Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste
Reference No.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2
Updated ESIA and EMP for Bijela Shipyard
July 2016
A project implemented by AMBIENTE S.C. (Italy) in Joint Venture with DBA Progetti S.p.A. (Italy), MEDIX Ltd. (Montenegro) and Smart Environmental Solutions (SES) (Montenegro) Updated ESIA and EMP for Bijela Shipyard
Document Control Sheet
Client: Environmental Protection Agency (EPA)
Project: Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste
Reference No.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2
Title of the Report: Updated ESIA and EMP for Bijela Shipyard –25 July 2016
Contractor: AMBIENTE S.C. DBA Progetti S.p.A.
Via Frassina, 21 – 5 MEDIX Ltd.
4033 Carrara (MS) - Italy Smart Environmental Solutions (SES)
Prepared by Quality Check by Approved by Mr. Franco ROCCHI Project Manager (EPA)
Team Leader Ms. Sara TONLORENZI and Ms. Inés Sanchez Ms. Cristina LAZARO Quality Control Expert and Project Manager Supporting Environmental Signature Mr. Nicola BERTOLINI Team Contract Manager
Date 25th July 2016 25th July 2016
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 2 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
Table of contents
1 Executive Summary ...... 5 2 Policy, legal, and administrative framework ...... 8 2.1 Montenegrin regulations ...... 8 2.2 Directives and regulations of the European Union in the field of waste management ...... 9 2.3 World Bank Policies and Guidelines ...... 11 3 Project description ...... 13 3.1 Location ...... 13 3.2 Remediation of Shipyard Bijela Contaminated site ...... 14 4 Baseline data - current situation of the Environment ...... 19 4.1 Description of the site and surroundings ...... 19 4.2 Flora, fauna and natural resources ...... 19 4.3 Cultural assets ...... 19 4.4 Climate ...... 19 4.5 Previous investigations...... 19 4.5.1. Additional investigation by CDM ...... 20 4.5.2. Additional investigations by CETI, considered by Tauw & Witteveen+Bos ...... 22 4.5.3. "Zero" state investigation by CETI ...... 22 4.6 Potential risk and design parameter ...... 23 4.7 General characterization of the waste body ...... 23 4.8 Social Economic baseline ...... 23 4.8.1. General information ...... 23 4.8.2. Potential for employment ...... 24 5 Environmental impacts ...... 25 5.1 Impact assessment of the current situation and possible mitigation measures ...... 25 6 Analysis of alternatives ...... 28 7 Environmental management plan (EMP)...... 31 7.1 Environmental Mitigation Plan ...... 32 7.2 Environmental Monitoring Plan ...... 38 8 Appendixes ...... 42 8.1 List of report preparers – the Joint Venture (Consultant) ...... 43 8.2 References – list of written materials and study visit report used in study preparation ...... 44 8.2.1 Policy, legal, and administrative framework ...... 44 8.2.2 Plans, programs, studies and projects ...... 45 8.2.3 Consultant’s Site visit on 1st July 2016 ...... 46 8.3 Public consultation – Minutes ...... 48
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Updated ESIA and EMP for Bijela Shipyard
List of Abbreviations
European Agreement concerning the International Carriage of ADR Dangerous Goods by Road CEMP Construction Environmental Management Plan CETI Center for Eco-Toxicological Research Podgorica I.l.c. EIA Environmental Impact Assessment EMP Environmental Management Plan EPA Environmental Protection Agency ESIA Environmental and Social Impact Assessment EU European Union IWMCP Industrial Waste Management and Clean-up Project JV Joint Venture LNAPL Light Non-Aqueous Phase Liquid MSDT Ministry of Sustainable Development and Tourism MCDA Multi Criteria Decision Analysis SES Smart Environmental Solutions TBT Tributyltin ToR Terms of References WB World Bank
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Updated ESIA and EMP for Bijela Shipyard
1 Executive Summary
The Government of Montenegro has obtained a loan (Loan No. IBRD 8428) from The World Bank for the ‘Industrial Waste Management and Clean-up Project’ to remediate five selected industrial waste disposal sites and to manage the ongoing disposal of industrial hazardous waste. The development objective of the IWMCP is to reduce contamination of Montenegro’s natural resources and public health risks of exposure to this contamination from selected industrial waste disposal sites. The IWMCP will achieve its objective through:
1. The development and implementation of a remediation investment program for selected legacy industrial waste disposal sites, and
2. Related to these interventions, supporting institutions and related industries in bringing the management of industrial hazardous waste in compliance with Montenegrin legislation.
The Ministry of Sustainable Development and Tourism of Montenegro and Environmental Protection Agency of Montenegro (EPA), in June 2012, published Environmental and Social Impact Assessment study (ESIA) for remediation of 5 locations for waste disposal, that were selected for remediation within IWMCP, with one of them being waste blasting grit dumpsite in Adriatic Shipyard Bijela.
The objective of the ESIA was to reduce the environmental and health risks posed by the selected industrial waste disposal sites, and to strengthen local institutional capacity for regulation and management of industrial and hazardous waste. Project implementation was expected to be financially supported by the WB, hence the ESIA was prepared and public consultations conducted in accordance with WB guidelines.
The main outcome of such preparatory assignment are the technical parts of the bidding documents for the execution of the project ‘Remediation works in Bijela shipyard’ (Project Reference No. MNE-IWMCP-8428-ICB-W-15-1.3.5), Such technical documentation included an update to the ESIA and Environmental Management Plan (EMP) that has originally been produced on behalf of the EPA.
The final scenario for the remediation works chosen in the preparatory assignment above consists on the ‘Export with the obligation to treat a certain amount of grit on-site’ (a combination of Scenario 1 (export of grit wastes) and Scenario 3 (application of grit wastes on-site)).
The Government of Montenegro used as well part of the proceeds of the loan towards the present consultancy assignment for ‘Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard ‘Bijela’ contaminated soil and blasting grit waste’ (Project Reference No. MNE-IWMCP-8428-CQ-CS-16-1.3.6.2). This assignment is implemented by the company AMBIENTE S.C. (Italy) in Joint Venture (JV) with the company with DBA Progetti S.p.A. (Italy), MEDIX Ltd. (Montenegro) and Smart Environmental Solutions (SES) (Montenegro), hereafter called the Consultant.
This report presents the final ESIA and EMP in accordance to WB’s requirements (Operational and Safeguard Policies OP/BP 4.01 on Environmental Assessment), prior to the start of the remediation works, being an update to the ESIA and EMP carried out previously by a third party (consultants). It is foreseen that an additional EIA following the Montenegrin guidelines and acceptable to the World Bank will be carried out by the Contractor.
The present document provides the background to the proposed projects as well as an assessment of their likely environmental and social impacts, both beneficial and adverse. Proposed enhancement and mitigation measures are outlined where necessary together with an initial assessment of responsibilities for their implementation.
The main objectives of the ESIA are to:
Identify and assess the anticipated environmental and social impacts of the proposed projects – both positive and negative; Identify and analyse alternatives to the proposed projects;
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Updated ESIA and EMP for Bijela Shipyard
Propose mitigation measures for negative impacts and enhancement measures for positive impacts to be undertaken during and after the implementation of the proposed project; Verify compliance with national environmental regulations and policies, World Bank Safeguard Policies, and industry best practice and standards; Generate baseline data for monitoring and evaluation of how well the mitigation measures have been implemented during the project life cycle; Recommend effective measures to be used to mitigate against the anticipated negative impacts; EMP; Prepare an EIA Report.
As already mentioned, the Contractor, as part of the present assignment, will prepare an EIA following the Montenegrin guidelines and acceptable to the World Bank.
The scope of these remediation works includes the following: All old blasting grit wastes stored in piles A, B, C All new blasting grit wastes stored in piles D, E All subsurface materials in the derelict dumping area that contain > 50 % blasting grit waste All blasting grit wastes and contaminated topsoil present in the depot areas and remediation site till a maximum depth of 0.15 cm All soil in the derelict dumping area and its direct vicinity that contains petroleum hydrocarbons above 5,000 mg/kg d.w.
Excluded from the remediation scope is any blasting grit waste that is present on the sea floor,outside of the depots and working areas of the remediation, sea sediments that contain blasting grit, as well as blasting grit wastes present in the subsurface (more than 10 cm below site surface) of the site outside the derelict dumping area. These grit wastes have been insufficiently investigated to design remedial actions.
The remediation scope for the groundwater is confined to measures needed for the excavation of the contaminated soil and blasting grit wastes from the derelict dumping area.
The areas outside of the derelict dumping area have not been investigated in sufficient detail to include in the current remediation scope. The same applies for the groundwater contamination situation and the sea floor sediments. These areas are excluded from the scope of the remediation works.
After finalization of the remediation all hazardous blasting grit wastes and severely contaminated soil from the derelict dumping area have been removed from the site and transported to a facility for destruction, processing or re- use. The remediated areas of the shipyard have been cleared from all above ground hazardous wastes and the area is made suitable for continued industrial use.
In the present situation, the contaminated dump site at Bijela Shipyard has several adverse impacts on the environment and on the social-economic environment. The objective of the remediation is to limit the adverse impact by implementing various mitigating measures including noise, increased traffic or dust related to the construction works during implementation of the remediation.
The remediation will have a significant positive impact on the environment; however during the implementation of the remediation some short-term minor negative impacts might be expected. The main environmental impacts from the dumpsite before and after the implementation of the remediation works are summarized below:
1. Soil - Exposure of humans and animals to contaminated soil and grit by direct contact (surface soil) pose a significant negate impact. The contaminated soil and grit material should be removed. The mitigation measure will have a positive impact by preventing risk for direct human contact.
2. Dust - Exposure of humans and animals to contaminated dust, wind erosion of surface particles pose a significant negate impact. The contaminated soil and grit material should be removed. The mitigation measure will have a positive impact with no future contaminated dust from the dump site.
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Updated ESIA and EMP for Bijela Shipyard
3. Groundwater - The groundwater flow is expected to be towards the sea and the contamination might spread to the sea, while the groundwater is not used for drinking water. The contamination might spread to the sea with a negative impact. With the removal of the contaminated soil, the expected LNAPL and part of the contaminated groundwater will have a positive impact on the environment, although it is expected the groundwater to remain contaminated even after the remediation.
