Development of Environmental and Social Impact Assessment Report of the Planned Remediation Activities on Coal and Ash Disposal Facility

Development of Environmental and Social Impact Assessment Report of the Planned Remediation Activities On coal and Ash Disposal Facility

Pljevlja, Montenegro

Environmental and Social Impact Assessment Report First Draft

DECEMBER 2018

TABLE OF CONTENTS

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LIST OF TABLES viii LIST OF FIGURES x LIST OF ABBREVIATIONS xii

1. INTRODUCTION 1.1. Project Background and Purpose 1-1 1.1.1. Location and Description of the Coal and Ash Disposal 1-3

Facility (Maljevac Landfill) 1.1.2. Technology and Current Condition of the Landfill 1-4 1.2. Project Formulation Structure 1-7 1.2.1. Overview of the Project 1-7 1.2.2. Overview of the Project Plus 1-8 1.2.3. Dynamics and Timing of Reclamation Works 1-9 1.3. Applicable EIA and ESIA Procedures and Status 1-10 1.4. Scope and purpose of the ESIA Report and ESMP 1-11 1.5. Structure of the ESIA Report 1-12

2. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK 2.1. Legal Framework for Environmental Protection and Conservation 2-1 2.2. Legal Framework for Health and Safety 2-2 2.3. Legal Framework for Expropriation and Resettlement 2-2 2.4. Montenegrin/European Environmental Legislative and Permitting 2-2

Framework 2.4.1. EU Directives 2-2 2.4.2. Horizontal Legislation 2-3 2.4.3. Nature Protection 2-4 2.4.4. Air Quality 2-4 2.4.5. Waste Management 2-5 2.4.6. Water Quality 2-5 2.4.7. Industrial Pollution 2-5 2.5. National EIA Procedure 2-6 2.6. International Environmental and Social Regulatory Framework 2-7 2.6.1. International Treaties and Conventions 2-7 2.6.2. World Bank Group Environmental and Social Framework and 2-8

Safeguard Policies 2.6.3. Gaps between the World Bank OP 4.01 and Montenegrin EIA 2-10

Procedure

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2.6.4. Good International Industry Practice 2-12

3. PROJECT DESCRIPTION 3.1. Remediation/Recultivation of Cassette II 3-2 3.1.1. Top Cover System for Cassette II 3-4 3.1.2. Landscape Design 3-7 3.2. Relocation of the Paleški Stream 3-8 3.3. Reclamation and Recultivation of the 4th and 5th Step and Construction 3-14

of the Precipitator 3.4. Leachate Management 3-15 3.4.1. Leachate Collection 3-15 3.4.2. Leachate Handling 3-17 3.5. Drainage Works and Flood Control 3-17 3.6. Personnel Requirements 3-18 3.7. Machinery and Equipment Requirements 3-19 3.8. Project Schedule 3-19

4. ENVIRONMENTAL AND SOCIAL BASELINE CONDITIONS 4.1. Study Area and Sources of Baseline Information 4-1 4.1.1. Potential Area of Influence of the Project 4-1 4.1.2. Sources of Baseline Data 4-2 4.2. Characteristics of the Physical Environment 4-2 Topography, Geology, Hydrogeology and Hydrology of the 4.2.1. 4-2 Region 4.2.1.1. Topography 4-2 4.2.1.2. Geology 4-3 4.2.1.3. Hydrogeology 4-4 4.2.1.4. Hydrological Characteristics 4-6 4.2.2. Erosion and Land Use 4-7 4.2.3. Climate 4-8 4.2.4. Seismicity 4-9 4.3. Quality of Physical Environment 4-9 4.3.1. Water Quality 4-11 4.3.2. Soil Quality 4-14 4.3.2.1. Soil Quality in the Area of Municipality Pljevlja 4-14 4.3.2.2. Soil Quality in Komini and Zabrdje Villages 4-15 4.3.2.3. Soil Quality around the Maljevac Landfill 4-16

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4.3.2.4. Ash and Slag Quality 4-17 4.3.3. Air Quality 4-17 4.3.3.1. Air Quality Monitoring in Pljevlja in the Period 2014 – 4-18 2018 4.3.3.2. Air Quality Monitoring in the Vicinity of Maljevac 4-19

