Development of Environmental and Social Impact Assessment Report of the Planned Remediation Activities On coal and Ash Disposal Facility
Pljevlja, Montenegro
Non-Technical Summary of Environmental and Social Impact Assessment Report
DECEMBER 2018
TABLE OF CONTENTS
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I. INTRODUCTION 1
II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK 1
III. PROJECT DESCRIPTION 2 III.1. Relocation of the Paleski Stream 2 III.2. Recultivation 2 III.3. Top Cover System for the Cassette II 2 III.4. Project Schedule 3
IV. ENVIRONMENTAL AND SOCIAL BASELINE CONDITIONS 4 IV.1. Study Area and Sources of Baseline Information 4 IV.2. Characteristics of the Physical Environment 5 IV.3. Quality of the Physical Environment 6 IV.4. Biological Environment 7 IV.5. Characteristics of Socioeconomic Environment 7 IV.6. Protected Areas and Cultural Heritage and Properties 8
V. ENVIRONMENTAL AND SOCIAL IMPACTS 8 V.1. Impacts on Physical Environment 8 V.2. Impacts on Socioeconomic Environment 10
VI. PROJECT ALTERNATIVES 11
ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM AND ENVIRONMENTAL AND VII 12 SOCIAL MANAGEMENT PLAN
VIII. PUBLIC PARTICIPATION AND INFORMATION DISCLOSURE 14
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LIST OF TABLES
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Table 1 Overview of the Phase 1 of Recultivation Works 3 Table 2 Summary of the Impact Assessment and Mitigation Measures 13 Table 3 Summary of Monitoring Activities 14
LIST OF FIGURES
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Figure 1 General View of the Project Area and the related Structures 4
LIST OF ABBREVIATIONS
NTS Non-Technical Summary ESIA Environmental Social Impact Assessment EPCG Elektroprivreda Crne Gore TPP Thermal Power Plan WB World Bank IR Inception Report ESMP Environmental and Social Management Plan IBRD International Bank for Reconstruction and Development EHS Environmental, Health and Safety AoI Area of Influence RAP Resettlement Action Plan CEMP Construction Environmental Management Plan
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NON-TECHNICAL SUMMARY
The aim of this non-technical summary (NTS) is to provide an easily comprehensible summary of the Environmental Social Impact Assessment (ESIA) Report prepared for the Project Remediation Activities on Coal and Ash Disposal Facility Pljevlja, Montenegro. In this regard, this NTS will summarize the Project characteristics, baseline conditions of the Project area, importance, potential impacts of the Project and the mitigation measures proposed in a non-technical context.
I Introduction
JSC Elektroprivreda Crne Gore (EPCG) development Project of Environmental and Social Impact Assessment of the Planned remediation activities on coal and ash disposal facility Pljevlja, Montenegro, which will contribute to improving the quality of environment in the area surrounding TPP Pljevlja. Implementation of the Project will ensure deposition of ash and slag in the upcoming period, and it will also contribute to an increase in efficiency of operation of the thermal power plan (TPP) Pljevlja.
The existing Maljevac Landfill is active at the moment and it should provide additional space for disposal of the ash and slag from the TPP Pljevlja in order to enable stable supply of electricity to the citizens of Montenegro in the following 7 years.
The World Bank (WB) is considering approving a loan where proposed loan will be used for carrying out the works on revitalization of the ash and slag Maljevac Landfill in Pljevlja.
The Project mainly consists of two components; rehabilitation of the Cassette II and relocation/diversion of the Paleški Stream/Creek. A part of the Paleški Stream runs through a concrete collector, which passes under the existing landfill. Degradation of water quality was detected in the downstream part of the stream due to the leaking of the landfill leachate into the collector. Therefore, it is decided to divert the riverbed outside the landfill area.
The project is categorized as a Category A project, according to the WB categorization. Therefore, this Project requires an Inception Report (IR), an Environmental and Social Impact Assessment (ESIA), an Environmental and Social Management Plan (ESMP), and a Non-Technical Summary (NTS).
II Policy, Legal and Administrative Framework
ESIA Study is being developed following legal requirements of Montenegrin legislation as well as requirements of the International Bank for Reconstruction and Development (IBRD) / World Bank Safeguard Policies.
Montenegrin environmental legislation is mostly harmonized with the EU acquis. In addition, Montenegro has ratified a number of international treaties and conventions relevant to the Project which have been considered during the elaboration of the ESIA.
In accordance with the Montenegrin EIA regulation, the EIA Elaborate for the purpose of depositing by-product generated through production of coal fuel at TPP Pljevlja, at the location of the existing Maljevac Landfill (on the UP in the area of DSP of Municipality of Pljevlja), has been developed and approved by the NEPA in 2017.
