Environment Management Plan - an Investment Program of Water & Sewerage SPLLC-Tagovishte

REPUBLIC OF Public Disclosure Authorized MINISTRY OF REGIONAL DEVELOPMENT AND PUBLIC WORKS

MUNICIPAL INFRASTRUCTURE DEVELOPMENT

PROJECT

DRAFT ENVIRONMENT MANAGEMENT

Public Disclosure Authorized PLAN /EMPI

VOL. 9 Public Disclosure Authorized

Investment Program of Water & Sewerage SPLLC - Razg+ad

October, 2007 Public Disclosure Authorized

Omonit Consult LLC, 17 G. Benkovski Street, 1000 phone.: 021980-21-16; fax: 021980-04-68 Environment Management Plan. an Investment Program of Vodosnabdyavane Dunav SPLLC .

TABLE OF CONTENTS

1. General ...... 3 1. 1. Purpose of the Project ...... ,...... 3 1.2. Bank's Requirements and Documents ...... 4 1.3. Role of the EMP...... 4 2 Initial Information Review...... 5 2.1. Selection Principle for Projects included in the Investment Program of waler Supply DUNAV SPLLC . Razgrad Projects for the Period 2008.2012 ...... 5 2.2 Brief description of the projects included in the Investment Program Ha waler Supply DUNAV SPLLC . Razgrad ...... 5 3. Analysis of the possible environmental impacts of the Project ...... 6 3.1 Positive impact ...... 6 3.2. Adverse Impacts ...... 7 3.3. Adverse Impacts during Construction ...... !...... 7

3.4. Adverse Impacts during Operation ...... ' ...... 10 4 Mitigation Measures against Potential Environmental Impacts due to Implementation of the Investment Program . during the construction and during the operation phase ...... 10 5 Monitoring ...... 13 5.1. Monitoring and Control during the Construction ...... 13 5.2. Monitoring and Control during Operation ...... 13 6. Conclusions and Steps Recommended to Ensure Performance of the EMP ...... 1 ...... 14

7 Consultations and Public Discussions . Discussion of the Positive an4 Adverse Impacts. Routine Consultations and NGO ...... 15

APPENDICES:

Annex 1 Contract Provisions Annex 2 Environmental Impact Mitigation Program for the Construction andoperation Phases Annex 3 Construction Phase Monitoring Program Appendix A. Normative Documents Applicable to the Project Appendix B. Abbreviations Used Map of Razgrad with plotted sectors of the water supply network to be reconstructed

Omonit Consult LLC. 17 G. Benkovski Street. Sofia 1000 phone ..02/980.2 1.16. fax:02/98q-04-68 2 Environment Management Plan - an lnvestment Program of Vodosnabdvavane Dunav SPLLC - Razgrad

1. General

The government of R. Bulgaria requested the World Bank's assistance id financing of activities related to the Municipal Infrastructure Development Project whicl) will help Bulgaria to comply to the European Union's directives on potable and waste water and the environmental protection factors in the investment schemes that will be acceptable and eligible for financing from the European Union's Structural Funds and are not {overed by other EU grants. The Project, part of which is this Environment Management P\an /EMPI, encompasses the completion of water-supply dams (Neykovtsi, Plovdivtsi and Lpda Yana) where construction was suspended in the last decade, and operating dam (Studena Dam), as well as rehabilitation of the water supply companies providing Water and Sewerage services (, Razgrad, and Smolian).

1.1. Purpose of the Project

The general purpose of the Project is to ensure better water supply and responsible use of the water resources underlying the state policy for sustainable developdent of the water sector. That objective is completely in the spirit of the National Strategy o'f Bulgaria for Environmental Protection (2005 - 2014) that envisages ,,provision of gobd-quality water and sufficient water supply for all purposes".

The purpose of the Project will be achieved by means of:

a) improvement of the conditions of water supply for domestic & drinking needs in selected regions; b) - ensuring the required quantity and quality of potable water; c) reduction of losses in the water supply network; d) improvement of the reliability and efficiency of water supply systems and facilities; , e) provision for environmental requirements and regulations with respect to the systems; f) enhancement of the management and operating capability of the oplerators

providing Water and Sewerage services. I I

Omonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/980]04-68 3 Environment Management Plan - an Investment Program of Vodosnabdvavane Dunav SPLLC - Razgrad

1.2. Bank's Requirements and Documents.

The overall environmental category of the proposed Project is A in line with Bank policies with individual investments that belong to both category A (the proposed dam completion activities and category B (the rehabilitation of water networks). Based on the proposed Project Investments the following World Bank's safeguards policies and procedures are triggered: OPIBP 4.0 1 Environmental Assessment; OPIBP 4.12 Involuntary Resettlement; OPIBP 4.37 Safety of Dams; and OPIBP 7.50 Projects on International Waterways. Furthermore, adequate protection and maintenance of ecosystems downstream of the dams should be assessed during project preparation to determine the relevance of the OPIBP 4.04 Natural Habitats and OPIBP 4.36 Forestry safeguard policies. Also, given the possibility that proposed water companies might implement projects in with historic districts, the OPN 11.03 Cultural Property safeguard policy might be triggered. The following documents will be prepared by the Government of Bulgaria prior to project appraisal: (1) Environmental Framework of the Project (EF) for all proposed subprojects; (2) Environmental Due Diligence Report (EDR), including, in summary, assessment of the site conditions and assessment of the possible environmental impacts related to completion and operation of the proposed three dam sites; (3) Environment Management Plans (EMP) on investment in rehabilitation of the water distribution networks in which the contract provisions for construction works will be specified /See Annexes 1, 2 and 31 related to application of the technical standards and other requirements relevant to the construction phase. 4) project Land Acquisition Policy Framework that will outline the process to be followed in case there is land bcquisition needed for the project; and (5) Social Due Diligence for the three dam sites that presents an overview of the past land acquisition process carried out by the Government.

1.3. Role of the EMP.

The present Environment Management Plan was developed by the Consultants Team of Omonit Consult LLC by assignment of the Ministry of Regional Development and Public Works (MRDPW) and contains a main explanatory part, Contract Provisions (Annex 1) on environmental precautions, Environmental Impact Mitigation Program, (Annex 2), including appropriate environmental protection measures that will help to mitigate the negative impacts arising from the construction of new facilities and rehabilitation of the water supply system of Water Supply DUNAV SPLLC Rqzgrad, and the attendant costs, as well as an Environmental Monitoring Program (Annex 3) pointing out to the parties in charge of the implemegtation of that program that, in the detailed documents of the works, they shall ensure adherence to all provisions related to environment and to the correct implementation of all environmental protection measures. The monitoring Plan includes information on the insp~ctionsin the course of realization, internal and external monitoring and assessment, as well as a reporting system. The plan presents cost estimates of the environment management measures and the time schedule of their performance.

Omonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/98q-04-68 4 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

2 Initial Information Review.

2.1. Selection Principle for Projects included in the Investment Program Of Water Supply DUNAV SPLLC - Razgrad Projects for the Period 2008-2012.

Selection of the sites proposed for financing from the loan granted by the World Bank was performed after analysis and assessment of the condition of the individual components of the water supply systems serviced by Water Supply DUNAV SPLLC, namely: settlements in the municipalities of Razgrad, and Tsar Kaloyan Razgrad District; the municipalities Popovo and in District, and two spttlements in the Municipality of Ivanovo, Rousse District. Their water supply systems are mainly of the pump type. The high loss percentage (reaching 60% of the fed volume) is the maih criterion used to assign the priorities in the selection of sites for the Investment Program. Irrespective of the poor condition of the water supply network, the water resodces in the region meet the needs for potable water supply. The total number of residents served by Water Supply DUNAV SPLLC - Razgrad is 117 874. The share of the population affected by water rationing is the lowest in the country - about 15% (in small aggldmerations supplied by local water sources with seasonal variations of the flow rate).