Landfill 4.3.4. Noise 4-20 4.3.5. Waste Generation 4-20 4.3.6. Landscape Features 4-21 4.3.7. Radioactivity 4-22 4.4. Biological Environment 4-23 4.4.1. Nature Protection and Key Biodiversity Sites 4-24 4.4.2. Terrestrial Flora and Vegetation 4-26 4.4.3. Terrestrial Fauna and Habitats 4-27 4.4.4. Aquatic Fauna 4-29 4.5. Socioeconomic Environment 4-29 4.5.1. Settlements 4-29 4.5.2. Demographic Characteristics 4-30 4.5.3. Employment 4-29 4.5.4. Education 4-30 4.5.5. Vulnerable Groups 4-30 4.5.6. Health and Social Security 4-30 4.5.7. Social Infrastructure and Services 4-31 4.5.8. Economy in the Municipality of Pljevlja and Livelihoods 4-33 4.5.9. Affected Settlements by the Project 4-33 4.6. Protected Areas and Cultural Heritage and Assets 4-35

5. ENVIRONMENTAL AND SOCIAL IMPACTS 5.1. Area of Influence and Impact Assessment Approach 5-1 5.1.1. Area of Influence 5-1 5.1.2. Impact Assessment Approach 5-1 5.2. Impacts on Physical Environmental Characteristics 5-4 5.2.1. Impact on Hydrogeology and Hydrology 5-4 5.3.2. Impacts on Erosion, Landslide and Land Use 5-5 5.3. Impacts on Physical Environmental Quality 5-5 5.3.1. Impacts on Water Quality 5-5 5.3.2. Impacts on Soil Quality 5-6

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5.3.3. Impacts on Air Quality 5-7 5.3.4. Impacts of Noise 5-9 5.3.5. Impacts of Waste Generation 5-11 5.3.6. Impacts on Landscape Characteristics 5-12 5.3.7. Impact of Radioactivity 5-13 5.4. Impacts on Biological Environment 5-14 5.4.1. Impacts on Nature Protection and Key Biodiversity Sites 5-14 5.4.2. Impact on Ecosystems 5-14 5.4.3. Impact on Flora and Fauna 5-14 5.5. Impacts on Socio-economic Environment 5-15 5.5.1. Impacts on the Local Population 5-15 5.5.2. Impacts on Economy and Livelihoods 5-16 5.5.3. Impacts on Local Public Infrastructure 5-17 5.5.4. Community Health and Safety 5-17 5.6. Impacts on Cultural Heritage 5-17 5.7. Occupational/Workers Health and Safety (HS) 5-17 Summary of the Environmental and Social Impacts and Mitigation 5.8. 5-18 Measures

6. PROJECT ALTERNATIVES 6.1. No Action/ Project Alternative 6-1 6.2. Alternative Projects for Remediation and further Operation of the 6-1

Maljevac Landfill 6.3. Method/Technology Variants/Options for the Selected Project 6-2

Alternative 6.3.1. Comparison and Assessment of Alternatives 6-5 6.3.2. Risk of Delays and Associated Recontamination of the 6-6 Remediated Sites 6.4. Variant Solutions for Relocation of Paleški Stream 6-7 6.5. Rehabilitation Technology/Method Variants for Cassette II 6-8

7. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) 7-1

8. PUBLIC PARTICIPATION AND INFORMATION DISCLOSURE 8.1. Previous Public Consultation Activities 8-1 8.1.1. Public Consultation for ESIA of Remediation of Five 8-2 Contaminated Sites

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8.1.2. Public Consultations regarding the Draft Detailed Spatial Plan (DSP) for TPP Pljevlja and the Draft Strategic 8-4 Environmental Impact Assessment Report (SEA) 8.1.3. Public Consultation for EIA Elaborate 8-5 8.1.4. Public Consultation for RAP 8-6 8.1.5. Meeting with the Representative of village Zbljevo 8-6 8.2. Public Consultation after Completion of the Draft ESIA/ESMP 8-7

