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NGO Breznica - POLUTION IN PLJEVLJA Case of the Thermal Power Plant

The “Greater Government Transparency and Accountability" project is supported by the European Union and implemented by MANS with five project partners. This Report was developed with the assistance of the European Union. The NGO Breznica bears sole responsibility for its contents and it does not reflect the official position of the EU. The Report is part of the NGO Breznica – Pljevlja

“Greater Government Transparency and Accountability“

Project implemented by

POLLUTION IN THE MUNICIPALITY

OF PLJEVLJA

The Thermal Power Plant Case

Sigurna ženska kuća

December 2014

Supported by

This Report was developed with the assistance of the European Union within the framework of the “Greater Government Transparency and Accountability" project, implemented by MANS with five project partners. The NGO Breznica bears sole responsibility for its contents and it does not reflect the official position of the European Union. TABLE OF CONTENTS

INTRODUCTION 3

1. GENERAL FEATURES OF THE MUNICIPALITY OF PLJEVLJA 3

2. THERMAL POWER PLANT – SINGLE LARGEST POLLUTER OF PLJEVLJA? 4

2.1. The Thermal Power Plants’ adverse environmental impact 5

NGO Breznica’ initiative towards the Parliament due to the environmental 2.2. 6 disaster following the Thermal Power Plant’s repair

2.3. Thermal Power Plant’s impact on public health 7

NGO Breznica’s initiative with the Parliament due to the lack of information 2.4. 7 on the impact of the pollution on public health

2.5. Problems with the reservoirs 8

3. INSTITUTIONAL TRANSPARENCY 9

4. CONCLUSIONS AND RECOMMENDATIONS 10

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INTRODUCTION

This Report is produced within the framework of the project implemented by six nongovernmental organisations: the Network for the Affirmation of the Nongovernmental Sector (MANS), the Safe Home for Women, Mogul, Stečajci u Crnoj Gori (Workers from Bankrupt Companies in ), Breznica, and the Youth Association of Montenegro.

Within the framework of the project, the NGO Breznica is monitoring the implementation of the Free Access to Information Law (FAI Law) by the state authorities responsible for environmental protection, as well as the actions taken by the responsible institutions to protect the environment and public health in Pljevlja.

This Report contains the information on general geographic and climate features of the Municipality of Pljevlja, on the Thermal Power Plant (TPP) and the industrial waste it generates, as well as the TPP impact on the environment and public health. The Report also provides the information on the procedures instigated by the NGO Breznica before the responsible institutions, as well as the data on the transparency of institutions responsible for providing information on the thermal power plant operation.

Some of the data for drafting this report were collected based on the information gathered from 12 state institutions, obtained through the requests filed under the FAI Law. Other data were obtained from the official documents on the state of the environment posted on the websites of the Environmental Protection Agency (EPA) and the Ministry for Sustainable Development and Tourism, the analyses provided by relevant nongovernmental organisations in Montenegro, from the press and other online sources, and in direct communication with health experts who wished to remain anonymous.

1. MAIN FEATURES OF THE MUNICIPALITY OF PLJEVLJA

The Municipality of Pljevlja is located in the northernmost part of Montenegro, at the border with and with . The municipality covers the territory of 1,346 km 2, thus being the third largest in Montenegro . The town of Pljevlja is located in a 6 km wide and 9 km long valley, along the Ćehotina river, surrounded by mountain slopes.

The major polluters, the Thermal Power Plant (TPP) and the open-pit Coal Mine, are located on the verge of the town, within the valley. At the same time, these are major employers within the municipality struggling with a high unemployment rate of 22%1 almost twice as high as the national average 2.

The municipality is one of the wealthiest in the country judging by the natural resources it disposes of: ore, wood and minerals. The largest deposits of lead, coal, zinc, copper, marble, mercury, etc. are found within the territory of this municipality. Agricultural land accounts for a large share of the municipal territory, close to 70,000 m 23.

The municipality is affected by grave depopulation . According to the 2011 census, the total population of Pljevlja was 30,786, and 40 years ago it had 50% more inhabitants or 46,667 4. Pljevlja ranks first in Montenegro by the negative population growth of – 2425.