2.2 Brief description of the projects included in the Investment Program ua Water Supply DUNAV SPLLC - Razgrad.

Centralized water supply is provided to all 52 settlements within the Operator's service area. It is provided mainly by the DUNAV Water supply system and 248 own water sources, 99 pump stations and 180 pressure reservoirs. Raw water is drawn by means of deep drilling (for a few villages - by means of drains and captations) which determines the highest price of the Operator's service in the country. The total length of the network is 1 754 km,of them head mains - 670 krn and street mains - 1 084 km. It is built mainly of asbestos cement pipes ( 70% ) with expired service life and high wear entailing serious water losses (60%). There is no potable water purification plant (PWPP) in the area, for which reason the water is supplied to the consumers only after disinfection. The quality of the ground and surface waters is adversely affected by the unfinished sewer networks and town waste water treatment plants ( TWWTP ) and by the application of bad agricultural practices. As a component of the engineering infrastructure, the water supply system of a district center has its functional specifics and spatial structure with increasing requirements set to it with a view to meeting the growing demand on the part of its customers. The Operator's attention is directed with good reason to the administrative center of the district

Omonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/980-~04-68 5 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad as a center of the social and economic and cultural activity, and where about 30% of the district's population is concentrated. The Investment Program of Water Supply DUNAV SPLLC, Razgrad envisages reconstruction of street water mains and replacement of piping branch-offs td buildings (PBB) in order to provide normal water supply to Razgrad. The data from an on-going joint monitoring with the Regional Inspectorate for Protection and Control of Public Health - RIPCPH show that health risk to the population has been minimized. A high dtandard of physico-chemical and micro-biological indicators was achieved in 2006 - more than 90%, in conformity with the requirements of Regulation No. 9116.03.2001 on the quality of potable water. The total length of water mains subject to reconstruction is 73581m (63221 m distribution network and 10360m - main branches), with diameters from 80mm to 350mm, the routes of which cross urban territories. Besides, 4105 LPB will be replaced.

3. Analysis of the possible environmental impacts of the Project

The analysis is based on the present state of components and environmentpl factors, and their possible development in connection with the investment intentions of Water Supply DUNAV SPLLC, Razgrad for the reconstruction of water supply facilities. The main problems, conclusions, recommendations and mitigation measures are defided in conformity with the goals defined in the Terms of Reference (TOR).

3.1 Positive impact

3.1.1. Positive environmental impact. Reasonable consumption of the water resources is of primary importance to the present as well as to the future generations. With implementation of the projects actual reduction of unreported water flows will be achieved which will result in reduction of the water quantities delivered at the inlet end of the water supply system and ecological resource economy. The smaller number of accidents guarantees also operation reliability. The replacement of asbestos cement and steel pipes by pipes made of high-density polyethylene (HDPE) permits application of mbdern pipe laying technologies. , 3.1.2. Positive social impact The proposed Program fits success full^ into the regional strategy for balanced and sustainable development of the Razgrad District, with actual contribution to improvement of the quality of water supply service provided to the population in the district center. The contemplated measures will help to erihance the regional competitiveness and level of development, and manifestation of its qdvantages withln the country's general development strategy. With improvement of the conditions in the urban environment and less urbanized territories related to it, beneficial conditions for development of the local tourism will be created. Opening of temporary jobs at the construction works is a prerequisite for social and economic stabilization of the respective region.

Ornon~tConsult LLC, 17 G. Benkovski Street, Sof~a1000 phone.:02/980-21-16; fax:02/98(1-04-68 6 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

3.2. Adverse Impacts

During the construction phase: The territories coming under the easement of the water supply network routes will be affected due to the increased emissions of certain noxious substances, fine dust particles and other pollutants generated by the operation of earth-moving building machines and transport activities, handling of earth and bulk building material, layer compaction, etc. During the operation phase: A negative impact on the urban environment (street network and infrastructure) can be expected as a result of accidents and/or incidents.

3.3. Adverse Impacts during Construction

The negative impacts during construction are mainly direct, temporary (within the construction phase), short-time and localized, without any cumulative effect.

3.3.1. Due to the nature of the contemplated works

Disrupted water supply in the region of activities. Potential deterioration of potable water quality upon a change in the wqter supply arrangements. Scattered materials and machines on the construction sites- pipes, reinforcement iron, pieces of castings, damaged building machines, etc.; creation of unregulated di~posalsites for construction debris and spoil material. Inappropriate methods of work and waste treatment in the case of asbestos-cement pipe replacement. Disruptions of the transport traffic and the attendant inconvenience to residents.

3.3.2. Due to type and use of materials

During construction, increased levels of fine dust concentrations in the air can be expected in the event of failure to apply the preventive measures during traqsportation, storage and placing of the aggregate materials used.

3.3.3. Due to construction debris and waste generated at the construction site

Waste generated during construction at any work site, according to the national classifier is: domestic solid waste, construction debris, waste fuels and lubricants, and less probable: hazardous, pints and varnishes. Domestic solid waste generated by the construction workers is handled together with that generated by the residents or urban territories. There is no provision for opening of any canteens or kitchens. The waste generated upon dismantling of asbestos-cement pipes will be treated in conformity with the prevailing regulatory acts (items 17 and 18 of Appendix A).

3.3.4. Atmospheric Air

Omonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/960-21-16; fax:02/989-04-68 7 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

It is assumed that the operation of building machines and transport vehicles at any construction sector creates pollution by dust and exhaust gases. Due to the limited dimensions of the sectors such pollution is local, however in the urban territories it may exceed the permissible concentration limits (permissible concentration limits, PCL).

3.3.5. Noise and Vibrations

Objects of impact by the "noise" factor will occur mainly during construction or refurbishment of the street water supply network in the settlements. The noise limits set for them are different depending on their function (item 23 of Appendix A). Residential areas: daytime - 55 dB(A), evening - 50 dB(A) and at night - 45 dB(A). Central urban areas and areas subjected to busy motor vehicle traffic: daytime - 60 dB(A), evening - 55 dB(A), at night - 50 dB(A). Educational activity and leisure areas: daytime - 45 dB(A), evening - 40 dB(A), at night - 35 dB(A). Medical facility areas: daytime - 45 dB(A), evening - 35 dB(A), at night - 35 dB(A). The noise sources during refurbishment of water mains and facilities, and dhring new construction are various transport and building machines and plants such as: dredger, front loader, asphalt cutter, compactor, asphalt laying equipment, roller, compressor, heavy-duty cars, with noise limits within the range 80 dB(A) - 92 dB(A). Noise levels considerably exceeding the above-indicated sanitary limits can be expected near the operating machines. The impact of high noise levels will last for a limited time period - till completion of the works in the respective sector of the water supply netwark. An increase of the overall acoustic load in that region of construction activities occurs also in the case of idle running building and transport machines.

3.3.6. Water

Release of effluent with excessive concentration of chlorine and chlorine-based reagents in open water courses during the startup and adjustment of the refuqbished or newly built water mains.

3.3.7. Soils

The soils are an acceptor of all harmful impacts in the environment and thus present a potential risk to human health. Erosion, floods, landslides and landfalls are factors that can cause environmental problems during both construction and operation phases. Improper disposal of construction debris and domestic solid waste may also cause soil pollution and degradation.

3.3.8. Flora

According to data from the W&S operator and the Targovishte District Administration, the investment projects do not belong to the Natura 2000 territories under the Habitats Directive and no rare or endangered species are destroyed.