The Monitoring Plan during all the remediation phases includes, among others:
Air: Dust, smell and PM10, Hydrocarbons and PAHs with appropriate licensed monitors and/or samplers and implemented by accredited laboratories inside the construction site and outside in downstream wind direction and settlements.
Waste: permanent on site monitoring of all types of waste and their handover to an authorized collector.
Soil and groundwater: check quality of topsoil within remediation area after remediation (control) once by taking samples in a raster of 20 x 20 m within the remediation area. At least the following parameters should be analyzed: TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total polyaromatic hydrocarbons (PAH), total hydrocarbons and mercury
Seawater: control spreading of contamination once (after completion of the remediation works) by collecting three samples of sea water in front of remediation area, at least following parameters should be analysed: TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total polyaromatic hydrocarbons (PAH), total hydrocarbons and mercury.
Sediments: control of sediment quality in East Pier area after works once by collecting 10 samples of the seafloor and at least the following parameters should be analysed: TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total polyaromatic hydrocarbons (PAH), total hydrocarbons and mercury.
The Monitoring Plan specific after the completion of remediation works includes, among others:
Ecosystems: risk assessment of any residual contamination to be conducted once per year on site and in surrounding area.
Monitoring wells: water quality in wells on permanent basis for the next two years.
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Updated ESIA and EMP for Bijela Shipyard
2 Policy, legal, and administrative framework
2.1 Montenegrin regulations Export of the grit waste and contaminated soil is governed by national and international legislation. The main Montenegrin legislation is the Law on waste management, ("Off. gazette of Montenegro", no. 64/11), accompanied by a set of bylaws, including at least:
Rule book on detailed content of documentation to be submitted when applying for waste import/transit/export License, and list of waste classification ("Official Gazette of Montenegro", no. 71/10)
Rule book on keeping records of the waste and content of the document for waste transportation ("Official Gazette of Montenegro", no. 50/12)
Law on transportation of hazardous materials ("Official Gazette of Montenegro", no. 33/14)
Law on sea protection from pollution caused by vessels ("Official Gazette of Montenegro", no. 20/11 and 26/11)
Law on maritime safety ("Official Gazette of Montenegro", no. 62/13)
Law on Spatial Planning and Construction ("Official Gazette of Montenegro", no. 51/08, 34/11, 40/11, 47/11, 35/13, 39/13 and 33/14)
Environmental Protection Law ("Official Gazette of Montenegro", no. 48/08, 40/10, 40/11 and 62/13),
Regulation on method of preparation, scale and detailed contents of the technical documentation ("Official Gazette of Montenegro", no. 23/14)
Regulation on detailed content and manner of drawing up a waste management plan by waste producers ("Official Gazette of Montenegro", no. 5/13)
Regulation on packaging and removal of asbestos-containing waste ("Official Gazette of Montenegro", no. 11/13)
Regulation on waste classification and Waste Catalogue ("Official Gazette of Montenegro", no. 59/13)
Rulebook on construction waste management, manner and method of construction waste treatment, conditions and manners of disposal of cement asbestos construction waste ("Official Gazette of Montenegro", no. 50/12)
Law on Occupational Health and Safety ("Official Gazette of Montenegro", no. 34/14) The waste management plan as developed by the shipyard (October 2014) defines the shipyard’s plan and method for adequate removal of waste that is generated in the course of production activities of the shipyard; i.e. hazardous and municipal wastes. The aforementioned plan of the shipyard has been approved by the Agency for Environmental Protection (02 No. UPI-164/04 of 20/11/2014).
The selected to manage and perform the remediation workshas to verify with the authorities to what extent this existing waste management plan can be used for the activities envisaged in these Technical Specifications. Depending on the outcome, the contractor will either update the existing waste management plan or develop a new waste management plan that complies with Montenegrin legislation. The Contractor is to apply with this plan within 60 days prior to the procedure or activity that results in waste generation.
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Updated ESIA and EMP for Bijela Shipyard
National permits, notifications and/or certifications:
The Contractor selected to manage and perform the remediation works, including export of the grit and contaminated soil from Shipyard Bijela, needs to be listed within the Registry of collectors/transporters of the waste, and needs to apply for and obtain a License for export of the grit waste and contaminated soil. Both Registry and License for export are managed by EPA Montenegro.
If the selected Contractor is not already listed within the Registry of collectors/transporters of the waste, it need to apply for registration by submitting the following documents:
1. Full applicant details (name/title and address)
2. Specification of waste types to be collected or transported, including basic chemical composition and characteristics of the waste
3. Location where collection/transport of the waste will take place
4. Location and methods of waste storage
5. Method and type of transportation
6. Technical and organizational capacities
Along with these documents, the Contractor needs to obtain the consent of the local government of the municipality in whose territory collection and transport take place, which is the Municipality of Herceg Novi.
The law on the of Environmental Impact Assessment ("Official Gazette of Republic of Montenegro", no. 80/05, "Official Gazette of Montenegro", no. 40/10, 73/10, 40/11, 27/13)
This law is fully in line with European Union (EU) guidelines, which define / determine this area.
The law regulates the impact assessment procedure for projects that may have a significant impact on the environment, the content of an environmental impact assessment, participation of authorities and organizations and the public, the process of assessment and approvals, notification of projects that may have a significant impact on the environment of another state, supervision and other issues of importance for the assessment of environmental impact.
This law for the assessment of environmental impacts determines, in each individual case, the direct and indirect impacts of the planned project on the lives and health of people, land, water, air, climate and landscape, as well as material goods and cultural heritage.
The subject of the EIA, according to the provisions of the Act, are projects planned and carried out that may significantly affect the environment or human health, in the field of industry, mining, energy, transport, tourism, agriculture, forestry, water management and public utilities, as well as projects planned in protected areas and in protected surroundings of immovable cultural property.
2.2 Directives and regulations of the European Union in the field of waste management European directives or regulations containing deadlines (transitional periods) and general tasks, with which Member States must comply. Each member country can decide, depending on their starting status, to adapt these tasks and make them more concrete.
Directive 2008/98/EC on waste
This Directive establishes a system for coordinated waste management in the EU in order to limit the production of waste. The Waste Framework Directive Member States are obliged to make a plan for waste management. The new Waste Framework Directive 2008/98/EC provides certain definitions (different in comparison to Directive 2006/12/EC):
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introduces new terms: bio waste, waste oil, dealer, collection, separate collection, treatment, best available techniques (BAT), etc;
sets targets for recycling and utilization remained the same - until 2020 to reach 50% of the total amount of collected municipal waste and 70% other non-hazardous waste;
use of waste energy is not specifically defined in the general conditions of the Directive, except Annex II - list of possible activities efficiency;
observance of the principle of waste management hierarchy;
in Annex I of the Directive lists the acceptable options for disposal;
prescribes certain minimum standards that must be met during the application of various methods of waste treatment.
This Directive generally aims to bring rules to protect human health and the environment from harmful effects of the collection, transport, treatment, storage and removal of waste. Each rule for removal of waste must be an essential objective for the protection of human health and the environment from the impact of subsequent collection, transport, treatment, storage and disposal.
Preparation of waste and re-use of materials obtained should be targeted the interest of maintenance of natural resources.Groups of waste are defined in the Q1-Q16.
"Waste producer": means anyone whose activities produce waste (original waste producer) or anyone who carries out pre-processing, mixing or other operations resulting in a change in the nature or composition of this waste.
"Waste management": means the collection, transport, recovery and disposal of waste, including the supervision of such operations and the after-care of disposal sites, and including actions taken as a dealer or broker.
By returning the defined procedures are given by D1-D15 of this Directive.
The Directive defines the utilization of waste materials from the procedures defined by R1-R13.
The costs of waste disposal should be borne by the owners who make available their waste collection companies, and/or borne by the previous owners or the manufacturers of the product from which the waste originates.
Directive 91/689/EEC on hazardous waste (as amended by Directive 94/31/EC and Regulation (EC) 166/2006)
The Directive aims to the controlled disposal, utilization and disposal of hazardous waste properly. Member States shall ensure that the hazardous waste is registered, identified and re-mixed with each other or with the non- hazardous waste, even if there are already implemented measures to protect health and the environment.
All plants or companies that exploit or remove hazardous wastes, as well as manufacturers of such waste, must be regularly monitored; primarily origin and the removal of waste are monitored as well. Producers of hazardous substances and facilities or enterprises of such waste keep a register of all the procedures (transport, removal, or exploitation) and communicated to the competent services of the Member States concerned.
The competent authorities shall publish plans for economization of hazardous waste, and the Commission evaluates such plans.
Regulation (EC) No 1013/2006 on shipments of waste
The Regulation defines the monitoring and control of transboundary movements of waste. It introduced into European legislation the provisions of the Basel Convention. The Basel Convention is an international multilateral treaty governing the treatment standards or criteria for the management of waste in a manner compliant with the requirements of protection and improvement of the environment and procedures for dealing with cross-border movements of hazardous and other wastes. The Directive establishes:
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identification and notification system, as well as obligations to contracting and subcontracting for various operations in the transport of waste;
method of accreditation of interested parties in the proceedings;
method and conditions for shipping, transport and receiving;
manner of waste export to third countries;
obligations for the return of waste and its disposal in an acceptable way for the environment if the process of dispatch cannot be completed;
Member States shall take the necessary steps for the inspection, sampling and monitoring of waste in transboundary movement.
On international level, export operations must meet the requirements of the Basel Convention and the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) requirements. It is important to emphasize that Montenegrin legislation is harmonized with the Basel convention. The Contractor is responsible to ensure that the following permits, notifications and/or certifications are in place:
International permits, notifications and/or certifications:
The Contractor must obtain the appropriate permits and notifications for disposal and/or treatment of the grit wastes and contaminated soil including, upon completion of disposal and/or treatment, the approval of the relevant organizations and authorities that the final disposal of or treatment has been performed appropriately and in line with relevant legislation including EU legislation as well as with the Basel Convention. This includes at least the following:
An appropriate permit to transport the wastes over international waters (through international territory) in accordance with the Basel Convention. This transport permit/document includes transport from the Bijela shipyard through international waters to a port in the country where the wastes are accepted and will be adequately processed, and across land from the port to the facility of final treatment and/or disposal.
Certification of the facility, or facilities, performing the disposal or recovery of waste.