1 In August 2014. 2 CDM, Pljevlja lider u nezaposlenosti (Pljevlja – Champion of Unemployment), Podgorica, 19 August 2014: http://www.cdm.me/ekonomija/pljevlja-lider-u-nezaposlenosti 3 The data taken from the official web pages of the Municipality of Pljevlja, http://www.pljevlja.me/ 4 The data taken from the websites of the National Statistical Office (Monstat) and the Air Quality Plan for the Municipality of Pljevlja http://www.monstat.org/userfiles/file/popis2011/saopstenje/saopstenje(1).pdf 3 of 10

According to the information featured in the Air Quality Plan for the Municipality of Pljevlja, prepared by the Ministry of Sustainable Development and Tourism (MSDT) together with the Environmental Protection Agency (EPA) and the Municipality of Pljevlja in February 2013, an upward trend in the number of foggy days was noted from 1974 onwards, when the construction and putting online of major industrial facilities in Pljevlja started 6.

Given its location in the flatlands encircled by hills and mountains, there is not much air circulation, resulting in windless climatic conditions. Pljevlja is covered in fog up to 200 days a year .

All of the above, the climate and geographic features in conjunction with the sources of pollution within the municipality, have an adverse impact on the air quality in Pljevlja. Figure 1: Pljevlja in fog

2. THE THERMAL POWER PLANT – SINGLE LARGEST POLLUTER IN PLJEVLJA?

Pljevlja is the municipality in Montenegro with the highest levels of water, air and soil pollution. Moreover, Pljevlja is the most polluted town in the whole of Europe.7

One of the largest polluters in Pljevlja, together with the Coal Mine , is the Thermal Power Plant (TPP) Pljevlja put online in early 1980s 8.

The TPP Pljevlja is the main generator of industrial waste. The total annual production of waste for the territory of Pljevalja is about 571,000 tons, out of which there are 280,000 to 300,000 tons of ash from burning coal used for firing the power plant. In the 30 years of its operation, the power plant has burnt close to 35 million tons of coal, at the same time disposing 12 million tons of ash and slug waste . The rest of the waste generated includes waste oil, heavy fuel oil, waste paint, mud and other types of waste.9

Huge amounts of slug and dust from the furnace are not classified as hazardous waste, but do require special handling. Numerous analyses have shown increased levels of metals, fluorine and boron above the maximum allowable limits.10 Increased radioactivity levels have also been recorded, but these remain below the maximum allowable limits. 11 The Centre for Eco-toxicological Testing (CETI) has carried out the classification of ash, categorising it as hazardous waste due to the high pH value, one of the criteria for assessing the quality of drinking and surface waters. 12

5 RTCG, U 8 opština negativan prirodni priraštaj (Negative Population Growth in 8 ), Podgorica, 23 April 2014: http://www.rtcg.me/vijesti/drustvo/49263/u-8-opstina-negativan-prirodni-prirastaj.html 6 The data taken from the Air Quality Plan for the Municipality of Pljevlja 7 Radio Free Europe, Pljevlja: (Entering the most polluted town in Europe only if wearing protective aids) U najzagađeniji evropski grad samo sa zaštitnom opremom, Podgorica, 20 December 2014 8 Taken from the document “Information on the TPP II project” from the official website of the Government of Montenegro https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&ved=0CCkQFjAA&url=http%3A%2F%2F www.gov.me%2FResourceManager%2FFileDownload.aspx%3FrId%3D137825%26rType%3D2&ei=1cWyUsPkPJP2ygO53YGw Dg&usg=AFQjCNHSQYN_QEgxnK3T3kMg2e1Hp-pjFw&sig2=tAurk2Ipmp2GzVxnTdNyow&bvm=bv.58187178,d.Yms 9 NGO Green Home, Analiza uticaja Termoelektrane Pljevlja na stanovnike Pljevalja sa predikcijom uticaja drugog bloka TE Pljevlja na zdravlje (Analysis of the TPP impact on Pljevlja residents with the prediction of the TPP Block II influence on public health in Pljevlja), Podgorica, December 2013: http://www.greenhome.co.me/fajlovi/greenhome/attach_fajlovi/lat/glavne- stranice/2014/11/pdf/Analiza_uticaja_TE_Pljevlja_sa_predikcijom_uticaja_drugog_bloka_TE_na_zdravlje.pdf 10 Ibid 11 Ibid 12 Ibid 4 of 10

Ash and slug are disposed of at the Mаljevаc site, already holding eight million tons of this waste. At the site, there is an increased risk of the dam collapsing given the existing cracks and the increasing hydrostatic pressure, as well as the low safety coefficient in case of a strong earthquake, which could lead to liquefaction (the phenomenon which causes lateral stretching of soil) of ash and partial or total collapse of the dam. 13

Dispersion of dust from the disposal site by winds happens mostly in summertime , when the surface is dry and the winds blow from the mountains, some settlements are located in the immediate vicinity to the ash disposal, exposing the nearby population and land to the ash coming from the disposal site.