- Ornonit Consult LLC, 17 G. Benkovski Street, Sof~a1000 phone. : 02/980-21-16; fax: 02/980;04-68 8 Environment Manaeement Plan - an Investment Program of Vodosnabdvavane Dunav SPLLC - Razgrad

3.3.9. Landscape

The scale of contemplated rehabilitation and new construction is small and no significant impact on the landscape is expected. After completion of the conshuction the urban environment will be restored (pavement, curbs, side walks).

3.3.10. Health Factor

3.3.10.1. Health risks for the population: a) Risk of excessive noise due to operation of the building machines. That noise is not permanent but with temporary effect only. The effect is disturbing and irritating. b) Work in the open precludes the negative health effect of combustion :gases and asphalt evaporations. 3.3.10.2. Health risks to the workers: a) Adverse weather conditions having in mind the need to work "in the open all the year round" in an environment with considerable temperature amplitudes. High temperatures are a risk factor of incidents such as thermal andlor sun shockd. Too low temperatures increase the frequency of colds, diseases of the skeletal/mudcular and peripheral nervous system. b) The drivers of building machines will be subjected to excessive noise levels of the order 80-100 dB(A). Noise has an adverse effect on the hearing and central nervous system resulting in sornnopathy, development of neurotic conditions aqd arterial hypertension. c) The drivers of building machines will be subjected to general and local vibrations. They injure the vestibular apparatus, the locomotory systea and the parenchymal organs, the sensory and circulatory systems of the fingers. 1 d) With the limited scope of excavation and refurbishment works and work in the open air, no adverse health effect is expected by air pollution. e) The labor haurnatism risk is highest in the case of manual excavation and erection works. - In the case of hard physical work involving lifting and carrying of excessive loads, there is higher risk of diseases of the locomotory and nervous/muscular system.

During the construction the working environment factors can have certairi effect on workers' health. Such effect is temporary and will be minimized if measures for protection of the workers' health and safety are undertaken. I

3.3.11. Common Heritage

According to information from competent authorities there are no historical, architectural and archaeological monuments along the routes of the proposed siies. In the event of an unforeseen find the Bulgarian legislation provides for the necessary adtion (item 8 of Appendix A).

Omonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/980104-68 9 Environment Management Plan - an Investment Program of Vodosnabdvavane Dunav SPLLC - Razgrad

3.4. Adverse Impacts during Operation

More significant adverse impacts are formed in the operation process in the event of failure to apply the Emergency and Accident Action Plan in relevant situations.

4 Mitigation Measures against Potential Environmental Impacts due to Implementation of the Investment Program - during the construction and during the operation phase.

The present EMP contains mitigation measures against the negative environmental impacts that are referred to the above-listed potential impacts, and will be applied in the course of Project implementation and after it.

During the construction:

4.1. For normal functioning of the water supply system in the regions that will be affected by the works, autonomous and/or alternative water supply should be organized for the time of construction and startup.

4.2. The repair works contemplated by Water Supply DUNAV SPLLC, Razgrad of the street water supply network allow, with appropriate organization, perfect matching of the construction/erection works (CEW) to the uninterrupted operation of the water supply system. As required, alternative water supply is ensured for cases of time extension announced by the operator.

4.3. In cases of modification of the water supply pattern the operator shall provide additional quantities of chlorine and chlorine-based reagents for disinfection of the drinking water with a view to preventing adverse health effects to the population.

4.4. It is recommended to use with priority non-excavation technologies that permit minimization of the environmental. impacts. Digging up of the streets is avoided. Besides, changes in traffic organization are reduced.

4.5. Construction debris is deposited in landfills defined by permits. Earth masses in the urbanized territories as well as in the country are stored temporarily along the routes after which they are used for backfilling. The spoil materials /earth and rock/ are handed over to the state forestries or to interested persons.

4.6. The nearest motor depots are used for filling with fuel and lubricants.

Ornon~tConsult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/9qO-04-68 10 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

4.7. In the event of generating any hazardous waste, including those generated by replacement of asbestos-cement pipes, a firm possessing a license for their treatment is contracted.

4.8. The transport routes crossing settlements for waste transportation to the deposit sites are agreed upon with the municipalities.

4.9. For containment of the impact mainly on the working environment and on the population, the following measures should be undertaken: water sprinkling, monitoring of the condition of machines and vehicles.

4.10. In the final phase of the construction, the quantities of reagents needed to neutralize the residual quantities of chlorine in the effluent from flushing and sanitation of water mains and facilities shall be defined in order to meet the requirements of environmental legislation towards the quality of such effluents and to prevent pollution of the environment (soils and open water courses) by chlorine agents.

4.1 1. Drinking water is delivered to the the construction site by water-camer cars or bottled.

' 4.12. In the course of rehabilitation measures and new construction in urban territories all effluents generated in the construction process as well as neutralized water from flushing and sanitation of water mains and facilities shall be discharged into the public sewerage system or into the nearest water basin with quality corresponding to its category.

4.13. The technical condition of machines shall be checked every month for oil leaks.

4.14. The existing latrines or chemical toilettes shall be used for the sewage.

4.1 5. In order to prevent soil pollution, inspections of the building machines and transport vehicles shall be regularly performed. Transport vehicles shall be washed in the appointed places.

4.1 6. The transport vehicles shall be covered.

4.17. In the course of rehabilitation works and construction of new facilities the destruction of ligneous and fruticose vegetation shall be minimized as much as possible, after coordination with the competent authority.

4.18. In compliance with the Bulgarian legislation upon discovery of archaeological finds in the course of construction works the Museum of Archatology and History shall be informed, the construction shall stop temporarily and the respective decision about their preservation shall be made (items 2 and 8 of Appendix A).

4.19. Construction activities shall be limited within the daytime period - from 7,00 a.m.. Till 7,00 p.m.

Ornonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/98()-04-68 11 Environment Manaeement Plan - an Investment Program of Vodosnabdvavane Dunav SPLLC - Razgrad

4.20. The machines and plants used shall be kept in good repair.

4.21. The exhaust pipes of the transport vehicles and building machines shall be fitted with mufflers.

4.22. Idle running of the transport vehicles and building machines shall not be allowed.

4.23. With a view to limiting the adverse effect of unfavorable weather conditions, the workers shall be supplied with work clothes suitable for the season (item 15 of Appendix A).

4.24. The workers shall be supplied with personal protection means - helmets, ear muffs, anti-vibration gloves, safety belts, etc., depending on the specifics of work (item 15 of Appendix A).

4.25. In compliance with the normative requirements (with a view to reducing physical strain, overfatigue and development of skeletal-muscular diseases), regimen of work and rest within a working day are introduced (item 15 of Appendix A).

According to the Bulgarian legislation (item 15 of Appendix A), aggregate materials, concrete mixes and asphalt products used may be supplied only by enterprises possessing the respective license for their extraction and production. With respect to waste, the requirements of the Waste Management Act are met at all stages of the construction. The measures for mitigation and improvement of impacts related to invystments in rehabilitation and new construction at water supply sites will be included in the Technical Specification to the Construction Contract. Contractual security is an indispensable prerequisite for implementation, by the Contractor, of all needed measures for protection of the environment on the site itself and outside it and to limit the damage and inconvenience to people as a result of pollution, noise and other consequences of the construction works. The Contractor shall be sure that, by implementation of the indicated mdasures that the air emissions, surface run-off and treated effluents, noise and vibration impacts, etc., resulting from the activities performed do not exceed the levels stipulated by the applicable laws (items 3,4,5,9,10 and 12 of Appendix A).. Coordinated action with the local state ahd Municipal authorities and the competent environmental protection and public health bodies is an important prerequisite for successful implementation of the planned rehabilitation measures and new construction in the water transfer network.