2.3 World Bank Policies and Guidelines The objectives of the WB’s environmental and social safeguard policies are to prevent and mitigate undue harm to people and their environment in the project development. These policies provide guidelines for WB and borrower staffs in the identification, preparation, and implementation of programs and projects.
The main document describing the World Bank Policy for environmental impact assessment is “Operational Policy/Bank Procedure (OP/BP) 4.01 Environmental Assessment”. The objective of the OP/BP 4.01 is to ensure the environmental and social soundness and sustainability of the investment project. In addition, the policy supports integration of environmental and social aspects of projects in the decision-making process. The OP/BP 4.01 Environmental Assessment consists of seven basic elements:
1. Screening 2. Environmental assessment (EA) documentation 3. Public consultation 4. Disclosure 5. Review and approval of EA documentation 6. Conditionality in loan agreements 7. Arrangements for supervision, monitoring, and reporting
The OP/BP 4.01 Environmental Assessment includes the following three annexes:
“Annex A: Definitions”
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“Annex B: Content of an Environmental Assessment Report for a Category A project”. This annex describes the items which should be included the EIA.
“Annex C: Environmental Management Plan”. This annex includes the set of mitigation, monitoring and institutional measures to be taken during implementation and operation of he project
In addition, the World Bank safeguards include the following relevant policies:
“OP/BP 4.04 Natural Habitat”. The objective is to promote environmentally sustainable development by supporting the protection, conservation, maintenance and rehabilitation of natural habitats and their functions.
“OP/BP 4.09 Physical Cultural Resources”. The objective is to assist in preserving physical, cultural resources and avoiding their destruction or damage. The Cultural resources include archaeological, paleontological, historical, architectural, religious, aesthetic or other cultural significance.
“OP/BP 4.12 Involuntary Resettlement”. The objective is to avoid or minimize involuntary settlement and, where this is not feasible, to assist displaced persons in improving or at least restoring their livelihoods and standards of living in real terms relative to pre-displacement levels or to levels prevailing prior to the beginning of project implementation.
“OP/BP 4.37 Safety of Dams”. The objective is to ensure quality and safety in the design and construction of new dams and the rehabilitations of existing dams and in carrying out activities that may be affected by an existing dam.
OP/BP 7.05 Projects on International Waterways” The objective is to ensure projects will neither affect the efficient utilization and protection of international waterways, nor adversely affect relations between the Bank and its Borrowers.
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Updated ESIA and EMP for Bijela Shipyard 3 Project description
The overall objective of the project is to mitigate the existing negative impacts from the contamination of the waste grit dumpsite within Adriatic Bijela Shipyard by the implementation of remediation works described as ‘export of the waste grit, with obligation to treat a certain amount of grit on-site’.
3.1 Location The Adriatic shipyard Bijela is situated in the Bijela settlement in Bokakotorska Bay along the road Herceg Novi - Risan. This is in the vicinity of the Kamenari settlement which has a ferry line across the bay. Bijela is extended along the coast in an elongated shape due to the expressed topography of the hinterland. The shipyard is situated within the urban area of Bijela. The dumpsite is located inside the shipyard. The location of the shipyard is shown in figure 1.
Figure 1 Location of the shipyard
The shipyard is situated within the urban area of Bijela, and grit waste piles and dumpsites are located within the shipyard. Location of the shipyard and area affected by grit waste is shown in figure 2.
Figure 2 Area affected by grit waste
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 13 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
3.2 Remediation of Shipyard Bijela Contaminated site The remediation scenario of the contaminated waste grit dumpsite within Bijela Shipyard was selected by the Client, and described as ‘export of the waste grit, with obligation to treat a certain amount of grit on-site’.
Figure 3 shows the layout of Bijela Shipyard, with labeled depots of grit waste, A through E, and derelict dumping areas North and South (N and S). Locations N and S are former contaminated landfill sites of grit mixed with waste oil and other waste.
Figure 3. Layout of Bijela shipyard
The remediation scope of the project includes all old blasting grit wastes stored in piles A, B and C, all new blasting grit wastes stored in piles D and E, all subsurface materials in the derelict dumping area that contain > 50 % blasting grit waste, all blasting grit wastes and contaminated topsoil present in the depot areas and remediation site to a maximum depth of 0.10 m, all soil in the derelict dumping area and its direct vicinity that contains petroleum hydrocarbons above 5,000 mg/kg d.w.
Excluded from the remediation scope is any blasting grit waste present on the sea floor, sea sediments that contain more than 50% of blasting grit, as well as blasting grit wastes present in the subsurface of the site outside the derelict dumping areas. These grit wastes have been insufficiently investigated to design remedial actions. For the same reason, insufficient information available to design a remediation process, groundwater is excluded from the works as well, and the remediation scope for the groundwater is confined to measures needed for the excavation of the contaminated soil and blasting grit wastes from the derelict dumping area.
The works required to reach the remediation goals may be divided into the following categories:
1. Removal of all waste materials from the remediation area surface that are not blasting grit waste or contaminated soil
2. Excavation or collection of blasting grit waste from the previously packed bags and the derelict dumping area, including soil containing petroleum hydrocarbons above 5,000 mg/kg d.w. and/or more than 50% blasting grit waste
3. Sieving of the material to remove large objects
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4. Repacking of hazardous blasting grit waste and contaminated soil in big bags and export to a treatment facility abroad
5. Backfilling the excavation pit (that will remain after excavation of blasting grit wastes and contaminated soil at the location of the derelict dumping area) below groundwater level with clean sand or gravel
6. Immobilization of non-hazardous blasting grit waste on site and backfilling of the excavation pit above groundwater level
After the remediation works have been completed, the site will be restored to the currently existing lay-out; i.e. surface will be restored to current surface levels, but certain site infrastructure that may have been removed because of the remediation works will not be restored (e.g. pathways, derelict structures or structures or facilities of a temporary nature), with exception of the concrete pathway and utility infrastructure leading up to the East jetty / pier.
Estimated quantities of the waste grit and contaminated materials present on the site are shown in table below:
Waste materials Total estimated tons Derelict dumping area Blasting Grit 40 000
Derelict dumping area soil 18 700
Depots B 18 950
Depot C 8 400
Depot A 40 900
Depots D, E 12 200
Subtotal 139 150
Other Blasting Grit Wastes 2 498
Total, waste material 141 648
Works to be undertaken during the initial stages of the remediation works: Removal of all waste materials from the remediation area surface that are not blasting grit waste or contaminated soil. These works are not expected to induce a significant environmental impact, provided that the contractor follows construction procedures and standards. These works are expected to generate the following hazardous materials that have to be handed over to an authorized collector of such a waste:
Other wastes (including mixtures of materials) from mechanical treatment of waste containing dangerous substances 19 12 11 * (M)
Absorbers, materials for filters, cleaning cloths and protective wear contaminated by hazardous substances 15 02 02 * (M)
Mixture of wastes from waste chamber and oil/water separator 13 05 08 * (A)
Sludge from oil/water separator 13 05 02* (A)
Construction materials containing asbestos 17 06 05 * (M)
Other wastes from construction and demolition (including mixed wastes) containing hazardous substances, 17 09 03 (M)
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Mixtures of, or separate fractions of concrete, bricks, tiles and ceramics containing dangerous substances 17 01 06* or 17 09 03*
Other wastes generated in this process, waste containing asbestos and non-hazardous waste, shall be treated in accordance with Law on Waste Management ("Off. gazette of Montenegro", no. 64/11), Rule book on handling construction waste and methods for its treatment, and conditions and disposal methods of concrete-asbestos construction waste ("Off. gazette of Montenegro", no. 50/12), and Rule book on methods of packaging and removal of waste that contains asbestos ("Off. gazette of Montenegro", no. 11/13). This waste includes concrete (code 17 01 01), iron and steel (17 04 05), mixed waste from construction and demolition (17 09 04), wood (19 12 07) and soil and stone wastes (17 05 04)
Waste oils shall be handed over to an authorized collector of this type of waste
Other possible types of waste that have not been listed above shall also be handed over to an authorized waste collector, for each respective type of waste
Works to be undertaken during subsequent stages of the remediation works: Excavation or collection of blasting grit wastes from the previously packed bags and the derelict dumping area, which includes soil containing petroleum hydrocarbons above 5,000 mg/kg d.w. and/or containing more than 50% blasting grit wastes. Significant environmental impacts can be expected from these works, especially if works are performed in an inadequate way. Leachate waters will be generated during excavation works and dewatering of grit waste and other contaminated material. These waste water, aqueous liquid wastes and aqueous concentrates from groundwater remediation containing dangerous substances (code 19 13 07*), can be either handed over to an authorized collector of this type of waste, or may be treated in such a way that their quality before the release meets requirements set forth within Rule book on quality and sanitary/technical conditions for release of waste waters into a recipient or public sewage systems, methods of waste water quality analyses, minimum number of analyses and content of waste water quality certificate ("Off. Gazette of Montenegro", no. 45/08, 09/10, 26/12, 52/12 and 59/13.
This phase will also include the removal of free phase layers found during the excavation of the soil from the derelict dumping area, which will be accomplished by skimming and collecting any such a light non-aqueous phase liquid (LNAPL) found during the excavation of soil below the groundwater table, and installation of a barrier to prevent the outflow of contaminated groundwater to the sea. This barrier will remain in place for at least 3 years after the excavations are over, and within that period, installment of a new, permanent barrier is expected by the new shipyard concession holder. The LNAPL and the drainage water from the dewatering basin shall be collected and handed over to an authorized collector of that type of waste.
Sieving of waste materials to remove large objects is not expected to induce adverse environmental impact, provided that the contractor follows construction procedures and standards, as well as operation manuals for machinery used in the process. Possible waste generated in this phase should be handled in the same way as described for the initial stages, and its estimated quantities are shown in the table below.
Other waste to be transported off-site Waste materials tons % Derelict dumping area Blasting Grit 4 000 10
Derelict dumping area soil 1 870 10
Depots B 569 3
Depot C 252 3
Depot A 1 227 3
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Other waste to be transported off-site Waste materials tons % Depots D, E 366 3
Subtotal 8 284
Other Blasting Grit Wastes 250 10
Total, waste material 8 534
After sieving, the hazardous blasting grit waste and contaminated soil obtained in previous phases will be repacked in big bags, with a usual mass of filled bags of 1 to 1.5 tons, and export of hazardous waste to a treatment facility, or handing over of non-hazardous waste to an authorized collector. Alternative is shipment as bulk cargo. The main environmental impact here will be the generation of the dust, which Contractor shall prevent by installing appropriate dusting systems and mitigation measures. No other adverse environmental impacts are expected in this phase. Estimated quantities of grit waste to be exported are shown in the table below.