2.1. Adverse impact of the TPP on the environment

The official data show that the TPP Pljevlja annually, on average, consumes over 1,3 million tons of coal, 3,500 tons of heavy fuel oil, and 660 tons of various chemicals, such as lime, hydrochloric acid, lye and others. Since the beginning of its operation, the total of 45 million tons of coal was extracted from the open pits of the Coal Mine. 14

Depending on the type and the place of extraction, coal contains many other compounds Particulate matter PM 10 falls among in different amounts. When burning coal, dry the most dangerous pollutants . It particulate matter is released, mostly composed consists of very small particles in of carbon, silica, aluminium and iron oxides, as liquid or solid form. Due to their well as suspended ash, and various gases are also small diameter, less than 1/7 of the released: carbon dioxide, sulphur oxides, nitrogen diameter of a human hair, when oxides, carbon monoxide, hydrocarbons and other. inhaled they can reach the furthest parts of lungs . The pollutants mostly damaging the air in Pljevlja are the particulate matter PM 10, or PM 10 cause or aggravate asthma, powdery matter less than 10 µm in diameter, bronchitis and other lung diseases, sulphur(IV)oxide (SO 2), carbon (II) oxide better and thus reduce the overall body known as carbon monoxide (CO), nitrogen(II)oxide resistance. PM 10 have a particularly (NO), nitrogen oxides (NO x) and other. detrimental effect on children, pregnant women, the elderly and ill The 2013 Report issued by the Environmental people. PM 10 reduce visibility during Protection Agency (EPA) states that the mean day the day, since they create the values for PM 10 during 177 days (out of 337 days effects typical of mist often of valid measurements) exceeded the set limit recognised as smog 15 . value of 50µg/m3, going above the tolerance level during 85 days . According to the Decree on Determining the Type of Pollutants, the Limit Values and Other Air Quality Standards, upper limits must not be exceeded more than 35 times within one calendar year 16 .

In 2013 the mean annual value of 79.51µg/m3 was above the set limit value (40µg/m3) and the tolerance level (50µg/m3).

In its report, the EPA states that, based on the measured values, it may be concluded that the air in Pljevlja is heavily polluted with PM 10 , not only as regards the values measured, but also the number of days with the maximum values exceeded.

13 Ibid 14 Ibid 15 The information from the official website of the Faculty of Chemistry in Belgrade http://www.chem.bg.ac.rs/~grzetic/predavanja/Osnovi%20hemije%20atmosfere%20i%20zagadjivaci%20vazduha/SUSPEND OVANE%20I%20RESPIRABILNE%20CESTICE%20U%20URBANIM%20SREDINAMA.pdf 16 the Decree on Determining the Type of Pollutants, the Limit Values and Other Air Quality Standards (Official Gazette of Montenegro 25/2012) 5 of 10

Moreover, the thermal power plant causes also water pollution. Apart from the effect of precipitation on the coal and ash deposits, the pollution results also from the discharges of waste water, which may be chemically polluted and oily.

2.2. NGO Breznica’ initiative towards the Parliament due to the environmental disaster following the TPP repair

On 01 July 2014, yet another in a row of huge pollutions, now becoming already customary, occurred from the TPP Pljevlja funnel. After the scheduled repair that lasted for 40 days, the TPP was put in operation on 01 July and around 3 pm heavy black smoke started emanating from the funnel, dispersed by the wind, which later settled above the town and its surrounding. In the neighbourhoods closer to the power plant, this was accompanied by poignant smell, and some areas were also covered in ash.

Given the absence of any response by the responsible institutions and no measures taken to protect the citizens against further pollution, in July 2014 the NGO Breznica filed an initiative with the parliamentary Committee for Tourism, Agriculture, Environment and Spatial Planning asking for a control hearing of the Minister of Sustainable Development and Tourism, the EPCG Executive Manager, the EPA Director, and the CETI Director. The Committee was asked to adopt the conclusions that would highlight the existence of responsibility of the above persons for the air pollution in Pljevlja, for flooding of the area downstream of the Otilovići reservoir, and endangering public health and the environment.

Figures 2 and 3: The black smoke emanating from the power plant

Unfortunately, this has not been the first similar incident when the TPP Pljevlja boilers are re-fired, but none of the responsible institutions has ever responded or taken any specific steps to protect the citizens and the environment against further pollution.

The NGO Breznica informed the EPA, the Ministry of Sustainable Development and Tourism and the Environmental Inspectorate of this incident and requested their prompt actions. However, following this we received a very disconcerting response from the EPA and the Ministry that the measuring stations did not record any pollution at any of the sites in Pljevlja.