During the operation phase:

4.26. he Emergency Action Plan defines the required environmental impact mitigation measures and the staff needed in such circumstances. The plan is developed by the Operator and reviewed by the local municipal administration

Omonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/960-21-16; fax:02/980-04-68 12 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

5 Monitoring

The contemplated model of monitoring the implementation of environmental impact mitigation measure was adopted so as to cover all aspects and requirements in conformity with the law and good engineering practice.

5.1. Monitoring and Control during the Construction

The adopted form of monitoring (Annex 3) includes a specific description of the monitoring and control measures and is designed to cover all aspects of the construction process (related to the adverse impact mitigation measures proposed in the adverse impact mitigation plan) with the parameters to be measured, methods to be applied, points of sampling, measurement intervals, concrete description of the organizational structures and reporting procedures;

5.2. Monitoring and Control during Operation

During the operation phase monitoring of the contemplated project sitas shall be performed by the Operator company in conformity with the normative requirements.

Organization of EMP application and reporting:

Monitoring and reporting will be applied entirely by the Contractor's management. The Contractor shall exercise everyday monitoring of the normal environmental practices by presentation of regular reports. These reports shall be addressed to the institutions indicated in the normative requirements and once in a month - to the Employer /Engineer/. The Contractor shall appoint its specialist in charge of the environmental aspects of the Project. The Engineer auditing the process shall report on the performance of environmental impact mitigation measures included in the Technical Specification to the Contwct; on the correct understanding and application of EMP by the Contractor; on assurwce of the relevant steps; on keeping correct record of any discrepancies, on the conducting of briefing and training, emergency aid measures, and shall evaluate and correct the Contractor's reports. The Engineer shall report on the EMP performance and progress to the Employer every month. The respective government institutions will be involved in auditing of all environmental protection and social measures and the progress on the Project by receiving regular reports in conformity with the normative requirements. The Project Management Unit (PMU) established at the MRDPW shall keep and store the documentation required by law and by contract. On the basis of the Engineer's reports and site visits as required, EMP performance and progress reports will be presented to the World Bank every six months.

Omon~tConsult LLC, 17 G. Benkovsk~Street, Sofia 1000 phone.:02/980-21-16; fax:02/98?-04-68 13 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

Institutional Responsibilities in Implementation of the Environment Management Plan

Making of decisions on Responsibilities for environment management impact mitigation and Reporting relations /start of action, expense performance (who reports to whom) authorization, completion/ monitoring and intervals Institutions or Activities persons in charge

MRDPW /Employer/ Contractor to Engineer Monitoring of Engineer RIEW /monthly/ EMP Superviqor, contact RIPQPH Engineer: performance person appointed IAE to MRDPW by Employer Municipality to RIEW /MKDP W/ /monthly/ MEW Project Management Unit MoEW at the MRDPW to the RIPQPH Bank (every 6 months)

6. Conclusions and Steps Recommended to Ensure Performance of the EMP.

According to the developed Environmental Impact Mitigation Program (Annex 2) and Environmental Monitoring Program (Annex 3), the Contractor is not required to provide additional facilities involving significant costs. The recommended steps needed to ensure performance of the EMP are: a) Provide for funds for implementation of the adverse impact mitigation measures and EMP performance monitoring by including it in the Technical Specifications to the Construction Contract. b) Obtain the Contractor's correct understanding of the steps and resources required for environment management, the required steps and measures being evaluated and offered. c) Discuss the EMP at preliminary clarification sessions. d) After signing of the Contract, the Employer shall officially familiarize the Contractor with the prevention and impact mitigation by means of the EMP included in the Contract and the implementation of monitoring. The main problems, conclusions, recommendations and negative impact mitigation measures are defined in conformity with the objectives set in the Terms of Reference. In the longer term, with the proposed investment projects, EMP implementation and through application of good engineering practices for optimization of the set of activities in the process of producing and supply of drinking and washing water to the population, the objectives of responsible use of water resources set in the government's policy for sustainable development of the water sector are achieved without any risk to

Ornonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/960-21-16; fax:02/98?-04-68 14 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

the environment and with a beneficial effect on the life quality of the population, which leads to the conclusion that the Project is beneficial

7 Consultations and Public Discussions - Discussion of the Positive and Adverse Impacts, Routine Consultations and NGO

In connection with the Municipal Infrastructure Improvement Project and more particularly, with implementation of the Investment Program of Water Supply DUNAV SPLLC - Razgrad, for the period 2008-2010 funded from a World Bank loan, the Environment Management Plan (EMP) was publicly announced at Water Supply DLMAV SPLLC - Razgrad.

EMP announcement Place of Comments made What was date announcement incotporated 1 2 3 4 22.10.2007 Water Supply No objections, comments DUNAV SPLLC or recommendations - Razgrad on the were received within the notice board 15-day time limit.

Ornonit Consult LLC, 17 G. Benkovski Street, Sof~a1000 phone.:02/980-21-16; fax:02/98@-04-68 15 Environment Management Plan - investment Program of Water Supply LLC - Razgrad Annex 1

Annex 1 Contract Provisions

The Technical Specifications of the Contract will include provisions on Environmental Protection.

General This Annex describes the environmental mitigation requirements to be followed by the Contractor and measures to be carried out by the Contractor(s) related to environmental protection. Contractor(s) shall follow all Bulgarian laws and regulations related to environmental protection in the process of construction organization and performance. Contractor(s) shall follow all Bulgarian laws and regulations related to environmental protection. The Environmental Monitoring and Management Plan shall constitute part of the method statement of the Contractor's proposed arrangements and methods of execution of the works required by section of these Technical Specifications. The Contractor shall be required to submit an Environmental Impact Mitigation Program and a program of monitoring the performance of the respective measures based on the provisions in this Environment Management Plan /Annex2 and Annex 3 to it/, prepared at the C~nceptual Design Phase and included in the Technical Specifications of the Contract.. The Contractor shall make sure that the air emissions, surface run-off, treated waste water, etc., resulting from its activity do not exceed the levels indicated in the Contract specifications and will not exceed the levels required by the applicable law. The Contractor shall provide the means, information, consumables, certified teams, tools and manpower needed for efficient test runs (sampling) wherever required. The Contractor shall nominate one of his senior staff members to be responsible for follow- up of the implementation of the provisions of the environmental plan as well as for the guidance of the rest of the staff and reporting to the Engineer. Without relieving the Contractor of its obligation for permanent control on conformity of the performance to the requirements, the Engineer will be in charge of the monitoring and verification of compliance of the overall construction work with the Environmental Impact Mitigation Plan and of making sure that there are no deviations from it or from the Contract. The Engineer shall have the right to interrupt the Contractor's wark if the conditions of the approved environmental plan are not met.

Permits The Contractor shall be in charge of drawing up and approval of the documentation and site-specific information:

1. Technologies and methodologies utilized by the Contractor; 2. Specification of basic materials for potable water supply and of the natural resources to be used (quantity and quality): i.e. all raw material, including gravel, fill, and bituminous materials as well as fuel and energy; 3. Specification of final work output; 4. List and characteristics of harmful substances utilized;

Ornonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax: 02/980i04-68 1 Environment Management Plan - investment Program of Water Supply LLC - Razgrad Annex 1

5. Particular measures ensuing from the climate conditions in the region of works, from the meteorological characteristics and coefficients of emission into the atmosphere; 6. Specification of water supply sources and treatment of waste water; 7. Investigation and obtaining of directions for disposal of humus and/or spoil material and/or construction debris from the construction site; 8. List of harmful substances generated in the production process by the Contractor 9. Emissions from construction equipment and transport vehicles.