Export Waste materials tons % Derelict dumping area Blasting Grit 36 000 90
Derelict dumping area soil 16 830 90
Depots B 18 381 97
Depot C 0 0
Depot A 36 097 88
Depots D, E 0 0
Subtotal 107 308
Other Blasting Grit Wastes 2 248 90
Total, waste material 109 556
The backfilling of the excavation pit below groundwater level with clean sand or gravel, is not expected to significantly impact the environment. Contractor shall monitor the source of clean sand/gravel, to prove it does not contain any hazardous material that can endanger local sea ecosystem, and to suppress the dust during sand transportation, loading, unloading or transfer within the site.
The immobilization of blasting grit waste and backfilling of the pit at the location of the derelict dumping area: Backfilling will be done with immobilized waste grit from new depots D and E, with waste grit from depots A and C also being considered for immobilization, depending on results of testing on presence, form and mobility of Zn present within the grit, which currently renders the grit to be classified as hazardous. If additional laboratory testing confirms that waste grit from depots A and C remains hazardous, therefore unsuitable for backfilling, it will be exported with the rest of the waste, and waste grit from depots D and E along with coarse sand will be used for immobilization and backfilling. Estimated quantities of material to be immobilized are shown in the table below.
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Immobilization Waste materials tons % Derelict dumping area Blasting Grit 0 0
Derelict dumping area soil 0 0
Depots B 0 0
Depot C 8 148 97
Depot A 3 576 9
Depots D, E 11 834 97
Subtotal 23 558
Other Blasting Grit Wastes 0 0
Total, waste material 23 558
Immobilization will be done by adding and mixing in of cement mortar to the selected waste grit (optimal concentration of mortar is estimated to 8%), and application of the immobilized material in the excavation area will be subject to Project management. Under those circumstances, no adverse environmental impacts are expected, provided that the contractor adheres to all relevant work procedures, HSSE requirements and instruction manuals for use of machinery and equipment in processes within this phase.
The total duration of remediation works is estimated at approximately 1.5 years, out of which one year of active on-site works, although experienced contractors could optimize the works and phases overlaps, so to possibly cut the total duration to less than one year.
The advantages and disadvantages of the selected remediation scenario are shown in table below.
Advantages Disadvantages Elimination of direct contact and material uptake by Costs of excavation, export and humans by source removal. immobilization of material and backfilling of the excavation pit. Safe solution to stop uncontrolled contamination transport into harbour area. Residual contamination after the remediation works will continue to Safe solution to stop contamination transport via wind require control and management during erosion / dust formation. re-development of the shipyard. Immediate improvement of the local environmental Remediation is not provided remediation situation. and dredging grit and contaminated sediment in the sea.
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Updated ESIA and EMP for Bijela Shipyard 4 Baseline data - current situation of the Environment
4.1 Description of the site and surroundings The Bijela Shipyard was founded in 1927 and is currently the biggest shipyard of the southern Adriatic Sea. It covers a total area of 12 ha and consists of 2 pilled jetties (500 and 175 m long) and 2 floating docks (l/w 259/45 m and 184/27 m). The shipyard is equipped for repairing and reconstructing of ships and other vessels of all types and purposes of up to 120,000 DWT. The activities include removal of old paint, old hull coatings and rust by sandblasting and the application of new coatings and paintings.
Used blast grit from the Adriatic Shipyard has been piled on two relict dumps (North and South) and five piles (A through E). This results in a mixture of different waste fractions (hazardous/ non-hazardous) that were dumped on the shipyard`s mostly unpaved surface. CDM/Smith has reported a volume of 60,000 t of spent waste blasting grit, 2,000 t of contaminated municipal waste, some hundred tons of steel scrap, several tons of construction waste, outdated oil and sludge recovery equipment and some vessel dilapidated hulks (Source: Site Investigations and Preparation Study for the Remediation of Industrial Waste Disposal Sites in Montenegro, Author CDM/Smith/Hidroinzeniring, July 2012) based on the detailed analyses completed by CETI. The surrounding area/soil is covered with blast grit, too. The volume of the dumps has previously been reported to be some 25,000 m³ and 50,000 tons respectively (EPA Montenegro - ToR for ESIA for remediation of five contaminated sites, 2012). However, investigations undertaken by Tauw in 2015 after CETI estimate total amount of grit waste and contaminated soil to 141,088 tons, out of which 109,187 tons will be exported, 23,560 tons immobilized and reused for backfilling of excavation pits, and 8,341 tons transported off site. For more detailed information about the site and contamination situation reference is made to report on Site Information & Contamination Situation - Remediation works in Bijela shipyard, Tauw and Witteveen+Bos, August 2015).
4.2 Flora, fauna and natural resources The contamination has a potential impact on the marine ecosystems or air quality because of airborne spread of grit. This is especially an issue as seasonal winds in the bay are quite common. In addition, the Bokakotorska Bay is one of the most important touristic destinations in Montenegro and the neighbouring Risansko-Kotorski Zaliv Bay is proposed as an Emerald Network site.
4.3 Cultural assets Bay of Kotor is a protected area by UNESCO as a part of World Natural and Cultural Heritage.
4.4 Climate The area of the Bay of Kotor is characterized by a Mediterranean climate with dry and hot summers and warm winters. Herceg Novi has a specific microclimate, which is a result of southern exposition, proximity to the sea, limestone substratum and mountainous hinterland which prevents the breakthrough of cold air masses.
Herceg Novi has approximately 200 sunny days a year. In July and August there are approximately 11 sunny hours per day. Average annual temperature is 16.2°C. The average daily temperature fluctuation is only 4°C. Average temperature from May to September is about 25°C, which provides a swimming season over 5 months long since the average summer sea temperature is rather high, between 22°C - 26°C.
The annual average precipitation is 1,930 mm. Relative air humidity is at its highest level, 80 %, in the fall. Its lowest level, 63 %, comes in the summer.
4.5 Previous investigations Previous investigations of the contamination of Bijela Shipyards include, inter alia:
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Analysis and characterization of the grit, Internal document, 2008
Brodogradiliste Bijela, Shipyard Bijela - Short description, Internal document, 2012
CETI, Grit, 20 Sep. 2011, vol. I-III in the context of research CDM Europe GmbH-Alsbach – Germany /Hidroinžinjiring Ltd Ljubljana-Slovenia
Environmental protection study, vol. 1, Internal document, 2011
ESIA of Remediation of Five Contaminated Sites, EPA/COWI for IWMC Project, 2012
Remediation works in Bijela shipyard Technical specifications with ESIA and EMP, Tauw & Witteveen+Bos, 2016
Testing of soil and groundwater at the site of the Adriatic shipyard a.d. Bijela for the purpose of making a "zero" state, CETI, March 2016
The produced waste contains different potentially hazardous residues of the removed ship paint and coatings, which can contain biocidal heavy metals or organic components, TBT and PAHs. The blast grit material is mixed with other types of waste such as metal scrap, plastics, barrels, oil and other hydrocarbons. The slopes of the dumps have partially reached the beach of the Bokokotorski Bay, meaning that water and sediment is in direct contact with the waste.
Available analysis show elevated levels of TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total polyaromatic hydrocarbons (PAH), total hydrocarbons and mercury (dry substance as well as leachate tests).
Minor contamination of the sediment was also identified, as well as in seashells, which serve as the major bio- indicator of this type of contamination. Such situation is a result of inadequate disposal of solid waste (waste grit, waste oils, grease and oily water, paint traces etc.) on site.
Investigations in the zone of the shipyard show that considerable quantities of grit resulting from sand-blasting as well as solid waste of hazardous origin and quality are deposited on the seabed.
4.5.1. Additional investigation by CDM
Investigations conducted by CDM includes additional drilling, leaching test, sampling and analyses of soil, groundwater and surface water. The results of the investigation by CDM are shown in table 4.5.1.
Table 4.5.1 Results of investigation
Investigation Results Analyses of 10 drillings to 0.5 m Exceeding threshold limits: surface soil Arsenic up to 59 mg/kg
Copper up to 2,554 mg/kg
Zinc up to 2,265 mg/kg
Chromium up to 5,338 mg/kg
Nickel up to 528 mg/kg
Cadmium up to 9 mg/kg
Lead up to 600 mg/kg
Mercury up to 2.3 mg/kg
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Investigation Results PAH up to 117 mg/kg
PCB up to 0.208 mg/kg
Analyses of 4 drillings to 10 m Exceeding threshold limits deeper drillings Copper up to 1,179 mg/kg
Zinc up to 2,201 mg/kg
Chromium up to 3,330 mg/kg
Nickel up to 404 mg/kg
Cadmium up to 44 mg/kg
Lead up to 104 mg/kg
TBT up to 5 mg/kg
Mercury up to 3.6 mg/kg
PAH up to 0.197 mg/kg
PCB up to 0.208 mg/kg
Analyze of used 1 sample of used grit Waste material grit Fe 284 mg/kg
Cr 14 100 mg/kg
Cu 1,166 mg/kg
Ni 976 mg/kg
Cd 25.5 mg/kg
Analyses of 4 samples with one from each of Low to very low concentration of heavy metals groundwater the 4 drillings Exceeding threshold limits:
TBT up to 0.00158 mg/kg
PAH up to 5.90 mg/kg
Total hydrocarbon up to 51 mg/kg
Phenols 0.74 mg/kg
BTEX up to 0.060 mg/kg
CHC up to 0.062 mg/kg
Sea sediment 10 samples taken from 2.5-20 m Exceeding threshold limits: bsl Copper 338 mg/kg
Zinc 474 mg/kg
Chromium 700 mg/kg
Nickel 237 mg/kg
Lead 161 mg/kg
TBT 4.93 mg/kg
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Investigation Results Mercury 3.6 mg/kg
PAH 17.61 mg/kg
PCB 0.163 mg/kg
Leaching test Neutral to slightly acidic conditions. Only one sample exceeded the threshold limits. In general moderate leaching.