The NGO Breznica believes that enormous pollution was caused by burning over 200,000 litres of heavy fuel oil in the thermal power plant within the span of several hours only, and the reason for this not to be recorded at the measuring stations should be sought in the fact that these record PM 10 and PM 2.5, thus probably the burning of heavy fuel oil caused larger diameter particles, remaining undetected by the stations, but easily visible by naked eyes. 6 of 10

This only confirms what we have been alleging for years that the air pollution measuring station in Pljevlja is practically unusable, and improperly sited, under a hill, among buildings, open from one side only (Skerlić Street).

2.3. The Thermal Power Plant’s impact on public health

No study has ever been done, following strict scientific methodologies, to assess the impact of the TPP-caused pollution on public health in Pljevlja. Hence, the information received from mandatory health statistics on the number of diseases, mortality rates, the state of health and injuries is indicative at best, and may only be used for ahving a general impression.

It is also noteworthy that Montenegro has no reliable annual data on the number of new cases and the total number of malign tumour cases, given the absence of population surveys or cancer cases registers.

For many years now the expert services of healthcare institutions in Pljevlja have been pointing out to the disconcerting impact of pollution on public health, particularly the increase in respiratory diseases, primarily among children. Both among children and adults, among all respiratory diseases, the particularly prominent and on the increase are the obstructive syndrome and asthma.17

The most susceptible to environmental pollution are children, senior citizens, pregnant women and people suffering from chronic diseases. Pljevlja has seen a substantial increase in the number of cases of bronchitis, asthma, pneumonia, chronic lung diseases, major harmful impacts on blood and bone marrow, lymph glands, then more frequent allergies and immune system diseases. The increase of various skin and bone diseases, blood pressure and cardiac diseases, then impact on reproductive health through sterility, miscarriages, premature births, foetus anomalies, low birth mass, brain damage during foetal development, harmful behavioural effects seen through irritability and aggression, and environmental discomfort have also been observed.

2.4. NGO Breznica’s initiative with the Parliament due to the lack of information on the impact of the pollution on public health

In order to prompt the state institutions into action and addressing numerous environmental problems in the Municipality of Pljevlja, and to determine and publish the information of long-lasting adverse impact of pollution on public health, the NGO Breznica, together with the NGOs MANS and the Green Home, submitted an initiative to the parliamentary Committee for Tourism, Agriculture, Environment and Spatial Planning to hold, together with the Committee for Health, Labour and Social Welfare, a control hearing of the representatives of responsible institutions to obtain relevant information on the impact of pollution on the public health.

Although the data on the environmental pollution in Pljevlja and the impact on public health are alarming and notwithstanding the fact that Pljevlja is the most polluted town in this country, the Government keeps ignoring the environment and public health issues in Pljevlja.

The fact that, despite the evident increase in the number of cases of respiratory diseases and cancer highlighted on several occasions by the Primary Healthcare Centre, no retrospective or prospective scientifically-based research of the impact of TPP-caused pollution on public health has never been done is particularly disconcerting. No study has

17 Air Quality Plan for the Municipality of Pljevlja , the Ministry of Sustainable Development and Tourism, 2013 7 of 10 ever been done either of the impact of air pollution on public health in Pljevlja, although, according to the WHO, the pollutants are the leading cause of lung cancer.

According to anecdotal evidence obtained from professionals, each year Pljevlja has another 500-600 cancer cases. However, there are no official data on the impact of pollution on public health, and it is quite possible these would reveal that an even greater number of residents of Pljevlja are being treated in the neighbouring countries. The relevant institutions state that the registers of malign and other chronic diseases was introduced for the first time in 2013, and that it is still early for giving precise data; the setting of the register was announced already in 2010.

The NGO Breznica submitted its initiative to the parliamentary Committee for Tourism, Agriculture, Environment and Spatial Planning in November 2014, but it has not been considered yet, and no actions have been taken to assess the facts of the case.

2.5. Problems with the reservoirs

The power utility Elektroprivreda Crne Gore A.D. Nikšić (EPCG) holds a majority stake in the TPP Pljevlja. As such, the EPCG was obliged to carry out environmental protection measures. This has not been the case, and the air pollution is not the only problem posed by the power plant to the citizens of Pljevlja.

In addition, the Ćehotina River regularly floods the estates downstream of Pljevlja, since the EPCG, due to great inflow, releases the water from the Otilovići reservoir, used for the thermal power plant needs.

In April 2014, the flooding occurred again. This has on several occasions destroyed the farming land of several farmers in the villages of Ševari and Židovići, and the local Pljevlja – Šula road was also flooded on several occasions.