Solid waste from construction and construction camps The Contractor(s)' obligations with respect to the material excavated are as described here below: The humus layer (wherever there is any) is reclaimed, deposited in the sites indicated in the permits and utilized on the terms and procedure of the existing Regulation on Humus Utilization. Construction debris and related waste shall be removed from the site in an orderly manner and disposed of in accordance with the existing regulations in the sites indicated in the permits. Clean soil material (Spoil Material) that is not reusable shall be removed from the site and deposited in accordance with the existing regulations in the sites indicated in the permits. The Contractor shall make arrangements for regular collection and removal of the solid waste from the construction site and construction camps to the respective disposal sites. When construction takes place in urbanized areas the solid waste is managed through the local waste collection and disposal systems of the respective municipalities. In the event of generation of hazardous waste, the Contractor shall contract a firm possessing a license for its treatment. The operations related to dismantling, transportation, storage and treatment of products containing asbestos shall be performed by persons possessing the permits required by the applicable law.

Protection of Ligneous Vegetation In the course of construction works, perennial ligneous vegetation may be destroyed only on the basis of a permit for clearing and in conformity with the regulation on developing and protection of the green system in the territory of the respective municipality, Grassed and park areas of the urban territory disturbed during construction shall be restored as part of the Contractor's obligations for restoration of the vicinity.

Noise control The Contractor shall follow all the existing laws and regulations concerning the noise control and limiting the discomfort to the population and the workers. The Contractor shall propose and adopt effective measures both in management and technology to minimize noise, including, but not limited to: The machines and plants used shall be maintained in good repair; The exhaust pipes of vehicles and building machines shall be fitted with muffles; Idle running of vehicles and building machines shall not be allowed; High-level noise generating work shall be performed within the working hours (9:OOh. - 17:00h.), and in the vicinity of medical facilities and kindergartens the noise-generating activities shall be interrupted between 14:OOh and 16:OOh.; All noise not relating to the construction shall be avoided as far as possible.

- -- Ornon~tConsult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; faxy0>/980-b4-68 2 Environment Management Plan - investment Program of Water Supply LLC - Razgrad Annex 1

Dust control The Contractor shall follow all the existing laws and regulations concerning the dust control in construction works and auxiliary operations. The Contractor shall submit and follow measures to minimize environmental impacts, to control dust from the operation of equipment and construction, including, but nDt limited to: The Contractor shall submit and coordinate a plan indicating the proposed routes for aggregate material transport to the construction site The transport vehicles delivering aggregate material to the site shall be covered Water shall be sprinkled over the construction site during earth work The equipment shall be maintained in good repair, etc.

Deviation and Traffic Measures: Temporary Traffic Management Plan The applicable Bulgarian regulation requires from persons performing construction or repair works to undertake steps to design and apply a Temporary Traffic Management Plan (TTM). The TTM Plan shall be reviewed by the National Road Infrastructure Fund / the district road administration / the municipal administration, (depending on the claSs of road sector where construction is going on) as well as the control authorities of the Ministry of Internal Affairs minimum 15 days before the commencement of construction. The TTM Plan can be prepared in advance as part of the Investment Project and integrated with the Technical Specifications (the detailed engineering designs). Where the Plan is drawn up by the Contractor, the Engineer's approval shall be obtained within 28 days prior to the commencement of the construction, after which the approval of the above-mentioned institutions shall be sought. The Temporary Traffic Management Plan shall indicate the proposed plan of safe road traffic, including all construction details, temporary lighting and signing, etc., matching the work performance milestones. The Draft Plan shall cover the entire construction site and the access to it and shall include: an Explanatory Note; Layout of the road (street) sector; scope of the work sitd; a TTM diagram indicating: a) type and location of the lighting and signing with road marking, road signs, traffic lights, and other means of signalization in the work sector with the required elevations and dimensions; b) by-road diagram and its traffic signing and lighting, including access roads to individual properties; c) specification of the devices and materials needed for lighting and signing and TTM implementation. The Temporary Traffic Management Plan should also indicate the manner in which pedestrian traffic will be controlled where required. During construction works, the Contractor shall apply the TTM Plan, both during working hours and after that, including: Inspect the condition and maintain in good repair the planned lighting and signing (signs, traffic control devices, marking, etc. ), including night lighting, both during work and in the parts of the day when no work is going on; Co-ordinate maintenance of traffic operations with the Engineer and the Traffic Police; Review work areas, equipment operation and storage, and material handing and storage related to traffic safety; Prepare and submit to the Engineer for approval a program for adoption of precautions for work during the winter period, containing: proposed precautions prior to the onset of winter; and proposed maintenance of existing traffic thoroughfares within the Site of the Works during the winter period.

- Ornonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax: 02/980-p4-68 3 I Environment Management Plan - investment Program of Water Supply LLC - Razgrad Annex 1

. Adopt all precautions required for safe work in winter - limit the excavation work, inspect and maintain the pedestrian bridges, etc. Where a Temporary Traffic Management Plan is prepared in advance as part of the Investment Project, all activities related to its implementation will be known in advance before the date of submission of the construction performance proposals and their detailed inclusion in the Bill of Quantities will be possible. In the event that the Contractor will be in charge of preparation and implementation of the TTM Plan, it can be included in the Bill of Quantities only as general items.

Soil Erosion The Contractor, under the Engineer's supervision, shall adopt all reasonable measures for erosion control and prevention during construction.

Materials The Contractor shall use materials that are certified as complying to the substantial requirements with respect to construction activities and meet the Technical Specifications pursuant to the Requirements to Products Act. The materials shall be of an origin indicated in advance, established and meeting the normative requirements and shall be accompanied with relevant documents (statements of compliance, certificates of compliance, test reports, etc.), evidencing their conformity with the normative regulations. Aggregate materials for backfilling (sand, gravel, rubble) shall be supplied from licensed borrow pits, and the documents evidencing that shall be presented in advance. At the construction site, materials shall be kept in the designated locations to avoid possible pollution of soil, water courses, etc.

Protection of Water Resources and Soils The Contractor shall carry the full administrative and legal responsibility for any pollution of surface waters and soils according to the existing legislation, caused by its acts or acts of its employees. The Contractor shall ensure that no oil products, fuel, lubricants, detergents, paint or other harmful substances are introduced into the soil, streams and imgation or drainage facilities. The discharge of oil and fuel onto open soils is prohibited. Filling of any machinery shall be restricted to the nearest filling station. If filling has to be carried out on the construction site, that should be done solely using suitable devices. The Contractor shall submit in writing to the Engineer the locations of the installations related to the provision of water, fuel, construction mixes, drainage, etc., and the distances to the nearest water supply, imgation or draining facilities, particular green or protected areas. The above-said applies to both the construction site and the construction camp for the staff employed for performance of the work. Without overruling the water resource and soil protection requirements the Contractor shall submit to the Engineer an emergency action plan for hazardous spills and leakage, subject for approval before commencement of the works. The nearest existing toilets or chemical toilets shall be used in the construction sites or at the workers' camps. The direct discharge of sewage from worker's camps into any water basin is prohibited.

Health, Safety and Accidents

The Contractor shall undertake all steps required and relevant to labor safety for compliance with the Bulgarian legislation.