Sea water 2 samples No indication of contamination except for 0.04 μg/l TBT which is above the EU standard of 0.0015 μg/l
Sea-shells Sea shell from the bottom near Monitoring of shellfish carried out in the framework the harbour of the ship-yard of the regular monitoring of the marine ecosystem of Montenegro from 2008-2012 show that the shells at the location B. Bijela (hot spot) had significantly higher concentrations of Pb, Zn, PCBs, PAHs, Ni, TBT, Hg and As.
4.5.2. Additional investigations by CETI, considered by Tauw & Witteveen+Bos
Centre for Eco-toxicological research (CETI), Podgorica, Montenegro, undertook new additional analyses of waste grit samples in July 2013 and February 2015. Consultants Tauw-Witteveen+Bos have used those results in preparing the Technical Documentation for the subject project; sampling maps created by CETI were overlapped with site maps prepared by Tauw-Witteveen+Bos, and it was determined that depots D and E match samples analysed in July 2013, that were classified as non-hazardous (CETI, "Report on waste analysis", no. 232-04 through 241-04, total of 10 reports, all dated on 17.07.2013, and (CETI, "Report on waste investigation", no. 232-04 through 241-04, total of 10 reports, all dated on 17.07.2013), while depots A, B and C match samples analysed in February 2015, that were classified as hazardous (CETI, "Montenegro Industrial Waste Management and Clean-up Project (IWMCP) – Site Investigations (Sampling and Testing) at Bijela Shipyard", dated on February 2015).
4.5.3. "Zero" state investigation by CETI
Centre for Eco-Toxicological Research (CETI), Podgorica, Montenegro, drafted a report on the testing of soil and groundwater at the site of the Adriatic shipyard a.d. Bijela for the purpose of making a "zero" state (March 2016). Exploratory works included the following:
collecting and reviewing data on underground installations
exploration rotary drilling to a depth of 3 meters (65 holes)
mechanical breaking concrete surfaces
sampling and chemical analysis
preparing documentation on exploration activities and interpretation of data
Sampling was conducted at sites in order to obtain a clear picture of the situation on the potential pollution of soil in the area concerned.
Results from the report on the examination of soil / sediment br. 00-3109/1 show that the following parameters at the site of the shipyard above the lowest level of the intervention of the standardized Dutch standards: barium, arsenic, copper, lead, zinc, nickel, cadmium, chromium, mercury, molybdenum, PAH, PCBs and TPH. A total of 138 samples of soil / sediment were collected. Of those 138 samples of soil / sediment, 74 ahd a content of TPH that
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Updated ESIA and EMP for Bijela Shipyard exceeds the target level value of 50 mg/kg of according to the Dutch standard, while 18 samples had a content of TPH above the level of the intervention, or above 5,000 mg / kg.
Of the 34 analyzed samples of groundwater, 22 of them had content of mineral oil that exceeds the value according to standardized regulation. High values of TPH were found in the waters at those locations where the content TPH in soil / sediment is high.
4.6 Potential risk and design parameter The results of the investigations show that the location is a potential source for contamination of the surrounding area. The potential source for contamination from the disposal of the waste grit includes TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total polyaromatic hydrocarbons (PAH), total hydrocarbons and mercury (dry substance as well as leachate tests). These components are relatively immobile.
TBT will bind strongly to suspended material such as minute organic components of phytoplankton and zooplankton, shellfish, fish, etc. and inorganic sediments. The extent of binding to bottom sediment will vary with location, organic content, particle size, and type of material. TBT is extremely toxic to molluscs; analysis from 2010 found values were exceeded 20 times the normal value for the Mediterranean, and in 2011 as many as 30 times, given that Montenegro has no standard for TBT in mussels..
4.7 General characterization of the waste body The results of the investigations show that the location is a potential source for contamination of the surrounding area. The potential source for contamination from the disposal of the waste grit includes TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total polyaromatic hydrocarbons (PAH), total hydrocarbons and mercury (dry substance as well as leachate tests). These components are relatively immobile. Characterization of the contaminated body is shown in table 4.7.
Table 4.7. Characterization of the contaminated body
Preliminary description Characterization Source volume High volume (141,000 tons of grit and contaminated soil)
Source type Dominated by heavy metal, TBT, PAH and PCB Mineral oil, PAH, phenols, BTEX and CHC was detected in the northern part of the landfill grit shipyard
Source strength The concentrations of contaminants are low to medium but the location close to the coast means a relatively high source strength
Hot spots Not expected
Sensitivity of surrounding area Very high - dumpsite located at gulf coastline, nearby resident area and within a touristic centre
4.8 Social Economic baseline
4.8.1. General information
Demographically, Bijela is part of the Herceg Novi municipality, which stretches from Prevlaka peninsula to the Verige Strait. An almost unbroken string of towns lie along this strip of coast, accommodating the municipality's 33,034 (2003 census) residents. These include Igalo, Herceg Novi, Baošići, Đenovići, Meljine and Bijela. Due to their proximity, Herceg Novi and Igalo are usually considered one town with a combined population of 16,493. Administratively, Herceg Novi's current population is 12,739.
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Population data for Republic of Montenegro, Municipality Herceg Novi and settlement Bijela, according to official preliminary data from Population census in 2011, are given in table 4.8.1.
Table 4.8.1 Population data
Total Urban Rural Montenegro 625 266 401 462 223 804 H. Novi 30 992 19 617 11 375 Bijela 3 725 - - (Source: MONSTAT, Census of Population, Households and Dwellings in Montenegro, First results 2011) Bijela is a small town with approximately 3,700 inhabitants. The town is dominated by the shipyard which is the largest employer in the town.
The shipyard is located in the middle of the town surrounded by residential and commercial area.
4.8.2. Potential for employment
Potential for employment during the construction phase of the remediation; however the effect is considered limited due to the relatively limited scale of the remediation.
The construction work related to the remediation can be tendered nationally or internationally according the WB procurement procedure. Given the nature, size and complexity of the project, it is reasonable to expect an international tender.
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Updated ESIA and EMP for Bijela Shipyard 5 Environmental impacts
5.1 Impact assessment of the current situation and possible mitigation measures The current impact from the dumpsite at Bijela Shipyard is summarized in table 5.1. In the present situation, the contaminated dump site has several adverse impacts on the environment and on the social-economic environment. The objective of the remediation is to limit the adverse impact by implementing various mitigating measures including noise, increased traffic or dust related to the construction works during implementation of the remediation.
The remediation will have a significant positive impact on the environment; however during the implementation of the remediation some short-term minor negative impacts might be expected. The impact during the construction phase and the operational phase of the remediation is included in the Environmental Management Plan and Monitoring Plan.
Table 5.1 The Environmental and Social Impact assessment
Current impacts Future impacts after Subject Issue Mitigation measures from dumpsite remediation 1. Soil - Exposure of The surface of the shipyard is Significant The contaminated soil Positive impact by humans and animals highly contaminated with negative impact and grit material will be preventing risk for to contaminated soil elevated levels of toxic metals removed direct human contact and grit by direct and petroleum hydrocarbons, contact (surface soil) PAHs. The area is uncovered and without vegetation and is enclosed and inaccessible for humans and animals
2. Dust - Exposure of Wind dust transport is Significant The contaminated soil Positive impact with humans and animals expected mainly during the negative impact and grit material will be no future to contaminated summer season when the removed contaminated dust dust, wind erosion of surface is dry and wind blow from the dump site surface particles alternating from the mountains or the sea. Residential area neighbouring the shipyard
3. Groundwater The groundwater flow is Negative Contaminated soil Removal of the expected to be towards the significant mixed with BGW and contaminated soil, sea. the contamination might soil with a TPH content the expected LNAPL spread to the sea. The of > 5,000 mg/kg. The and part of the groundwater is not used for latter is basically soil contaminated drinking water, but there are where TPH is present in groundwater will groundwater extraction wells a free phase. Soil left at have a positive for production water. the soil can have quite impact on the high TPH contents (up environment. We During the excavation, a part to 5,000 mg/kg d.m.) expect the of the contaminated soil will be removed. During groundwater to (partly mixed with grit wastes) excavations, a separator remain will be excavated under (skimmer) of oily waters contaminated even groundwater level; ‘in the wet’. will be in place, to after the After this first drainage step, prevent leaching of oils remediation. the remaining moisture will be back to the soil. The However as the main drained in the dewatering water coming from the source of
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Current impacts Future impacts after Subject Issue Mitigation measures from dumpsite remediation basin. The water from the dewatering basin will be contamination will dewatering basin will be collected and have been removed transported off-site by tanker transported off-site by a gradual trucks to a treatment facility. truck. improvement of the groundwater quality In addition, installation is possibly. In any of (sea) barrier to case we do not prevent the outflow of foresee the quality of contaminated water to the groundwater the sea. Depending on getting worse. the amount and depth of contaminated groundwater it should be considered the creation of underwater barrier-injection curtain to prevent impact on the maritime zone.
4. Backfilling of the Above groundwater level, non- Moderate Above groundwater Limited impact. excavation hazardous blasting grit waste adverse impact level: Non-hazardous will undergo an immobilisation blasting grit wastes will step and subsequently used to be used as backfill backfill the excavation. Below material. As extra groundwater level, clean precaution, this non- backfill material will be hazardous grit waste brought in to fill the will undergo an excavation. immobilisation step to ensure that no leaching The clean backfill material of possible (brought in from outside the contaminants will occur. site), below groundwater level, may become contaminated Under groundwater due to contact with level: The backfill contaminated groundwater material will be of such (which is not specifically nature and texture treated / remediated). (gravel and coarse sand) that only limited concentrations of contaminants are expected to adhese to the soil faction. Furthermore, the backfill material will be of much better environmental quality than the excavated material. Hence, an improved environmental situation will be the result.
5. Remaining and Not all contamination will be Possibly The choices made in the Management residual remediated, e.g. soil with TPH negative remediation approach measures imposed contamination concentrations below 5,000 significant aim at removing the on the shipyard
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Current impacts Future impacts after Subject Issue Mitigation measures from dumpsite remediation mg/kg d.m. will remain, sea worst contamination, operator will sediments contaminated with sources and hotspots. mitigate risks for grit wastes will not be Upon completion of the people and remediated, groundwater will works, an end-situation environment on-site not be remediated, but must evaluation will be be subject to monitoring, with performed, and control regard to its possible impact on / management the marine water, and not the measures for future site entire site has been fully use specified and investigated (which may mean executed by the that some kind of operator of the contamination has gone shipyard. unnoticed and as a result will remain after the remediation works).