Besides environmental legislation, all the applicable Montenegrin legislation and international standards regarding health and safety, expropriation and resettlement have been applied during development of the ESIA Study.
In accordance with the World Bank Safeguard policies and procedures OP/BP 4.01 on Environmental Assessment, the Project meets the requirements of environmental category A-type investment standards. The ESIA report and the ESMP for the Project are being prepared in accordance with the Annex B and Annex C of the OP 4.01. In addition, the 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 ESIA study together with the relevant Industry Sector EHS Guidelines, such as Guidelines for Thermal Power and Guidelines for Waste Management.
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III Project Description
III.1. Relocation of the Paleški Stream
Source of Paleški Stream is located south-west of the Maljevac Landfill. A 2.9 km long watercourse flows through the Paleški Stream valley.
The main concrete collector was made in the valley of Paleški Stream and it had the length of 1,338 m with wall thickness of 60.00 cm. There is also a secondary collector with the length of 600m.
With the aim of preventing further pollution of Paleški Stream caused by drainage water from the ash and slag landfill, it is planned to relocate the water which belongs to the waterflow of the Paleški Stream and other water from the associated basins. Spring water and atmospheric water from these basins is transported to the Borovičko Lake as clean water through adequate channels.
The proposed new Paleški Stream route passes through private parcels and the new river bed is planned with a width of 30.0 m. Dimensions for the reinforced concrete channel would be constant along its length.
Section 1 - L 1 will have the length of 848 m and Section 2 - L 2 will have the length of 1028 m from the asphalt road to the confluence with the Borovičko Lake.
III.2. Recultivation
Recultivation of the Maljevac Landfill would be done in accordance with the Rulebook on the closer characteristics of the site, conditions of construction, sanitary and technical conditions, manner of operation and closure of landfills ("Official Gazette of Montenegro", No. 31/13 and 25/16) and DSP - and UTR number 1055- 1846 / 2. Degraded surface at the landfill is intended for planting, by using optimal recultivation - phases of technical and biological reclamation.
Recultivation of the Maljevac Landfill would be done in phases as follows:
Phase 1 - Recultivation works on the Cassette II and rehabilitation and recultivation of the 4th and 5th steps with precipitation Phase 2 - Recultivation works on the Cassette I and II Phase 3 - Recultivation work on the Cassette III in several stages:
According to the physical chemical properties of the soil, geomorphology of landfill, climatic conditions and natural vegetation in the environment, the biological phase of optimal recultivation is on;
Final levels - plateau of the ash and slag landfill cassettes - afforestation; and Final slopes of the landfill - covering with grass.
The targets of the reclamation of the Maljevac Landfill are mainly the following:
Permanent prevention of ash dispersion by wind Creating a pleasant environment for the inhabitants around the landfill and the possibility of using the recultivated areas Restoring the damaged ecosystem Controlling flow and pollution of surface waters
III.3. Top Cover System for the Cassette II
The biological phase of optimal recultivation involves a complex of biotechnical and phyto-ameliorative measures for grassing of the cassette of the landfill as well as cultivation of forest cultures in order to revitalize the soil and restore the damaged ecosystem.
After the ash disposal in the Cassette II (an average level 832 m asl) is completed, three layers, which have the protective role and are significant for preparation for biological recultivation, will be placed during the technical recultivation phase.
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Table 1. Overview of the Phase 1 of Recultivation Works
Arranging the slope of the Cassette at the projected angle (1:2 ratio) Levelling the plateau of the Cassette Technical Recultivation - Material planning (marly clay), along the slope and along the plateau of the Cassette II Phase 1 Levelling and compacting the terrain with a roller Works on enrichment of the third layer (0.15 m) Loading and transport of arable soil on the slope and plateau of the cassette Machine seeding of grass-leguminous mixtures, i.e. 50 kg / ha Works on grassing of the slopes and Rolling area with grass mixtures with rollers plateau of the Cassette II (2019) Wetting the area sown to grass germination and thereafter, depending on the meteorological conditions. Sowing grass seeds - leguminous mixtures, sowing depth is between 1-2 cm Rolling a toothed roller of sown surfaces for the Work on formation of the protective purpose of establishing as good a contact between belt of bushy vegetation and trees soil and seeds as possible allowing for faster and around the periphery of the plateau more even spacing of the Cassette II (2020) Biological Recultivation Sprinkling (irrigation) of planted areas up to the point of emergence of the grass (if the drying period is appropriate) and, depending on the amount of precipitation
Forming two rows of grass on the periphery of plateau of Cassette II Works on afforestation of plateau of the Cassette II using bushy plants Forming three rows of deciduous woody plants and woody plants according to the mosaic schedule (year 2021)
Forming two rows of evergreen woody plants
On flat surfaces along the perimeter, the protective belts of trees and shrubs, 15.5 m wide, will be planted, in the quantity of 2,000 pcs / ha, which corresponds to installation of a square or triangular mesh of pits with a distance of 2.24 m. Shrub type Rhus (Cotinus coggyria Scop.) will be planted in two rows closer to the perimeter. After that, deciduous trees, i.e. maple (acer obtusatum Waldst. Ec Kit. Ex. Willd.) will be planted in three rows. In the end, two rows of conifer trees, i.e. Black pine (Pinus nigra) will be planted. This method of planting aims to form a shelterbelt as well as to enhance the aesthetic effect. In order for the function of this band to become prominent, it should be formed as soon as possible, i.e. it will be formed one year after the formation of the lawn.