Figures 3 and 4: Flooded estates

The EPCG says they are not responsible for flooding of the area, stating that it happens due to abundant rainfall and lack of regulation to the Ćehotina river bed. This is very unlikely given that the flooding occurred even at the time when the river bed was dredged and when the so called riverbed regulation was done. The inhabitants of Ševari witnessed the water coming in surges from the released dam, while the citizens of Pljevlja claim to have seen people at the Otilovići reservoir dam opening the two spillways to prevent overtopping.

The Committee for Tourism, Agriculture, Environment and Spatial Planning has as yet not taken any action as per the initiative we filed nor taken any actions to examine the facts of the case.

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3. INSTITUTIONAL TRANSPARENCY

For the duration of the project over the last two years the NGO Breznica, in cooperation with the partner organisation NGO MANS, filed 35 requests for information referring to the Thermal Power Plant.

The requests were sent to 12 different institutions: the Ministry of Economy, the Ministry of Finance, the Basic Court Plevlja, the Real Property Administration, the Tax Administration, the Ministry of Sustainable Development and Tourism, the Finance Secretariat of the Municipality of Pljevlja, the Regulatory Energy Agency, the General Secretariat of the Government of Montenegro, the Environmental Protection Agency, the Ministry of Justice and the National Power Utility (EPCG).

Out of the 35 requests Nema informaciju filed with 11 3% 3% 3% 11% institutions, in one 3% Nije nadležan third of the cases the institutions stated they Dozvoljeno were not responsible for the given matter. Djelimično 29% For one in nine dozvoljen requests the Zabranjen institutions did not hold the information 48% Već objavljen requested, with the information actually being provided in Ćutanje almost a half of all the administracije cases.

Chart 1: Responses per the requests filed

Although access to information was allowed in close to one half of all the cases, there are certain problems in the implementation of the FAI Law even when access is allowed. Namely, following the payment of costs for accessing information held by the EPCG, this company started with the obstructions in the provision of data by posing some administrative requirements not recognised by the FAI Law.

In addition, the relevant state authorities fail to provide the key information that might assist in having a full picture of the impact the TPP has on the environment and the public health, both now and in future, with the envisaged construction of the 2 nd Block.

In addition, some institutions provided the information in the form different than the requested one, thus making it impossible to analyse such information or obtain any specific piece of information which prompted us to request the documents in the first place.

4. CONCLUSIONS AND RECOMMENDATIONS

Through monitoring the work of the responsible institutions for environmental protection and public health in Pljevlja, that the NGO Breznica conducted over the last two years, there is an evident absence of proper actions of the responsible institutions to prevent

9 of 10 environmental pollution, as well as the absence of any response in case of environmental incidents.

The institutions responsible for the environment do not hold such information on the air pollution levels in Pljevlja. According to the official data, measuring stations are often out of order or due to technical failures the equipment rests idle and is not being used properly or the equipment fails to register all forms of pollution.

Moreover, despite the evident increasing trend of respiratory diseases and cancer in Pljevlja, no study has ever been done to assess the impact of the thermal power plant on the public health. No study on the impact of pollution on the health of the inhabitants of Pljevlja has been done either, although, according to the World Health Organisation, air pollutants are the main cause of the lung cancer.

Montenegro lacks reliable annual data on the number of newborns and the total number of people suffering from malign tumours, given the absence of population surveys or any registers of cancer diseases. The responsible authorities say that registers of malign and other chronic diseases were introduced in 2013 only, and that it is still early to give precise data.

Finally, although the institutions show readiness to allow access to the information relating to the thermal power plant, nevertheless the bulk of key data is unavailable. Also, the authorities and the EPCG obstruct access to information by placing administrative barriers or by providing the information in the form different from the requested one, preventing the analysis of such information or obtaining any concrete information for which the documents were requested in the first place.

Given the above, we propose to the Environmental Protection Agency and the Ministry of Sustainable Development and Tourism to urgently:

1. undertake measures to reduce air pollution and prevent further environmental disasters in Pljevlja caused by the TPP;

2. improve the pollution monitoring system in Pljevlja in order to register particles of larger diameters inevitably generated during ecological incidents;

3. ensure the development of a study on the impact of the pollution caused by the TPP to public health;

4. publish the information on the number of new cases and the total number of people suffering from tumours in Pljevlja and keep an updated register of such diseases;

5. proactively publish the information relating to environmental pollution, the measures undertaken to protect the environment, and the information on large polluters, primarily the Thermal Power Plant and the Coal Mine Pljevlja.

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