6. Indirect impact No indirect impacts is expected - - -
7. Cumulative impact No cumulative impact is - - - expected
8. Transboundary The remediation includes Insignificant Export of hazardous - impact exporting of the waste waste shall be in accordance with the Basel Convention, final treatment/disposal shall be in accordance with EU legislation
9. Social impact Noise, dust, disruption of Possibly Planned works and No negative impact, traffic during the removal and negative material transportation but it is expected a transport of the material, significant will induce increased positive impact on vapors of petroleum products noise levels and impact the quality of the from the excavated area to local population. environment of the Works shall be shipyard. performed only within daily working hours, 07- 19 h.
10. Cultural assets The remediation might have a Insignificant - - positive impact on the conception of the environment in Bijela.
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 27 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard 6 Analysis of alternatives
0-alternative:
The 0-alternative means doing nothing. The current negative impacts from the contaminated dumpsite at Bijela will continuously represent a risk of environmental and of human exposure.
Scenario 1 - Complete removal of all grit and export to treatment/disposal facility
This alternative includes that all wastes classified as hazardous will be exported to a disposal or recycling facility outside of Montenegro. Non-hazardous wastes will be landfilled at a sanitary landfill in Montenegro.
The material will be transported in big bags. Where the current big bags are damaged, the blasting grit will either be double bagged or transferred completely to new big bags. It is estimated that this will need to be done for all of the currently packed bags. Transporting the blasting grit in an open container will lead to significant dust formation during loading and unloading, which is undesirable.
The big bags will be transported to the treatment facility with a registered vehicle/ship. The treatment facility will confirm receipt of the waste with a declaration of reception and will process the blasting grit in compliance with the agreed working method.
The processor will process the blasting grit as agreed in the notification request. As soon as the processing is completed, all involved governments will be notified.
Scenario 2 - Landfilling of grit wastes in Montenegro
This alternative comprises the following measures:
1. On-site separation of hazardous grit waste and non-hazardous grit waste
2. Disposal or re-use of non-hazardous grit waste in Montenegro
3. Disposal of hazardous grit waste at a sanitary landfill in Montenegro
The transport of the wastes from the Bijela site is identical to scenario 1, with the exception that the wastes will remain in Montenegro and thus no export permits are necessary. Due to the large volume of wastes and, in places, narrow road network in Montenegro the use of barges and trains for parts of the route can mitigate the environmental impact of the transport and improve operational feasibility and reduce costs.
Scenario 3 - On-site recycling of grit
This alternative for export of grit is on-site recycling of grit at the Bijela Shipyard site. In general there are two options for on-site recycling of grit:
1. Immobilisation of grit with a binding agent resulting in a granulate that can be used as construction/foundation material
2. Immobilisation of grit by using it as filling material (replacement of sand) in concrete or asphalt
Both immobilisation techniques are commonly used and accepted treatment techniques. The actual immobilisation procedure and mixture recipe depends on the composition of the grit (i.e. particle size, contaminations, et cetera) and have to be determined based on material and leaching tests.
The project ‘Remediation works in Bijela shipyard’ (Project Reference No. MNE-IWMCP-8428-ICB-W-15-1.3.5) outlined, evaluated and compared the three last scenarios for the remediation of the shipyard (Task 2). After a
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 28 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard careful process of weighing the options in environmental, technical, financial and political terms, on 29 June 2015, the Government of Montenegro, represented by the project’s steering committee, selected a combination of Scenario 1 (export of grit wastes) and Scenario 3 (application of grit wastes on-site) as the preferred scenario.
This scenario entails the export of all hazardous blasting grit wastes and soil contaminated with petroleum hydrocarbons over 5,000 mg/kg d.m. Non-hazardous blasting grit wastes will be immobilized on-site and used to refill the excavated area on the shipyard.
The scenario for the remediation works as prescribed by the steering committee as a basis for design was formulated as: ‘Export with the obligation to treat a certain amount of grit on-site’.
The following multi criteria decision analysis (MCDA) was used to aid the selection of the best scenario:
# Criterium Evaluation Environmental risks reduction and nuisance for local 1. Environmental and social merits and risks inhabitants
2. Technical feasibility and risks The availability of recycling capacity
3. Operational feasibility The level of complexity of remediation works and logistics
4. Legal feasibility The risk of not getting required permits and permissions
5. Duration of the works Estimated execution time till completion of the remediation
6. Costs Estimated costs
The table below shows the evaluation of each scenario using the MCDA:
# Criterium Scenario 1 Scenario 2 Scenario 3 1. Environmental Nuisance of excavation Comparable with scenario 1, Nuisance similar to scenario and social works, sieving and but extra traffic due to 1, with the possibility of merits and dewatering trucks or trains (for a part) extra traffic of trucks to and risks driving to MSW landfill in from the site with Montenegro immobilized wastes. It should be noted that immobilization of the grit might give some (initial) public unrest as waste material is not removed
2. Technical It is likely that there is no On paper the sanitary Integration with site feasibility and treatment facility that has landfill sites have sufficient redevelopment is required; risks sufficient capacity to capacity to accept the grit uncertain if vendor is willing accept all grit in one load; wastes, however it is not to accept immobilized grit so tendering in multiple clear if the landfill operators and whether all grit can be lots or shipping are willing to accept these stored on site quantities
For the alternative of re-use in the highway: It is yet to be determined whether the
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 29 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
# Criterium Scenario 1 Scenario 2 Scenario 3 waste will be accepted as construction material
3. Operational Feasible, but only if Feasible, but only if shipyard Complex logistics with feasibility shipyard activities are activities are temporarily limited space for execution temporarily ceased around ceased around East pier and of the works. East pier adequate transport planning Significant impact on is done shipyard operations near East pier anticipated
4. Legal Complex process to get Limited permitting required No export notification feasibility expert notification if all wastes can be landfilled needed in sanitary landfill. If not then similar procedure needed as in scenario 1.
In case of transport of wastes for immobilization off-site review of legal status in Montenegro should be checked
5. Duration of Uncertain, but at least 1 Works can be executed Uncertain, fully depends on the works year till confirmation of parallel. Duration estimated planning of site recycling at 5-6 months, but strongly redevelopment, but will take depends on transport and at least one year, in case of execution planning. And, in off-site recycling it might be the case of re-use in the faster, but depends on highway, it depends on the transport and execution capacity to take-in the planning waste
6. Costs EUR 14,900,000 - EUR EUR 10,600,000 - EUR EUR 8,900,000 - EUR 18,900,000 12,100,000 9,900,000
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 30 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
7 Environmental management plan (EMP)
The purpose of the Environmental Management Plan (EMP) for the remediation is to ensure that all adverse environmental impacts are within the acceptable level, according to subsequently prevention, control and monitoring and mitigation. The EMP sets out to ensure that all aspects of the works comply with the relevant legislation, permit conditions and good practice, and that measures to mitigate the negative impacts identified in the ESIA are implemented. The EMP strives to implement appropriate environmental controls and monitoring procedures during construction.
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. The detailed CEMP should include detailed method statements, environmental control procedures and environmental compliance monitoring to be carried out during the construction works. The Health and Safety measures and monitoring are specified in the preliminary HASP, also part of the Technical Documentation produced in the assignment ‘Remediation works in Bijela shipyard’ (Project Reference No. MNE-IWMCP-8428-ICB-W-15-1.3.5).
The following tables present the Environmental Mitigation Plan measures and the Environmental Monitoring Plan.
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 31 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
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7.1 Environmental Mitigation Plan
Table 7.1.1 Preparatory works
Installation Operation Installation Operation Issue Mitigating Measures cost cost responsibility responsibility Dust control during works, by for instance sprinkling water during dry periods Included in Included in Contractor Contractor Mixing and sieving installations should be installed as far away as possible from the the supervised by EPA supervised by EPA, and Dust the site borders (but within the remediation area) bid from the bid from the and supervising supervising During droughts, transport areas that are not asphalted need to be watered Contractor Contractor engineer engineer The load in all trucks leaving the site should be covered to prevent dust formation Handling of oil and fuel Oil and fuel should be kept in locations with secondary containment. No drums are used for Contractor's As above As above As above As above allowed to be placed directly on the ground vehicles and machinery Use of Personal Protection Equipment, staff training especially for work with asbestos, Work in contaminated waste oils, waste with PCBs, which will occur after the dismantling of equipment that As above As above As above As above material contains it (see NAP for PCBs) The noise impact is related to the use of machineries like bulldozer, dredgers, vehicles for Noise As above As above As above As above waste transport. Limiting time for activities, suggestion: 07 - 19 h. Any newly waste generated during the remediation activities, depending on its Waste As above As above As above As above categorization, shall be handed over to a company authorized to collect the subject waste. Limited time for works, 07 - 19 h, to avoid disturbance of population near the shipyard, as Social issues - - - - well as cumulative effect of transportation off site. The contractor shall set up a health and safety organization before the implementation of the work. HSE Training The contractor shall also ensure that all relevant staff has been training in health and As above As above As above As above safety issue not at least in relation to work in contaminated soil and use of personal protection equipment.