Bearing in mind that recultivation of the Maljevac Landfill will be performed in phases, it is necessary to establish a temporary storage site which will be used for depositing all the fertile soil gained through the process of performing the works at the defined locations. Dynamics of performing recultivation of the Maljevac Landfill is ensured in this way.
III.4. Project Schedule
The works will be started by filling Cassette II in 2018. In October 2019 Casette I will be filled up. The filling of the Casette III will be performed in several phases from October 2019 until September 2025.
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IV ENVIRONMENTAL AND SOCIAL BASELINE CONDITIONS
IV.1. Study Area and Sources of Baseline Information
The wider Project area is located on the borders of Pljevlja Municipality. Pljevlja is located in the northern part of the Republic of Montenegro, in the geographical region of mountainous Montenegro.
The Project area (Cassette II of the Maljevac ash and slag landfill and the adjacent area where Paleski Stream would be relocated) is located about 800 m southwest of the TPP and the closest settlement to the site is Zbljevo. The general view of the Project area and the related structures is shown in Figure 1.
Figure 1. General View of the Project Area and the related Structures
IV.2. Characteristics of the Physical Environment
Topographical Characteristics of the Region
Municipality Pljevlja is located in the mountainous northern part of Montenegro.
The area of the TPP Pljevlja, including the ash and slag disposal site "Maljevac", is located in the industrial zone of Pljevlja, on the fourth kilometer of the road Pljevlja – Đurđevića Tara - Žabljak, with an altitude of 770 m asl.
Nearby environment of the area of TPP Pljevlja is sparsely populated, but in the wider surroundings there are several smaller settlements: Zabrdje, Kalušići, Komina, Radosavac and Grevo, in which the impact of the thermal power plant is felt the most. Village Zbljevo is located in the immediate vicinity of the ash and slag disposal site "Maljevac", while settlements Ljuća, Borovica and Šumani are located near the future landfill Šumani II. The ash and slag Maljevac Landfill is located about 800 m southwest of the TPP.
The ash and slag Maljevac Landfill was formed by the construction of the Maljevac dam in the valley of the Paleški Stream. The landfill was formed by raising embankments for the relatively wide and shallow valley of the Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - NTS - 01 NTS Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 4 / 14 Non-Technical Summary Date: December 2018
Paleški brod near the settlement Zbljevo. The source of the Paleški Stream is located southwest of the Maljevac Landfill. The stream flows through the valley for 2.9 km, including a 1338 m long collector which runs toward the Vezišnica River, which Paleški Stream joins. The Vezišnica River is located north of the Maljevac Landfill, which continues its flow to Pljevlja, where it joins the river Ćehotina.
Hydrological Characteristics
In terms of hydrology, the area of Municipality Pljevlja is mainly covered by the Ćehotina river and its tributaries. A smaller section of the Municipality is located in the Tara basin, while a small part is in Poblacnica area, a tributary of the Lim river. Out of the total surface area of the Municipality Pljevlja (1347 km2), the Cehotina basin takes up 994.6 km2 (74%), the Tara basin covers 318.8 km2 (24%), while the Lim basin covers surface area of 33.6 km2 (2%). The watercourses of these basins have their specific hydrographic characteristics.
The valley, where the ash and slag landfill was built, spreads in the south-west direction, and it is located west of the TPP Pljevlja. The surface area of the basin is 2.79 km2, while the length of the basin is 2.9 km. Runoff from the basin flows into the Paleški Stream, downstream of the landfill, and then into the Vezešnica River. During and after precipitation, nameless springs are generated in the valley surrounding the landfill, and they flow from the basin into the Vezišnica River. The valley is dry for most of the year.
