offer feedback of Supervision Engineer and NEPA works end of the remediation Contractor 10 samples at a distance of 0 - 200 m from the contaminated site, it is necessary to examine the Contamination control Involved in Once after the completion following parameters: arsenic, In line with real Contractors, under control Soil quality surface layer in the vicinity offer of the rehabilitation. barium, copper, zinc, fluorine, cost analysis of Supervision Engineer and NEPA of the landfill Contractor chromium, nickel, lead, total hydrocarbons, PAHs, CN and mercury Groundwater Involved in pH, Conductivity, CN, In line with real Contractors, under control (Piezometric Once a month boreholes B2, B10 and B13 offer heavy metals cost analysis of Supervision Engineer and NEPA wells) Contractor In accordance with the Cehotina river, at the location Decree on Classification of Involved in Involved in Surface water Gradac before the landfill and Contractors, under control Surface and Groundwater Once a month offer offer (Cehotina) after the landfill and before the of Supervision Engineer and NEPA (Official Gazette of MNE Contractor Contractor tunnel. No. 02/07) Drainage Three places: before the drainage waters pH, Conductivity, CN, Involved in Involved in Once after the completion of drainage water, drainage water Contractors, under control (Water from Heavy metals, offer offer of the rehabilitation. and the recipient water after the of Supervision Engineer and NEPA the peripheral Contractor Contractor drainage of drainage water. channel) State of the Ecosystem and assessment of the risk Develop a site of residual contamination. monitoring program Location of recultivated land on Biodiversity Monitoring the number of Once after the completion of the According to the real Contractors, under control landfill surface and a close (flora, fauna) returns of destroyed plant of the rehabilitation. representative costs of the performers of Supervision Engineer and NEPA environment and animal species that plant and animal are specific to the site species (Gradac). Operation Phase TSP, PM10, and Heavy Once a year by an At min. 4 points outside the dump, Develop a site According to the real NEPA or the new owner, or the Local Air Quality Metal Content in TSP accredited institution near the village. monitoring program costs of the performers Administration In accordance with the Cehotina river at the location Decree on Classification of 2 times a year in the Surface water Gradac before the landfill and Develop a site According to the real NEPA or the new owner, or the Local the Surface and period of high and low (Cehotina) after the landfill and before the monitoring program costs of the performers Administration Groundwater (Official water levels tunnel Gazette of MNE No 02/07)

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Responsibility for the Issue Parameter Frequency Location Equipment costs Operational costs implementation of monitoring (provision of funds) Groundwater pH, Conductivity, CN, Develop a site According to the real NEPA or the new owner, or the Local (Piezometric Once a year boreholes B2, B10 and B13 Heavy metals monitoring program costs of the performers Administration wells) Drainage waters Three places: before the drainage 2 times a year in the (Water from pH, Conductivity, CN, of drainage water, drainage water Develop a site According to the real NEPA or the new owner, or the Local period of high and low the peripheral Heavy metals and the recipient water after the monitoring program costs of the performers Administration water levels channel) drainage of drainage water.

State of the Ecosystem and assessment of the risk Develop a site of residual contamination. monitoring program Location of recultivated land on Biodiversity Monitoring the number of of the According to the real NEPA or the new owner, or the Local Once a year landfill surface and a close (flora, fauna) returns of destroyed plant representative costs of the performers Administration environment and animal species that plant and animal are specific to the site species (Gradac). Location of recultivated land and Erosion and Develop a site According to the real NEPA or the new owner, or the Local State of slopes stability Once a year surrounded area including river land stability monitoring program costs of the performers Administration sides

DEVELOPMENT OF EIA AND UPDATE OF ESIA REPORTS FOR THE MINE TAILINGS DISPOSAL FACILITY GRADAC, PLJEVLJA Pg. 11/13 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

4. INSTITUTIONAL ARRANGEMENTS

The main responsible for the Project implementation, including ESMP implementation, would be the NEPA as a Project Implementation Agency (PIU) for the Project. NEPA will ensure that all relevant ESMP requirements are duly incorporated into tender documentation. Supervision Engineer with NEPA will have the authority to stop the works if the performance is not in line with the ESMP or other environmental standards and regulations.

Project Supervision Engineer will be engaged during execution of construction works according to the Law on Spatial Development and Construction of Facilities and will be responsible for day-to-day project implementation and monitoring its compliance.

The Contractor would have the responsibility of implementing all mitigation and monitoring measures complying with the ESMP on site during the construction phase. Contractor is responsible for conducting all relevant mitigation and monitoring measures complying with the ESMP on site during the implementation of works. In this regard, Contractor should develop Construction Environmental Management Plan (CEMP) for their respective activities. The detailed CEMP should include detailed method statements, environmental control procedures and environmental compliance monitoring to be carried out during the construction works.

The maintenance Contractor or future owner of the facility would be responsible for implementing the relevant measures during the operation phase (regular maintenance of the site).

The effectiveness of this ESMP will be assessed by the NEPA by monitoring the environmental and social issues discussed in the mitigation sections above.

In the event that the findings of monitoring indicate any deviation from the implementation of the outlined ESMP or if any environmentally and socially unsatisfactory condition should be encountered, the NEPA will advise construction contractor for corrective actions as necessary.

Monitoring records will be kept by construction contractor. Reports will be prepared regularly to describe monitoring activities and their results (including any need for improvement and the means of achieving this). These reports will be available to relevant governmental agencies and WB, when required, and to the public as appropriate. During the construction phase of the Project, a monthly report on the environmental and social performance will be prepared by construction contractor for submitting to supervisor and/or NEPA. These reports will help supervisor and NEPA to monitor the implementation of ESMP. The ESMP will be the part of the construction contract; therefore, it is obligatory for the construction contractor to implement it and for supervisor and NEPA to monitor its implementation. NEPA will also prepare quarterly environmental and social performance reports to submit WB. Environmental and social performance reporting will be in compliance with the standards stipulated in OP 4.01 and IFC PS1.

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