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 32 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
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Table 7.1.2 Excavation or collection of blasting grit wastes from the previously packed bags and the derelict dumping area, including soil containing petroleum
Installation Operation Installation Operation Issue Mitigating Measures cost cost responsibility responsibility Dust control during works, by for instance sprinkling water during dry periods Included in Included in Contractor Contractor Mixing and sieving installations should be installed as far away as possible from the the the supervised by EPA supervised by EPA, Dust site borders (but within the remediation area) bid from the bid from the and supervising and supervising During droughts, transport areas that are not asphalted need to be watered Contractor Contractor engineer engineer The load in all trucks leaving the site should be covered to prevent dust formation Smell-vapors of Smell control (petroleum hydrocarbons, PAHs) during excavation works, by covering of the As above As above As above As above petroleum products* dewatering basin at night and excavation below the groundwater in trenches Handling of oil and fuel Oil and fuel should be kept in locations with secondary containment. No drums are allowed to used for Contractor's As above As above As above As above be placed directly on the ground vehicles and machinery Work in contaminated Use of Personal Protection Equipment, staff training especially for work with asbestos, waste As above As above As above As above material oils, waste with PCBs Covering the dewatering and water collection basins with plastic foils during the night. As above As above As above As above Water Installment of protective barrier trench Treatment of waste waters to required level or handover to an authorized dealer. The noise impact is related to the use of machineries like bulldozer, dredgers, vehicles for Noise As above As above As above As above waste transport. Limiting time for activities, suggestion: 07 - 19 h. Any waste generated during the remediation activities, depending on its categorization, shall Waste As above As above As above As above be handed over to a company authorized to collect the subject waste. Limited time for works, 07 - 19 h, to avoid disturbance of population near the shipyard, as well Social issues - - - - as cumulative effect of transportation off site. The contractor shall set up a health and safety organization before the implementation of the As above As above As above As above work. HSE Training The contractor shall also ensure that all relevant staff has been training in health and safety issue not at least in relation to work in contaminated soil and use of personal protection equipment. * Significant vapors of petroleum products, originating from plants for the treatment of oily water Hemosan, which also can have a negative effect on the environment and the health of the local population
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Table 7.1.3 Sieving of the material to remove large objects
Installation Operation Installation Operation Issue Mitigating Measures cost cost responsibility responsibility Dust control during works, by for instance sprinkling water during dry periods Included in Included in Contractor Contractor Mixing and sieving installations should be installed as far away as possible from the the supervised by EPA supervised by EPA, Dust the site borders (but within the remediation area) bid from the bid from the and supervising and supervising During droughts, transport areas that are not asphalted need to be watered Contractor Contractor engineer engineer The load in all trucks leaving the site should be covered to prevent dust formation Handling of oil and fuel Oil and fuel should be kept in locations with secondary containment. No drums are used for Contractor's As above As above As above As above allowed to be placed directly on the ground vehicles and machinery Work in contaminated Use of Personal Protection Equipment, staff training especially for work with asbestos, As above As above As above As above material waste oils, waste with PCBs The noise impact is related to the use of machineries like bulldozer, dredgers, vehicles for Noise As above As above As above As above waste transport. Limiting time for activities, suggestion: 07 - 19 h. Any waste generated during the remediation activities, depending on its categorization, Waste As above As above As above As above shall be handed over to a company authorized to collect the subject waste. Limited time for works, 07 - 19 h, to avoid disturbance of population near the shipyard, as Social issues - - - - well as cumulative effect of transportation off site. The contractor shall set up a health and safety organization before the implementation of the work. HSE Training The contractor shall also ensure that all relevant staff has been training in health and As above As above As above As above safety issue not at least in relation to work in contaminated soil and use of personal protection equipment.
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 34 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
Table 7.1.4 Re-packing of the hazardous blasting grit waste in big bags and its export to a treatment facility
Installation Operation Installation Operation Issue Mitigating Measures cost cost responsibility responsibility Dust control during works, by for instance sprinkling water during dry periods Included in Included in Contractor Contractor Mixing and sieving installations should be installed as far away as possible from the the supervised by EPA supervised by EPA, Dust the site borders (but within the remediation area) bid from the bid from the and supervising and supervising During droughts, transport areas that are not asphalted need to be watered Contractor Contractor engineer engineer The load in all trucks leaving the site should be covered to prevent dust formation Handling of oil and fuel Oil and fuel should be kept in locations with secondary containment. No drums are used for Contractor's As above As above As above As above allowed to be placed directly on the ground vehicles and machinery Work in contaminated Use of Personal Protection Equipment, staff training especially for work with asbestos, As above As above As above As above material waste oils, waste with PCBs Water Temporary depots with big bags should be covered with a LDPE-liner in case of rainfall As above As above As above As above The noise impact is related to the use of machineries like bulldozer, dredgers, vehicles for Noise As above As above As above As above waste transport. Limiting time for activities, suggestion: 07 - 19 h. Any waste generated during the remediation activities, depending on its categorization, Waste As above As above As above As above shall be handed over to a company authorized to collect the subject waste. Limited time for works, 07 - 19 h, to avoid disturbance of population near the shipyard, as Social issues - - - - well as cumulative effect of transportation off site. The contractor shall set up a health and safety organization before the implementation of As above As above As above As above the work. HSE Training The contractor shall also ensure that all relevant staff has been training in health and safety issue not at least in relation to work in contaminated soil and use of personal protection equipment.
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 35 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
Table 7.1.5 Backfilling the excavation pit below groundwater level with clean sand or gravel
Installation Operation Installation Operation Issue Mitigating Measures cost cost responsibility responsibility Dust control during works, by for instance sprinkling water during dry periods Included in Included in Contractor Contractor Mixing and sieving installations should be installed as far away as possible from the the supervised by EPA supervised by EPA, Dust the site borders (but within the remediation area) bid from the bid from the and supervising and supervising During droughts, transport areas that are not asphalted need to be watered Contractor Contractor engineer engineer The load in all trucks leaving the site should be covered to prevent dust formation Handling of oil and fuel Oil and fuel should be kept in locations with secondary containment. No drums are used for Contractor's As above As above As above As above allowed to be placed directly on the ground vehicles and machinery Flora and fauna Monitoring the sand source, so to prevent introduction of invasive species As above As above As above As above The noise impact is related to the use of machineries like bulldozer, dredgers, vehicles for Noise As above As above As above As above waste transport. Limiting time for activities, suggestion: 07 - 19 h. Limited time for works, 07 - 19 h, to avoid disturbance of population near the shipyard, as Social issues - - - - well as cumulative effect of transportation off site. The contractor shall set up a health and safety organization before the implementation of the work. HSE Training The contractor shall also ensure that all relevant staff has been training in health and As above As above As above As above safety issue not at least in relation to work in contaminated soil and use of personal protection equipment. Installation Operation Installation Operation Issue Mitigating Measures cost cost responsibility responsibility
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 36 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
Table 7.1.6 Immobilization of non-hazardous blasting grit waste on-site and backfilling the pit
Installation Operation Installation Operation Issue Mitigating Measures cost cost responsibility responsibility Dust control during works, by for instance sprinkling water during dry periods Included in Included in Contractor Contractor Mixing and sieving installations should be installed as far away as possible from the the supervised by EPA supervised by EPA, Dust the site borders (but within the remediation area) bid from the bid from the and supervising and supervising During droughts, transport areas that are not asphalted need to be watered Contractor Contractor engineer engineer The load in all trucks leaving the site should be covered to prevent dust formation Handling of oil and fuel Oil and fuel should be kept in locations with secondary containment. No drums are used for Contractor's As above As above As above As above allowed to be placed directly on the ground vehicles and machinery Flora and fauna Monitoring the sand source, so to prevent introduction of invasive species As above As above As above As above The noise impact is related to the use of machineries like bulldozer, dredgers, vehicles for Noise As above As above As above As above waste transport. Limiting time for activities, suggestion: 07 - 19 h. Limited time for works, 07 - 19 h, to avoid disturbance of population near the shipyard, as Social issues - - - - well as cumulative effect of transportation off site. The contractor shall set up a health and safety organization before the implementation of the work. HSE Training The contractor shall also ensure that all relevant staff has been training in health and As above As above As above As above safety issue not at least in relation to work in contaminated soil and use of personal protection equipment. Installation Operation Installation Operation Issue Mitigating Measures cost cost responsibility responsibility
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 37 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
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7.2 Environmental Monitoring Plan Installation Operation Installation and operation Phase Item Parameter Frequency Location cost cost responsibility Baseline Appropriate licensed - Dust monitors and / or Inside the construction site and outside In line with - Asbestos samplers and Contractor supervised by Air in downstream wind direction and Minimal the costs of - PM10 implemented by EPA settlements monitoring - Hydrocarbons and PAHs accredited laboratories 10 samples at a distance of 0 - 200 m from the contaminated site, at least the following parameters should be Soil Once at the beginning analysed: TBT (tributyltin), arsenic, Included in Control surrounding topsoil on Contractor supervised by Soil and one at the end of barium, copper, zinc, fluoride, chrome, the bid - contamination (baseline) EPA works tin, cobalt, nickel, lead, total from the polyaromatic hydrocarbons (PAH), Contractor total hydrocarbons and mercury and PCBs Soil samples in a raster of 20 x 20 m within the remediation area. No drilling though concrete. At least the following parameters should be analysed: TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total polyaromatic Included in Check quality of topsoil within Once at the beginning hydrocarbons (PAH), total the bid Contractor supervised by Soil and groundwater remediation area (baseline and and one at the end of hydrocarbons and mercury and PCBs - from the EPA after works) works Placement of two monitoring wells Contractor within former derelict dumping area. Sampling and analysis of groundwater for at least the following parameters: TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total hydrocarbons and mercury Control spreading of Once at the beginning Three samples of sea water in front of Contractor supervised by Seawater contamination (baseline and the and one at the end of remediation area, at least following As above As above EPA state after completion of the works. If necessary, parameters should be analysed:
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Installation Operation Installation and operation Phase Item Parameter Frequency Location cost cost responsibility works in the waters of the port, and during the works TBT (tributyltin), arsenic, barium, as well as on the beaches in the if the need arises due copper, zinc, fluoride, chrome, tin, immediate area in the direction to adverse weather or cobalt, nickel, lead, total polyaromatic of H. Novi and in the direction of other conditions. hydrocarbons (PAH), total Kamenar hydrocarbons and mercury 10 samples of the seafloor. The sampling locations should be spread out over the waters At least the following parameters Included in Control of sediment quality in Once at the beginning should be analysed: the - bid Contractor supervised by Sediments East Pier area (baseline and after and once at the end of - TBT (tributyltin), arsenic, barium, from the EPA works) works copper, zinc, fluoride, chrome, tin, Contractor cobalt, nickel, lead, total polyaromatic hydrocarbons (PAH), total hydrocarbons and mercury and PCBs All remediation phases In In Appropriate licensed accordance accordance - Dust monitors and/or Inside the construction site and outside with the with the - Asbestos samplers and Contractor supervised by Air in downstream wind direction and cost of cost of - PM10 implemented by EPA settlements implement implement - Hydrocarbons and PAHs accredited ation ation laboratories monitoring monitoring Waste Monitoring of all types of Permanent On site Minimal Included in Contractor supervised by waste and their handover to the bid EPA an authorized collector from the Contractor - Working hours - Daily Contractor supervised by Noise At site borders Minimal Minimal - Noise level - Subjectively EPA Included in In the beginning and the bid Poll of the surrounding Contractor supervised by Social issues at the end of Local municipality Minimal from population EPA remediation the Contractor Control surrounding topsoil 10 samples at a distance of 0 - 200 m Once (after In line with Contractor for contamination related to from the Soil completion of the real cost of - supervised by remediation works (effect of contaminated site, at least the remediation works) analyses EPA spreading of dust) following
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 39 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
Installation Operation Installation and operation Phase Item Parameter Frequency Location cost cost responsibility parameters should be analysed: TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total polyaromatic hydrocarbons (PAH), total hydrocarbons and mercury and PCBs Samples in a raster of 20 x 20 m within the remediation area. No drilling though concrete. Sampling points as close as possible to original locations. At least the following parameters should be analysed: TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, Included in cobalt, nickel, lead, total polyaromatic the bid Check quality of topsoil hydrocarbons (PAH), total from the Contractor Soil and within remediation area after once hydrocarbons and mercury. Contractor - supervised by groundwater remediation (control) (In line with EPA If required placement of two new real cost of monitoring wells close to location of analyses) original wells. Sampling and analysis of groundwater for at least the following parameters: TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total hydrocarbons and mercury Three samples of sea water in front of remediation area, at least following parameters should be analysed: Included in Control spreading of Once (after Contractor TBT (tributyltin), arsenic, barium, the bid Seawater contamination (control after completion of the - supervised by copper, zinc, fluoride, chrome, tin, from the works) remediation works) EPA cobalt, nickel, lead, total polyaromatic Contractor hydrocarbons (PAH), total hydrocarbons and mercury Control of sediment quality in 10 samples of the seafloor. The Included in Contractor East Pier area after works sampling locations should be as close the bid Sediments Once - supervised by (Examination of sediments after as possible to the original locations from the EPA completion of the work must At least the following parameters Contractor
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 40 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
Installation Operation Installation and operation Phase Item Parameter Frequency Location cost cost responsibility include the general location, should be analysed: because they carry the TBT (tributyltin), arsenic, barium, undulation and sea currents) copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total polyaromatic hydrocarbons (PAH), PCBs, total hydrocarbons and mercury After completion remediation works Included in Contractor selected by EPA, Ecosystems (flora, Risk assessment of any residual the bid Once per year On site and in surrounding area - for investigation of residual fauna, water, soil) contamination from the contamination Contractor Included in Permanent in the next the bid Contractor Monitoring wells Water quality Wells - two years from the selected by EPA Contractor
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 41 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
8 Appendixes
8.1 List of report preparers – the Joint Venture (Consultant)
8.2 References – list of written materials and study visit report used in study preparation
8.3 Public consultation – Minutes
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 42 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
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8.1 List of report preparers – the Joint Venture (Consultant)
JV leader:
ambiente s.c., with registered office at Via Frassina, 21, 54033 Carrara (MS), Italy. Is a leading European company in the field of environmental engineering with laboratories for chemical, physical and biological analysis.