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 during winter (periods without wind) and during cold days.
With the average annual precipitation of 796 mm and average of 128.5 days with precipitation during the year, Pljevlja falls into the category of areas with the least amount of precipitation in Montenegro. The precipitation regime also has the characteristics of the continental climate.
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. Due to the basin position, the number of days with fog is increased in Pljevlja. In this respect, the annual average is 80.8 days with fog, whereby the highest number of foggy days is in December, while the lowest is in April.
The most frequent winds are southern, with 17.5% and with average force of 3.1 Beaufort, and northern with a 6.2% and with an average force of 2.2 Beaufort. The types of wind which have the second highest frequency are western and north western wind, with representation of 3.6%, the force of 2 Beaufort. All other winds occur significantly less frequently.
Seismicity
The wider area of municipality of Pljevlja belongs to the seismically relatively quiet region.
Landscape Features
According to 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 m asl (Ljubičnja, 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.
The largest karst field in the basin of the Ćehotina River is Pljevaljsko field, which occupies an area of 16 km2. The Ćehotina River flows through the central part, which is, as noted, the basic feature of this and much wider area. Anthropogenic landscape is dominant in the area of Pljevlja. The impact of the urbanization and the mining- energy-industrial zone is clearly seen in the city and its surrounding area. Areas of open pit mining (tailing ponds, thermal power plant and the Maljevac Landfill 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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IV.3. Quality of Physical Environment
Water Quality
In order to determine whether the surface and groundwater belong to a certain class, monitoring of qualitative and quantitative parameters of water is carried out by the state authorities of the state administration.
The obtained data suggests that Ćehotina is endangered by the wastewater of the city and the water of Vezišnica. In the downstream part of the flow, water quality is changing slightly, and there is still a quality problem in Gradac, where 37.5% of all the parameters are out of all classes. In average, Ćehotina River water belongs to the predicted class in 45.3% of cases. Water of Ćehotina in the section downstream of Pljevlja - Gradac has a bad appearance, there is an unpleasant smell and there is a large quantity of waste in the riverbed and along the banks. The water of river Vezišnica is mostly affected by the wastewater of TPP Pljevlja, human activities along its course and low water flow.
According to the results of physical-chemical analysis, water samples from Paleški Stream that have been taken upstream and downstream from the landfill are out of the all classes of the Regulation on classification and categorization of water because of the increased COD HPK (Chemical Oxygen Demand) and cyanide levels.
According to the results of physical-chemical analysis, groundwater samples that have been taken from the body and base of the dam are out of the all classes of the abovementioned Regulation because of increased turbidity, electrical conductivity, suspended particles, HPK COD (Chemical Oxygen Demand) and nitrites levels.
Soil and Ash/Slag Quality
Through analysis of the sample of agricultural land, taken at the location close to the TPP Pljevlja tailings pond, it was determined that fluorine content exceeds the maximum allowed concentration, while the content of the other inorganic and all the organic pollutants is below the values stipulated as the norm. Deviations from the prescribed concentrations have been recorded through analysis of the soil samples taken at locations of TPP Pljevlja tailing pond (referring to the increased content of nickel in 2009, 2010 and 2012 and arsenic in 2009, 2010 and 2011).
According to the results of the physicochemical analysis results show that the landfill does not have significant impact on the surrounding soil.
Analysis results for the fly ash show extremely high concentration of Boron. Results for slag only show insignificant deviation from the prescribed soil quality due to a slightly higher concentration of Nickel, even though it should be treated as waste.
Air Quality
Air quality in the town of Pljevlja is mostly affected by the extremely 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 monitoring results indicate that, besides the industrial sources, city combustion plants and individual combustion plants contribute to the high degree of air pollution.
The results of air quality monitoring in Pljevlja in the Period 2014 – 2018 show that the concentrations of SO2, NO2, PM10 and PM2.5 particles in the air during the heating season were significantly higher than the concentrations measured in the period from May to September.
Regarding air quality monitoring in vicinity of the Maljevac Landfill, one of the concluding points of the report stipulated that increased concentrations of PM10 were only recorded in individual cases. Based on the analysis of these values and meteorological data provided in the obtained reports, it may be stated that this course of events was directly caused by the weather conditions (strong wind).
Radioactivity
Content of radionuclides in the ash from the Maljevac Landfill is significantly higher than the content of radionuclides in the coal, because this is a normal process of concentration of radionuclides from coal into the ash during the combustion process in the TPP furnaces, but even these concentrations are significantly lower than the naturally highest concentrations in the soil in Montenegro, according to the performed analysis in 2016.