Omonit Consult LLC, 17 G, Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax: 02/980t04-68 4 Environment Management Plan - investment Program of Water Supply LLC - Razgrad Annex 1

The applicable Bulgarian legislation (Regulation No. 2 / 22.03.2004 on meeting the minimum requirements for healthy and safe labor conditions during construction and erection works) requires preparation of a Health and Safety Plan (HSF) for construction involving risks defined in the Regulation at the investment project phase, providing for all necessary construction management and performance measures guaranteeing its safe performance. According to the applicable regulation a SHF shall contain: 1. Or~anization Plan; 2. Layout Plan; 3. an Integrated project schedule of the sequence of Constmction and Erection Works (CEW); 4. Fire and accident prevention and fighting plans and plans for evacuation of the workers and persons present at the construction site; 5. Safety and health measures and requirements applied to performance of CEW, inclusive of specific-risk sites; 6. A list of plants, machines and facilities subject to control; 7. A list of the persons in charge (with names, positions, employer) of supervision and review of individual builders' plans concerning specific-risk sites, and of evacuation, drills andtor training; 8. diagram of the temporary traffic management and safety in the transport and evacuation routes and pedestrian catwalks and crossings on the construction site and access roads; 9. layout of the points on the construction site where two or more builders will work; 10. layout of the specific-risk points on the construction site; 11. layout of the points of erection, of lifting equipment and scaffolding; 12. layout of the points on of storage of building supplies and equipment, temporary site workshops and waste containers; 13. layout of the locations of staff rooms; 14. layout of the utilities; 15. plan and operation schedule of the temporary artificial lighting on the construction site and at work sites; 16. diagram and type of disaster, accident, fire or emergency alarm devices, with a site designed for first-aid provision. According to the same Regulation preparation of the SHF for the investment design phase shall be assigned by the Employer or a person authorized by it to the Designer or to the HSLC OfficerICoordinator and submitted to the construction Contractor before opening of the construction site. Provision, update review, or absence of a HSF plan does not relieve the Contractor of any responsibilities to ensure the safety and health of its employees, subcontractors or any other persons on the site, or of its obligations by force of the applicable Regulation pertaining to: Performance of risk assessment before start of the works on the construction site and till its completion. Development and updating of safety & health instructions depending on the specific conditions on the construction site by CEW types and in the cases required by the applicable legislation; The provision of protective clothing and equipment in accordance with the regulatory framework of Bulgaria and depending on the assessment of existing professional risks in every individual case; Provision of initial and regular instruction on healthy and safe labor conditions (HSLC) to the employees; Defining, in written job descriptions, the senior staffs (engineering managers, foremen, etc.) responsibilities as well as the responsibilities of persons in charge of risk elimination in the process of work, endowed with the powers and resources needed for that purpose; The provision of a qualified officer as HSLC Officer/Coordinator who has specific knowledge of safety regulations, and experience of safety precautions and who shall advise on all matters affecting the safety of workers, subcontractors and supervising officers. The provision of safety maintenance of the facilities and equipment (electrical and lifting equipment, building machines, transport vehicles, etc.) and their continuous

I Ornonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax: 02/980104-68 5 Environment Management Plan - investment Program of Water Supply LLC - Razgrad Annex 1

monitoring with a view to elimination of defects that might affect the employees' safety and health or the environment; The adherence to Bulgarian legislation on fire protection and preparation of a fire prevention and fighting plan subject to the Engineer's approval. The provision of latrines in conformity with the sanitary and hygiene requirements and fire and accident safety (FAS) requirements; The provision of instruction on handling of various materials, storage and disposal of used hazardous materials; The provision of collection, storage and transportation of waste and debris; The provision and maintenance of access to all points on the site in a safe condition free of injury risk; The provision of joint work of construction workers and free-lance employees, if any; The provision of collaboration with the industries in the region of or near the construction site; The provision of first-aid facilities for persons injured in an industrial accident, fire, disaster or incident; Adoption of extra measures for protection of persons working in the open in adverse weather conditions; Good order and cleanliness on the construction site; Provision of integration of the construction site into the environment, including appropriate sewerage, waste collection and disposal, etc., as required by law and in a manner satisfactory to the Engineer. This requirement applies also to auxiliary work sites, the construction camp, etc. Reporting of details on all accidents to the Engineer and, if needed, to the police. The safety officer/coordinator appointed by the Contractor shall have the power to receive instructions from the Engineer on matters relating to the health and safety of personnel on Site and the safe conduct of site operations. Considering the nature of the sites and the fact that when water supply mains are connected to existing water mains andlor facilities, the persons (the Contractor's employees) may come into direct contact with drinking water, a requirement can be set that such work may be performed solely by persons possessing personal health record book.

Common Heritage: Historical, Architectural and Archaeological The Bulgarian law defines obligations towards the persons involved in construction even in cases where it is conducted outside the boundaries and protection zones of immovable objects of common heritage. In the event of chance finds during construction that show some signs of cultural heritage objects, the work shall cease, and the Contractor shall immediately inform the Engineer, the municipal administration and the nearest museum of history. Initial measures for preservation of the find shall be adopted under the Engineer's and competent persons' guidance.

Social Issues The Contractor should adhere to the principles of corporate social responsibility in its interrelations with its staff, business partners and the local community. Beside the mitigation measures against the adverse impacts on the environment and population from and during the Project performance, the Contractor shall meet the following requirements:

Omonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax: 02/980+04-68 6 Environment Management Plan - investment Program of Water Supply LLC - Razgrad Annex I

- - The Contractor will apply, at any time, all required precautions against breaches of the law and violations of the social order and morality by or among the Contractor's staff. The operations conducted shall be adapted to the uninterrupted operating mode of the water supply system Scheduled interruptions of water supply shall be conducted after notification of the residents concerned. Alternative water supply shall be provided upon water supply interruptions lasting longer than the one instructed by the Operator of the W&S system.

Supervision and Monitoring Without relieving the Contractor of its obligation for permanent compliance control, the Engineer will be in charge of the monitoring and verification of compliance of the overall construction work with the Environmental Impact Mitigation Plan and of making sure that there are no deviations from it or from the Contract.

Payment

All costs associated with environmental protection will be considered as being covered by the overall payments specified in the Construction Contract. All costs entailed in sampling and testing for environmental purposes shall be deemed to be included in the prices and rates entered by the Contractor in the Bill of Quantities.

Ornonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax: 02/98q-04-68 7 Environment Management Plan - Investment Program of Water Supply DUNAV SPLLC - Razgrad - Annex 2

Annex 2. Environmental Impact Mitigation Program for the Construction Phase

Place and time Implementation Control functions Impact due to: Impact Mitigation Measure of Person in Charge Funds performed by: performance 1 2 3 4 5 6

Site Clearing The construction debris from asphalt, pavement, sidewalk At the As per bills of The Contractor MRDPW (The Engineer*), paving stone, etc. removed during reconstruction of the construction quantities, construction supervision and street water mains and branch-offs to local building water site, initial phase actually proven representative of the piping shall be disposed of at the indicated sites in and after quantities at municipal administration conformity with the local regulations and permits. After construction prices accepted and RIEW completion of construction the paving is restored to its initial completion by contract. condition. Destruction of ligneous and fruticose vegetation shall be minimized and done after agreement with the competent authority.. a) Noise disturbance including The machines and plants used shall be maintained in good At the Included in the The Contractor The Engineer, RIPQPH vibrations repair and meet the noise limits set in Bulgaria. The exhaust construction cost of mandatory pipes of the transport and building equipment shall be fitted site, maintenance. The with mufflers. Construction work time shall be restricted permanently. minimum for from 7.00 a.m. till 7.00 p.m. near homes. Repairs performed extra measures. in the regions of medical facilities, sanatoria, kindergartens (where the daytime noise limit is 45 dB(A), shall cease all noise generating works between 2,00 and 4,00 p.m. when the residents are resting. Idle ruilning of transport and construction equipment shall not be allowed. The workers shall be supplied with ear muffs. b) Dust pollution/Air quality Earth works, temporary and by-roads shall be sprinkled with At the The minimum The Contractor The Engineer water to prevent dust pollution; the trucks canying fine construction materials such as sand and fine aggregate shall be covered to site, reduce their scattering on the way. permanently c) Trafic disturbai7ce during Prepare and apply a Temporary Traffic Management Plan At the The minimum The Contractor The Engineer, District Road