Partners:
“Medix” Ltd. Podgorica, with registered office at PC Krusevac, 81000 Podgorica Montenegro. Is a leading European company in the field of Environmental Impact Assessment Studies, Strategic environmental impact assessment reports, Feasibility studies and projects in the area of environmental protection
DBA Progetti S.p.A., Italy with registered office at Piazza Roma 19, 32045 S. Stefano di Cadore (BL), Italy. Is a leading European company active in the fields of engineering, design and project management.
Smart Environment Solutions - SES, with registered office at UI. Svetlane Kane Radević 3, 81000 Podgorica, Montenegro. Is a leading European company in the field of provision of up-to-date, innovative and technologically advanced approaches and solutions fostering environmental preservation and improvement, and sustainable development.
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 43 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
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8.2 References – list of written materials and study visit report used in study preparation
8.2.1 Policy, legal, and administrative framework
National regulations
Rule book on detailed content of documentation to be submitted when applying for waste import/transit/export License, and list of waste classification ("Official Gazette of Montenegro", no. 71/10)
Rule book on keeping records of the waste and content of the document for waste transportation ("Official Gazette of Montenegro", no. 50/12)
Law on transportation of hazardous materials ("Official Gazette of Montenegro", no. 33/14)
Law on sea protection from pollution caused by vessels ("Official Gazette of Montenegro", no. 20/11 and 26/11)
Law on maritime safety ("Official Gazette of Montenegro", no. 62/13)
Law on Spatial Planning and Construction ("Official Gazette of Montenegro", no. 51/08, 34/11, 40/11, 47/11, 35/13, 39/13 and 33/14)
Environmental Protection Law ("Official Gazette of Montenegro", no. 48/08, 40/10, 40/11 and 62/13),
Regulation on method of preparation, scale and detailed contents of the technical documentation ("Official Gazette of Montenegro", no. 23/14)
Regulation on detailed content and manner of drawing up a waste management plan by waste producers ("Official Gazette of Montenegro", no. 5/13)
Regulation on packaging and removal of asbestos-containing waste ("Official Gazette of Montenegro", no. 11/13)
Regulation on waste classification and Waste Catalogue ("Official Gazette of Montenegro", no. 59/13)
Rulebook on construction waste management, manner and method of construction waste treatment, conditions and manners of disposal of cement asbestos construction waste ("Official Gazette of Montenegro", no. 50/12)
Law on Occupational Health and Safety ("Official Gazette of Montenegro", no. 34/14)
The waste management plan as developed by the shipyard (October 2014) approved by the Agency for Environmental Protection (02 No. UPI-164/04 of 20/11/2014).
The law on the of Environmental Impact Assessment ("Official Gazette of Republic of Montenegro", no. 80/05, "Official Gazette of Montenegro", no. 40/10, 73/10, 40/11, 27/13)
Directives and regulations of the European Union in the field of waste management
Directive 2008/98/EC on waste
Directive 91/689/EEC on hazardous waste (as amended by Directive 94/31/EC and Regulation (EC) 166/2006)
Regulation (EC) No 1013/2006 on shipments of waste
International permits, notifications and/or certifications
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 44 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
World Bank Policies and Guidelines
“Operational Policy/Bank Procedure (OP/BP) 4.01 Environmental Assessment “OP/BP 4.04 Natural Habitat”. The objective is to promote environmentally sustainable development by supporting the protection, conservation, maintenance and rehabilitation of natural habitats and their functions.
“OP/BP 4.09 Physical Cultural Resources”
“OP/BP 4.12 Involuntary Resettlement”
“OP/BP 4.37 Safety of Dams”
OP/BP 7.05 Projects on International Waterways”
8.2.2 Plans, programs, studies and projects
Internal document (2008): Analysis and characterization of the grit
CETI (20 Sep. 2011): Grit,vol. I-III in the context of research CDM Europe GmbH-Alsbach – Germany /Hidroinžinjiring Ltd Ljubljana-Slovenia
Internal document (2011): Environmental protection study, vol. 1
Internal document (2012): Brodogradiliste Bijela, Shipyard Bijela - Short description
COWI A/S (2012): Environmental and Social Impact Assessment of Remediation of Five Contaminated Sites. World Bank ESIA and safeguard studies for contaminated industrial sites remediation for Ministry of Sustainable Development and Tourism, Environmental Protection Agency
Consortium CDM Europe & Hidroinženiring (2013); Site Investigations and Preparation Study for the Remediation of Industrial Waste Disposal Sites in Montenegro - Final report, Ministry of Sustainable Development and Tourism, Environmental Protection Agency Montenegro, Podgorica
CETI (2015): Site investigations (sampling and testing) at Bijela Shipyard
Tauw & Witteveen+Bos (2016): Remediation works in Bijela shipyard Technical specifications with ESIA and EMP
CETI (2016): Testing of soil and groundwater at the site of the Adriatic shipyard a.d. Bijela for the purpose of making a "zero" state
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 45 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
8.2.3 Consultant’s Site visit on 1st July 2016
The Consultant’s site visit to the Shipyard “Bijela” has allowed to take vision of the general state of the places, the typologies of abandoned waste in the area and the conditions of the blasting grit still stored in big bags.
Figure 4. Bijela shipyard location
Access to the location is enabled by an asphalt road, which connects to the main road Risan-Herceg Novi. Figure 5 shows the interior of the location of the blasting grit storage and contaminated soil.
Figure 5. Internal area of the Bijela shipyard
Therefore, the Consultant visited the old blasting grit stored in piles in specific areas named A, B, C and the new blasting grit stored in piles (areas D, E). In addition, visit also included the derelict dumping areas N and S and a general internal and external visit of the sheds facing the port area.
The state of general abandonment of the site has brought the accumulation of wastes of various nature variously disposed in the area and composed mainly by metals, plastics, inerts, pallets, ropes etc
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 46 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
Regarding the blasting grit, it is evident an overall deteriorating condition of the fabric that constitutes the big bags, the totality of the bags are ripped and in this condition they cannot be handled any further. This condition is common to all the bags.
Figure 6. Blasting grit bags stored at the Bijela shipyard
The blasting grit is then exposed to weathering and washed out by the rains and exposed to the winds and therefore, causing soil contamination.
Figure 7. Contaminated soil
The former storage areas of the material N and S located near the coast are unobstructed except for the presence of heterogeneous waste spread on land. Located at the borders of the same area there is still a deposit of metal bins containing waste oil.
Within the area N, it was taken vision of a piezometer placed in proximity of the coast line that has shown the presence of supernatants hydrocarbons in its interior.
The inspection visit was completed outside and inside the sheds placed along the south-west pier, some this are currently used and generally in good structural condition.
In the area of the site and in its vicinity there are no areas that are protected in terms of cultural and natural resources. On the site there are objects that are built with a serving ship repair shipyard services, and part of it is scheduled for demolition. The broader surrounding area is residential and of business nature, as well as tourist, so it could be said that such area has a higher density.
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 47 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME
Updated ESIA and EMP for Bijela Shipyard
8.3 Public consultation – Minutes
Development of Environmental Impact Assessment Elaborate and update of Environmental and Social Impact Assessment report of the Shipyard "Bijela” contaminated soil and blasting grit waste 48 REFERENCE NO.#: MNE-IWMCP-8428-CQ-CS-16-1.3.6.2 LOAN NO. 8428-0 ME