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IV.4. Biological Environment
There are no protected areas in the zone of the subject location and its wider region. Two areas protected by the national legislation are located in the wider area, on the part of territory of Pljevlja Municipality. One of those sites is a part of the Durmitor National Park with canyon of the Tara River, protected as a World Heritage site – UNESCO which is abundant in exquisite richness in terms of flora and fauna. The other area consists of mountain pine (creeping pine, Pinetum mughi montenegrinum) on Mountain Ljubišnja. It should be noted that autochthonous vegetation is located in the area of the Biserka River bed. This natural micro-reserve deserves special protection and a more detailed investigation of species.
In the area of Municipality Pljevlja, there are 28 registered types of habitats of international importance, among which spruce forests on Ljubišnja stand out as most important. Mountain Ljubisnja is identified as a potential IBA and Emerald site.
IV.5. Characteristics of Socioeconomic Environment
Municipality of Pljevlja has the total area of 1,346m² which represents 9.7% of the total territory of Montenegro. TPP is located in the industrial zone 4km of the road Pljevlja-Djurdjevica Tara-Zabljak. Zbljevo settlement is located nearby the Maljevac Landfill and under the direct impact of the project.
Municipality of Pljevlja has population of 30,786 inhabitants, according to the latest data (Monstat, Census 2011) whereas 49.1% are male and 50.8% female inhabitants and their average age is 41.8 years. Out of the entire population, 37.5% is active, while 47% is inactive, and 15.4% is less than 15 years old. Total number of inhabitants in Pljevlja decreased by 8.6% in 2011, compared to 2003. Out of the total number of active inhabitants, 69.3% were employed in 2011.
Social Infrastructure and Services
Compared to the main road network of Montenegro, the Municipality of Pljevlja has an unfavorable traffic position. The only mode of transport on the territory of the municipality is road traffic.
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). TPP Pljevlja plant started operating in 1982 and is currently the only TPP in Montenegro.
Economy and Occupation
Mining in coal and zinc and lead mines is well developed in the Municipality of Pljevlja. Potrlica Coal mine supplies the TPP and the rest of the production is marketed.
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 municipality, even though Municipality of Pljevlja has great resources for wood processing and is rich in high quality forests.
Municipality of Pljevlja has natural and cultural-historical heritage which represents 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 the UNESCO protection. In this regard, the Municipality has great possibilities for developing rural and eco-tourism as well as organic food production.
According to the latest Index of the municipal development, Municipality of Pljevlja is on 13th position out of 23 municipalities in Montenegro (Ministry of Economy, 2015).
Regarding the Project Area, most of the affected landowners are providing livelihood for their households. One household has regular income, while other households have at least one or more regular sources of income, whether from pension or salaries. According to the RAP Survey, the ratio of unemployed respondents is approximately 36%. Some 19% of the respondents are pensioners. The remaining is employed.
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Livelihood and Resettlement
The Project consists of remediation of Cassette II and relocation of the Paleski Stream. Remediation of Cassette II and construction works for the relocation of Paleski Stream would have positive impacts on the local economy and livelihoods through employment and trade opportunities. There would be some limited adverse impacts on the livelihoods of the persons having property on the relocation route of the Paleski Stream. The proposed new Paleški Stream route passes through some private parcels which would need expropriation. This issue for the Paleski Stream relocation was considered and studied in the RAP report prepared by the EPCG in 2017. For the affected persons all compensation and relevant mitigation measures are developed and presented in this RAP.
IV.6. Protected Areas and Cultural Heritage and Properties
There are two Category I cultural monuments (monuments of extreme importance) on the territory of the Municipality of Pljevlja, as well as four Category II cultural monuments (monuments of great significance). In addition to the abovementioned 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 the early prehistoric eras.
In the minor area/vicinity of the Maljevac Landfill there are no monuments protected by law, nor have other important cultural and historical heritage assets been recorded. In the wider surrounding area there is an archaeological site in Komini (1km from the site).
V. ENVIRONMENTAL AND SOCIAL IMPACTS
The relocation/diversion of the Paleški Stream and remediation of the Cassette II is formulated as a Project to be financed by the funds obtained from the World Bank. The ESIA study is mainly aimed at this Project, which intends to mitigate some of the ongoing impacts of the ash and slag disposal activities on the environment. The other elements included in the Main Design are planned to be performed in phases and they will be financed from the EPCG’s individual source of financing.
Area of Influence
Potential area of influence (AoI) of the Project includes the geographical area that potential impacts of the Project could extend to. The AoI is defined for physical and biological environment, and socioeconomic environment and has been covered as the study area in the ESIA Study.