~ ~ constructioi7 works through appropriate measures and a clearly visible and easy construction Administration / Municipal to follow sign and light system for traffic redirection, site, administration, Traffic coordinated with the respective institutions in conformity permanently Police with the prevailing normative system. No-excavation technology shall be applied wherever possible. Excavation-free technology shall be applied wherever

Ornonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/980-04-68 1 Environment Management Plan - lnvestment Program of Water Supply DUNAV SPLLC - Razgrad - Annex 2

possible. d) Transport andpedestrian Prepare and apply a plan for temporary traffic organization At the The minimum The Contractor The Engineer safety with/without ongoing with appropriate fencing, lights and clear safety signs. construction construction work Preparation and application of a safety and health plan. site, permanently e) Soil erosion Control of soil erosion by means of battering, draining, and At the The minimum The Contractor The Engineer other means. construction site, permanently 8 Aggregate material borrow Use only licensed borrow pits; undertake preventive At the No extra funds The Contractor The Engineer pits measures against in-transport material spilling; all vehicles construction required. shall be covered to avoid spilling on the way from the site, borrow pits. permanently g) Water andsoilpollrrtion due Define places for material storage; isolate the concrete work At the The minimum, The Contractor The Engineer to improper storage, sites from water basins; the areas for washing building and construction included in the management and use of other equipment shall be isolated from water basins and sites site, funds for materials in places that do not drain into water basins directly or permanently construction site indirectly. organization. h) Water andsoilpollution due The wastes shall be deposited in designated places protected At the As per bills of The Contractor The Engineer to improper waste disposal from washing away, indicated by the authorized bodies. In construction quantities, the event that hazardous wastes, including asbestos- site, actually proven containing materials, are generated, contract a firm permanently quantities at possessing a license for their treatment prices accepted After flushing and disinfection of newly built water mains by contract. and facilities, neutralize the solution and release it in the designated places - public sewerage, or another basin. Existing or chemical toilets shall be used for sewer effluent. In the event of generation of hazardous wastes, contract a firm possessing a license for their treatment. i) Potential water and soil Use the nearest motor depot for fuels and lubricants. At the No extra funds The Contractor The Engineer pollution due to improper use of No waste oil from the machines /dredgers,etc.l shall be construction required. the building equipment released in the public sewerage, in gutters, rivers or any site, other places not indicated in the permits permanently j) Airpolllrtion due to improper The machines and plants used shall be maintained in good At the No extra funds The Contractor The Engineer

--~.urfenanceofthe equipment ~ ~ - iechieal condition. - construction required. Idle running of transport and construction equipment shall site, not be allowed.. permanently k) Labor safety Follow the safety and health plan; provide briefings daily At the The minimum The Contractor The Engineer and at regular intervals as required by the regulations; use construction

Ornonit Consult LLC, 17 G. Genkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/980-04-68 2 Environment Management Plan - Investment Program of Water Supply DUNAV SPLLC - Razgrad - Annex 2

personal protection means; safe organization of by-pass site, traff~c. permanently I) Common heritage All archaeological finds discovered during the works shall On the The Contractor The Engineer, the Ministry be treated in conformity with Bulgarian laws. Upon finding construction of Culture of archaeological objects the Contractor shall promptly site - upon inform the Engineer, the municipal administration and the discovery of nearest museum having taken measures for preservation of archaeological the find and following the competent bodies' instructions. finds m) Possible air, water andsoil Domestic solid waste shall be collected in containers and At the The minimum The Contractor The Engineer and pollution at the workers' taken to the nearest landfill. construction RlEW cot~structioncamp Existing or chemical toilets shall be used for sewage camp site effluent. Ensure proper handling of lubricants and solvents through safe storage.

2.1. During the Operation Phase

Place and time Implementation Control functions Impact due to: Impact Mitigation Measure Person in Charge of performance Funds performed by: 1 2 3 4 5 6 Accident and Emergency Action Plan On work sites, By the Operator Operator Municipality 'c)Force Majeure events and upon contingencies occurrence of I I an event I The investment program of Water Supply DUNAV SPLLC - Razgrad does not include construction of a PWPP

* Everywhere in this text Engineer means Consultant Engineer or any other expert who is appointed by the Employer and performs site supervision.

Ornonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/980-04-68 3 Environment Management Plan - Investment Program of Water Supply DUNAV SPLLC- Razgrad - Annex 3

Annex 3: Monitoring Program for the Construction Phase

Where shall the What parameter shall be monitored ?

prevailing report regulations b) Dust pollution/Air Air pollution At and near the work Inspection and First check At prices of the The Contractor, the quality places measurement by an - at the start of accredited Engineer, RIPQPH, accredited laboratory construction; laboratory and IAE, RIEW and the with the respective - sudden; at express check municipalities apparatus pursuant to - at reg.intervals, prices prevailing pursuant to regulations regulations c) Traffic disturbance Availability and At and near the work Inspection, Before works Included upon during construction application of a site within the scope of observation start; project The Contractor; the works Temporary Traffic the Temporary Traffic - permanently performance Engineer,RTC and the Organization (TTO) Organization (TTO) - at intervals costing for TTO municipalities Plan; traffic schemes Plan d) Transport and Visibility and At and near the work Observation - continuously Included upon The Contractor; the pedestrian safety appropriate methods site - at reg.intervals project Engineer,RTC and the with/without ongoing performance municipalities construction work costing for TTO e) Soil erosion Turbidity On the work site Observation Continuously No extra funds The Contractor, the . ~- - - ~~- ~ ~ required Engineer fi Aggregate borrow Possession of valid Sand, rubble and rock Inspection and Before works No extra funds The Contractor; the pits license for operation and borrow pits document control start; during required Engineer origin of the aggregate performance, upon used placing of Environment Management Plan - Investment Program of Water Supply DUNAV SPLLC- Razgrad - Annex 3

materials g ) Water andsoil Water and soil quality Effluent from site, Observation; -Continuously -The Contractor; pollution due to for presence of material storage sites; Inspection; -At reg.intervals - Engineer, IAE and improper storage, suspended substances, equipment washing Check - sample -Upon RIEW management and use of oils, pH value collection precipitation (rain, - At prices of -The Contractor materials snow etc.) and the accredited incident laboratory h) Water and soil Water and soil quality The construction site Observation; -Continuously -No extra funds -The Contractor; pollution due to for presence of and service roads required improper waste suspended substances, Inspection -At reg.intervals -The Engineer, RIEW disposal oils, pH value At least monthly and municipalities and upon report i) Potential water and Water and soil quality The construction site Observation; -Continuously -No extra funds -The Contractor, soil pollution due to for presence of and service roads required improper use ofthe suspended substances, Inspection -At reg.intervals - The Engineer and the building equipment oils, pH value sudden check At least monthly municipalities and upon report j) Airpollution due to Exhaust gases, dust The construction site Observation; -No extra funds -The Contractor, improper maintenance During work required ofthe equipment Inspection The Engineer, RIPQPH, IAE, RIEW and the municipalities k) Labor safety Availability of personal The construction site Inspection sudden checks -No extra funds The Contractor, the protection means; during work required Engineer, RIPQPH, instruction books; Health and Labor Inspectorate and safety checks I) Common heritage Architectural, The construction site Observation Upon discovery -No extra funds The Contractor, the archaeological and required Engineer, NICH and historical common Inst. of Archaeology heritage with Museum m) Overall conditions Cleanliness, collection At the construction Sudden check As per prevailing -No extra funds The Contractor, the at the workers' and removal of domestic camp regulations and required Engineer, RIPQPH, construction camp solid waste, effluent procedures W&S treatment