In this regard, the AoI for physical and biological environment includes the Project footprint (including the Cassette II reclamation), the upstream and downstream of the Paleški Stream and the new stream bed route reaching to the Borovičko Lake.
In terms of the socioeconomic environment, the AoI includes the close-by settlements mainly Zbljevo and Podrogatac. In addition, Pljevlja is considered as the main settlement unit where these villages are also connected, so certain assessments are based on Pljevlja.
V.1. Impacts on Physical Environment
Impacts on Air Quality
Main impact of the project activities on air quality would be dust generation. 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 soil materials dust is a potential impact to consider.
The most intensive process of dissemination of ash originates from the embankments that are being constructed for the new cassettes, since the hardened surface is getting devastated by construction machinery. Other spots from which wind lifts the dust are dry landfill strands, during periods after winter frosts, whereby the settled ash is separated from the compact precipitated surface due to frosting. This happens when the wind speed is higher than 2.0 m/s. Thereby; this brings about potential threat for quality of the surrounding air, as well as the quality of soil.
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Regarding emission of dust and exhaust gasses from construction equipment; the estimation of emissions is based on the specifications and standards, which must be met by the drive motors of the construction equipment/machines and the planned number of machine hours. The total emissions were estimated according to the limit values for construction equipment for the standardised allowed emissions of CO, HC, NOx and PM10, in line with the guidelines for the EU Stage III standard. The estimated results indicate that use of these construction machines would not cause unmanageable negative impacts on air quality in the area.
Impacts on Water Quality
The main expected impact on water quality of the Project is related to Paleški stream and to Vezisnica and Cehotina rivers as well as the impact on water quality of Borovičko Lake.
Maljevac Landfill represents a hilly-mountainous landfill, made by partitioning of a part of the Paleški Stream valley by constructing an earth (embankment) dam. The Paleški Stream was taken into the collector under the landfill body.
The Project will mitigate the already existing impacts on water quality in the area, so once implemented it would have positive impacts on surface and groundwater quality. Through mitigation of the possible negative impacts that would be observed during the construction phase of the Project, the adverse impact significance will be low.
Impacts on Soil Quality
The potential impacts of the Project on soil quality would be due to use, fuelling, and maintenance of the construction vehicles, waste disposal on the lands around and the construction sites. There would be soil loss at the land take areas for the Paleski Stream. All these impacts could be easily controlled with standard measures.
Impacts of Noise and Vibration
Maljevac area belongs to the Industrial zone. At the border of this zone, noise must not exceed the noise limit values set for the zone it borders. In this case, the zone it borders is the Quiet zone in the agglomeration in which the noise limit values for day and evening conditions are 40 dB, while the night limit value is 35 dB.
Based on the estimations, it may be stated that the noise levels in the provided conditions – for the Quiet zone in the agglomeration, will be above the limit values in the 100 m diameter from the source of noise, during the process of performing the works. The least favourable case was considered while performing the calculations, which is difficult to happen in practice. The proposed project activities would use a limited number of construction equipment and would be conducted in a limited area, so vibration would be generated rather locally. Therefore, any impact of noise and vibration would be rather insignificant and would not be felt in the nearby settlements.
Impacts on Flora and Fauna
Deposition of ash and slag has been carried out since 1982 on the Maljevac Landfill, which has already affected the flora and fauna in the area. These impacts can be summarized as follows:
Loss of vegetation and habitats due to land acquisition Loss of flora species on these lands Movement of terrestrial fauna away from the landfill site Negative impact on water ecosystems of the streams and river Negative impact on agrobiodiversity in general.
The ecosystem in the area reached a balance with the operations of the Landfill. In this regard, the proposed Project (remediation of Cassette II) would not cause any further considerable impacts on the flora and fauna. Thus, the overall state of things would not get worse, and the already reached equilibrium would not change. In fact, some positive impacts on flora and fauna might be expected after closing the landfill, specifically upon the performed recultivation, whereby the damaged ecosystem shall be rehabilitated.
In regards of the relocation of the Paleški Stream component of the Project, there would be some land acquisition on the new route of the river bed and the terrestrial environment would be converted to aquatic environment in these areas. Thus, there would be some loss of flora, but the river bed would not be too wide (around 30 m), so
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the loss of flora species would not be significant. In addition, the terrestrial fauna species would still have a chance to survive in the surrounding area, which minimizes the impacts on those species.
Impacts on Climate Change
The types and number of vehicles to be used within the scope of the Project are rather limited. It may be concluded that potential impact of project activities on climate change would be rather insignificant.
Impacts on Land and Landscape Characteristics
The ash and slag landfill have been in the exploitation phase for more than three decades, which caused loss of land and degradation of soil in the initial stage of formation of the landfill. In order to fulfil the conditions for continuation of deposition of ash and slag on the landfill, it is planned to expand it by constructing the Cassette III, which will cause loss of additional land, and thus a discontinuity will occur on the naturally shaped terrain.
By examining the cadastral parcels on which the landfill is located, as well as the green buffer zones around the landfill, it was seen that the land is divided into several types. Agricultural land around the Maljevac Landfill takes up around 60% of the total surface area, being the dominant land use type.
There would not be any significant impact on land and land use due to the proposed Project. After completion of restoration the impacts to the landscape will be reversed and, depending on the quality of the restoration work, the area could gain significant amenity value.
Waste Generation
Types and volume of materials used, and waste generated during construction works and operation phase of the Project are expected to be small. Occasional hazardous waste may arise during civil engineering works and during the maintenance activities, clearance of drainage facilities and, separators and clean-up of accidental spills. The waste management will be carried out in accordance with the EPCG Waste management Plan. No significant impact is expected to arise from resource use or waste disposal during operation in regard to maintenance of the landfill.
V.2. Socio-economic Impacts
Impacts on the Local Population
The proposed Project is not expected to have significant impacts on the local population. Impact on the population would be caused due to the Project Plus (planned construction of the Cassette III) since there would be a need for expropriation of the land required in the buffer zone (300 m distance from the landfill). A separate resettlement action plan (RAP) has been prepared for this impact and relevant mitigation and compensation measures were developed.
Impacts on Business Activities and Livelihoods
The proposed Project would have positive impacts on socio-economic situation and livelihood since local population would be involved in the Project as workers. There would be some limited adverse impacts on the livelihoods of the persons having property on the relocation route of the Paleski Stream. This issue was considered and studied in the RAP report prepared. For the affected persons all compensation and relevant mitigation measures are developed and presented in the RAP.
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.
Impacts on Community Health and Safety
Key identified reasons for potential negative effects on people’s health and safety is seen in air, soil and water pollution as well as noise. The proposed Project would not have significant effects on the health and safety of the
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community. There might be limited risk associated with the traffic during the construction works especially regarding the relocation of Paleski Stream. By realization of the Project, some positive impacts would be expected. Impacts on Cultural Heritage
The proposed Project and the overall Maljevac Landfill would have no considerable impacts on the cultural heritage assets and monuments identified in the region.
VI. PROJECT ALTERNATIVES
In this section the alternatives in the Project are evaluated; including alternative routes for the Paleski Stream relocation, alternative methods for construction, and alternative methods of reclamation for Cassette II. No Project/Action 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 this case, 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 cannot be regarded as an appropriate option for the ash disposal site.
Alternative Projects for Remediation and further Operation of the Maljevac Landfill
Following alternatives are evaluated during development of the project:
Stabilization of the embankment and monitoring the status of the dam; Stabilization of the dam and construction of series of drainage wells; Construction of Cassette II and continued ash deposition, relocation of Paleski Stream, and phased reclamation of the landfill.
The further assessment of these alternatives showed that the third alternative has least adverse and most beneficiary impacts among the other ones. Third alternative provides the solution for minimization of surface water contamination by collecting of the effluents of the ash dump and recycling them to the system and by relocating the Paleski Stream.
Variant Solutions for Landslide Rehabilitation
The conceptual design was developed based on the selected alternative project. The following variants for surpass of the entire landfill were evaluated, according to the order of construction and exploitation of each Cassette:
Variant 1 – Cassette II – Cassette III m – Cassette I Variant 2 – Cassette II – Cassette III v – Cassette I Variant 3 – Cassette II – Cassette III v – Cassette IV – Cassette I Variant 4 – Cassette II – Cassette (III v + IV) – Cassette I
From the detailed comparison of the variants, Variant 4 has been chosen since it is distinctive, whereby the basic creation of evaluation was maintained (i.e., providing the highest possible storage volume for the ash with reaching the longest possible period of exploitation of the landfill). Advantages and disadvantages of the selected alternatives are as follows:
Advantages: o Extended period of exploitation of the landfill o Usage of maximum available space of already devastated land o Reclamation of the Cassette II in parallel with exploitation Disadvantages: o Negative impact from the continued use of the site for dumping for the next 7 years o Negative impact on the landowners due to the expropriation (for Cassette III) o Risk of unsynchronized works or delayed works during phase reclamation
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Variant solutions for Relocation of Paleški Stream
Three variants of relocation of the Paleški Stream have been considered during preparation of the Project.