* Everywhere in this text Engineer means Consultant Engineer or any other expert who is appointed by the Employer and performs site supervision Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

Appendix A

Regulation Acts Applicable to the Proiect

1. Water Act. Adapts the European Framework Directive on Water to the conditions in Bulgaria; 2. Structure of the Territory Act - regulates the public relations related to structure of territories, investment planning and civil works in the Republic of Bulgaria; 3. Environmental Protection Act - This act regulates the public relations in the area of: protection of the environment for the present and future generations and protection of people's health; preservation of the biological diversity in harmony with the natural biological and geographical characteristics of the country; protection and use of environmental components; control and management of the factors harmful to the environment; exercising of control on environment condition and pollution sources; pollution prevention and restriction; establishment and functioning of the National Environment Monitoring System; the environmental protection strategies, programs and plans; collection and access to information on the environment; economic organization of environmental protection activities; environmental protection rights and obligations of the State, the Municipalities, legal and physical persons; 4. Health Act. This act regulates the public relations related to protection of the citizens' health; 5. Waste Management Act. This act regulates waste management with consideration of the environment as a combination of rights and obligations, decisions, acts and activities, related to their generation and treatment as well as the forms of control over these activities. This act sets the requirements with respect to products forming hazardous or widespread wastes in the process of their generation or after their final use; 6. Biological Diversity Act. This act regulates the relations between the State, the Municipalities, legal and physical persons with respect to protection and sustainable use of the biological diversity; 7. Protected Areas Act. Regulates the categories of protected areas, their purpose and regime of protection, use, restoration and management including permitted and prohibited activities in the individual categories; 8. Monuments of Culture and Museums Act - regulates finding, protection and popularization of the monuments of culture located in the territory of the Republic of Bulgaria; 9. Air Purity Act. The act regulates the methods of determining the air quality indicators and limits, emission restriction, rights and obligations of the respective regulating authorities, management and preservation of fiee air quality. The act regulates the restriction of noxious emissions from fixed and mobile sources; 10. Environmental Noise Protection Act. This act regulates the assessment, management and control of noise in the environment caused by motor, railway, air and water transport as well as industrial plants and facilities and by local noise sources ...; 11. Water Supply and Sewerage Services Regulation Act. This act provides for price regulation, affordability and quality of water supply and sewerage services provided by water supply and sewerage (W&S) operators; 1 2. MH, MRDP W and MoE W Regulation No. 9/16.03.2001. on the Quality of Potable and Washing Water. W&S operators carry out, or assign to accredited laboratories the continuous and periodic monitoring of the quality of water supplied to consumers by physico-chemical, microbiological and radiological indicators; Ornon~tConsult LLC, 17 G. Benkovsk~Street, Sof~a1000 phone.:02/980-21-16; fax:02/980-04-68 1 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

13. MoE W Regulation No 5/08.11.2000 on the Procedure and Method of Establishing the Networks and Activity of the National Water Monitoring System. This Regulation establishes Procedure and manner of establishing water monitoring networks and regulates the activity of the National Water Monitoring Agency in the territory of the Republic of Bulgaria; 14. Regulation No.7 on air quality assessment and management. This Regulation establishes the terms, procedure and manner of assessment and management of free air quality by provisions for: conduct of the state policy of free air quality assessment and management, including improvement of free air quality in the regions where the established limits have been exceeded, and its maintenance in the other regions; credible, representative, timely and precise assessment of free air quality in the country's territory performed by the observation and monitoring systems... ; 15. Regulation No. 2 / 22.03.2004 on the Minimum Labor Health and Safety Requirements for Construction and Erection Works This Regulation defines the minimum of requirements applicable to provision of healthy and safe labor conditions at temporary and mobile construction sites; 16. Regulation No. 15 / 2 7.06.2006 on the sanitary requirements with respect to persons working at child-care facilities, specialized institutions for children and old people, water supply facilities, food production or trade enterprises, barber's shops, hair- dresser's and beauty parlors. This Regulation defines the sanitary requirements with respect to persons working at: . . ., water supply facilities and stations - pump and water treatment stations, reservoirs, chlorinating plants, water supply networks (that applies to the persons who are in direct contact with the potable water during repairs and emergency action) and sanitary protection zones of the water sources; 17. Regulation No.5 / 15.04.2003 on prevention and reduction pollution of the environment with asbestos. This Regulation defines requirements applicable to the prevention and reduction of pollution of the environment with asbestos for the purpose of environmental and human health protection; 18. Regulation No.9/04.08.2006 on protection of the workers against risks related to asbestos exposure during work. This Regulation defines requirements applicable to protection of workers' health, including prevention of existing or potential risks of asbestos exposure in the process of work; 19. Regulation No.16 / 23.07.2001 on temporary trafflc management in cases of construction and repair works on roads and streets. This Regulation defines the terms, procedure and means of signalization in cases of temporary traffic management in the process of construction and repair works on roads and streets; 20. Regulation on the Terms and Procedure of Performance of Environmental Impact Assessments. This Regulation defines the terms and procedure of investment proposal environmental impact assessment; 21. Regulation No.26 122.10.1996) on Recultivation of Disturbed Lands, Amelioration of Low-Productive Lands and Utilization of the Humus Layer. Defines the humus layer treatment during construction works on agricultural land; 22. Regulation No. 3 on the permissible limits for noxious substance concentration in soils. This Regulation sets the permissible concentration limits for noxious substances in soils; 23. Regulation No. 6 /26.06.2006 on Environmental Noise Indicators determining the discomfort degree during diffrent parts of the day, limit values of the ~nvironkental Noise Indicators, methods of assessment of the noise indicator levels and harmful effects of noise on the population's health; 24. Council of Ministers Decree 131/2000 Regulation on the requirements towards treatment and transportation of waste oils and oil produces. The Decree defines the requirements towards collection, temporary storage, transportation, utilization and sequestration of waste oils. Omon~tConsult LLC, 17 G. Benkovski Street, Sof~a1000 phone.:02/980-21-16; fax:02/9E/0-04-68 2 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

APPENDIX B

ABBREVIATIONS USED

1. AIM - Archaeological Institute with Museum 2. SWSN - Street Water Supply Network 3. TTM - Temporary traffic management 4. TWWTP - Town waste water treatment plant 5. EU - the European Union 6. HSLC - Healthy and safe labor conditions 7. IAE - Implementation Agency for Environment 8. TP - Traffic Police 9. MRDPW - Ministry of Regional Development and Public Works 10. MoEW - Ministry of Environment and Water 1 1. MIA - Ministry of Interior Affairs 12. MV - Motor vehicles 13. NICH - National Institute of Cultural Heritage 14. NGO - Non-government Organizations B 5. PWPP - Potable water purification plant 16. HDPE - High-density polyethylene 17. PCL - pennissible concentration limits 18. SHP - Safety and Health Plan 19. FAS - fire and accident safety 20. EMP - Environment Management Plan 2 1. RIEW - Regional Inspectorate of Environment and Water 22. RIPQPH- Regional Inspectorate for Protection and Quality of Public Health 23. CEW - Construction and erection works 24. PBB - Piping branch-offs to buildings

Ornonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/980-04-68 Environment Management Plan - an Investment Program of Vodosnabdyavane Dunav SPLLC - Razgrad

RAZGRAD MUNICIPALITY

RECONSTRUCTION OF WATER MAINS AND BRANCHES TO BUILDINGS IN THE TOWN OF RAZGRAD

Map of Razgrad presenting the zones in which reconstruction of the water supply network will be carried out

Omonit Consult LLC, 17 G. Benkovski Street, Sofia 1000 phone.:02/980-21-16; fax:02/980-04-68