The variant proposed includes relocation of the Paleški Stream to the Borovičko Lake. The existing collector would stay in function while leachate would be pumped out to the recirculation system of technical waters. The relocation route would be on the north side of landfill, from upstream part toward asphalt road and further to the downstream part of the landfill where it would be connected with the natural bed.
That variant is in accordance with prescribed Urbanistic-technical conditions and will provide the solution most similar to natural flowing conditions of the stream.
Rehabilitation Technology/Method options for Cassette II
Within biological reclamation of the Cassette II, different methods for reclamation of the degraded surfaces have been considered, such as self-reclamation, semi-reclamation and optimal reclamation. Due to the state of the surface after completion of ash dumping on Cassette II of the Maljevac Landfill, and specific pedological, microclimate and climate conditions, optimal reclamation with grass planting and forestation was selected.
VII. ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM AND ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN
The Project ESMP is divided into two functional groups which are Mitigation Plan and Monitoring Plan. 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.
The EMP and Monitoring plans are the basis for fulfilling the requirements under Montenegrin legislation. In a later phase, the Environmental Protection Agency will require all construction contractors to develop a detailed Construction Environmental Management Plan (CEMP) for their respective activities.
Key mitigation measures and monitoring issues are presented in Table 2 and Table 3 below, respectively.
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Table 2. Summary of the Impact Assessment and Mitigation Measures
Issue Mitigation Measures Land Use, Erosion and Slopes of embankments will be landscaped and planted. Landslide Risks 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 Oil and fuel will be stored in places with secondary containment. Site specific emergency plans will be prepared to respond any incidents and spillages. Topsoil will be removed, stored, and handled in such a manner that it would be used during finishing works. Non-controlled and unplanned access road openings will be prevented. Soil Quality Drainage channels will be constructed. Operational plans for winter maintenance would be developed. Soil quality will be monitored during operation stage including control of the top soil in the village Gradac Donji. Working sites will be frequently watered in land preparation and construction phase. Temporary spoil storage areas will be positioned not to be vulnerable to wind erosion. Air Quality EPCG will designate a liaison staff, in case of complaints related with air quality that could be received from the neighborhood settlements. Construction will be limited to day-hours (07:00-19:00). Noise Natural acoustic barriers and screens will be used. Systematic collection of solid waste during construction and operation phases will be undertaken Waste Generation 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 for Cassette II Landscape including the realistic requirements to minimize short term visual intrusion 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. Measures will be taken to prevent animal deaths in the project area and on access roads. Checks and photographic recording for germination success of planted areas and for natural Ecosystem / Flora and regeneration/vegetation will identify locations and areas of disturbance, successes and failures. Fauna Technical measures, such as fencing and intermediate cover, will be taken to prevent the entrance of fauna to the landfill site. Passages over the new Paleski Stream bed would be formed/allowed as appropriate for the fauna. Land acquisition will be done in a manner which ensures transparency and accountability, and which ensures that compensation is paid in accordance to the law in force. Appropriate disclosure of information, consultation, and the informed participation of affected Socioeconomy persons and community will be implemented. Procurement of the land has been started on 'willing buyer/willing seller' basis. EPCG has developed a Resettlement Action Plan. Contractor will follow the national requirements with respect to "chance finds" which may emerge Cultural heritage during construction. EPCG 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 Occupational/Works Health incidents, i.e. Implement international HSE standards in all contracts. and Safety A Health and Safety Management Plan would be developed as well as undertaking training programmes, inspections and reward/penalty schemes to enforce safe working practices. An Emergency Action Plan will be developed in lien with the emergency plan and procedures of Emergency Situations the EPCG.
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Table 3. Summary of Monitoring Activities
Issue Parameter to be Monitored Erosion and Landslide Slopes and relevant signs Risk Surface Water and Water quality parameters (sampling and analysis) as required in relevant legislation Groundwater Number of spill/leakage incidents and corrective measures taken in accordance with national and Soil international standards and soil quality parameters (analysis) as required in relevant legislation Air Quality Dust and PM 10 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 Having alternative access to the parcels close to the construction site, and related grievances Socio-economy records 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
VIII. PUBLIC PARTICIPATION AND INFORMATION DISCLOSURE
The Project as a part of a larger project framework was subject to previous public consultations during development of the ESIA for Remediation of Five Contaminated Sites, as well as within the national EIA procedure and the public consultation during the RAP process. A meeting was also held with the representative of village Zbljevo in the initial phase of ESIA development. Thus, these consultations are considered as first round of discussions related to scope of this ESIA. A public consultation/participation meeting would be conducted within the scope of the ESIA studies following the completion of the draft report in line with the WB standards.
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