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APPENDICES

Appendix 1 – List of Preparers

Appendix 2 – Relevant Regulations

Appendix 3 – Project Maps – General Layout – Drawings Related to Project Units

3.1. Site review of the current status 3.2. Site review of the 5th step 3.3. Site review of the drainage cover 3.4. Site review of Cassette II including the profile view – peripheral channel 3.5. Technical recultivation of Cassette II channel 3.6. Biological recultivation of Cassette II channel - grass covering 3.7. Biological recultivation of Cassette II channel - formation of a protective zone 3.8. Biological recultivation of Cassette II channel - afforestation 3.9. Site map with overview of the measuring locations

Appendix 4 – Surface and Groundwater Analyses Results

4.1 Report on Physical and Chemical Testing of Surface Waters (Paleski Stream) no.360 / 04/1 Center for Ecotoxicological Tests Podgorica, June 2018 4.2 Report on Physical and Chemical Testing of Groundwater no.358 / 04/1 Center for Ecotoxicological Tests Podgorica, June 2018

Appendix 5 – Soil Quality Analyses Results

5.1 Report on physical-chemical waste analysis no. 366/04/01, Center for Ecotoxicological tests Podgorica, June 2018 5.2 Report on physical and chemical soil testing no. 364/04/1, Center for Ecotoxicological tests Podgorica, June 2018

Appendix 6 – Annexes of Regulation on determination of the Types of Pollutants, Threshold Values and other Air Quality Standards ("Official Gazette of Montenegro", 25/2012)

Appendix 7 – Indicative Measurements of Air Quality in the Area of Ash and Slag Landfill Maljevac, Report no. 1256/1, Center for Ecotoxicological tests Podgorica, June 2018

Appendix 8 – Map of the Acoustic Zone in the Municipality of Pljevlja In relation to the Location of the Maljevac Landfill

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Appendix 9 – Flora-Fauna Species Lists and Photographs

9.1 List of Vascular Plants 9.2 List of Insects: 9.3. List of Birds 9.4. List of Mammals 9.5. List of Fishes

Appendix 10 – Landscape Restoration Plan

10.1 Typical pattern of plant crop layouts in the protective circumferential zone 10.2 Typical schematic diagram of plant crops 10.3 Park cassette 2 with positions of bench and signs

Appendix 11 – Institutional Arrangements for Implementation of the ESMP and Emergency Action Planning Framework

Appendix 12 – Public Participation Meeting Records

12.1 Minutes / List of participants - Public consultation for ESIA of Remediation of Five Contaminated Sites (10/04/2012) 12.2 Minutes, Second Public Consultation (12.07.2012) 12.3 Minutes / List of participants - Public consultation for EIA Elaborate (9/11/2016) 12.4 Minutes / List of participants - Public consultation for RAP (29/05/2018) 12.5 Minutes / List of participants - Meeting with the representative of village Zbljevo (11/09/2018)

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LIST OF TABLES

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Table 1.1 Reclamation Phases 1-9 Table 2.1 Gaps between the World Bank OP 4.01 and Montenegrin EIA 2-10 Procedure Table 3.1 Total Degraded Areas for Recultivation 3-4 Table 3.2 The required Amount of Material for forming the Final Layer of 3-4 Cassette II Table 3.3 Structure of Recultivated Areas 3-4 Table 3.4 Overview of Recultivation Works on Cassette II 3-6 Table 4.1 Regulatory Classification and Categorization of Surface and 4-11 Groundwater Table 4.2 Required Quality of Cehotina and Vezisnica 4-11 Table 4.3 Comparison of Required and Established Quality Class of 4-12 Cehotina and Vezisnica Table 4.4 Results of Analysis of Water Samples from the Paleški Stream 4-13 (Upstream and Downstream from the Maljevac Landfill) Table 4.5 Groundwater Analysis Results 4-14 Table 5.1 Impact Interaction Matrix (before Mitigation Measures) 5-3 Table 5.2 Impact Significance Matrix 5-4 Table 5.3 Impacts on Erosion and Land Use 5-5 Table 5.4 Impacts on Water Resources (Surface Water and Groundwater) 5-6 Table 5.5 Impacts on Soil Quality 5-7 Table 5.6 Stage III B Emission Standard for Non-road Diesel Engines 5-8 Table 5.7 Calculated Emissions from Construction Machinery 5-8 Table 5.8 Impacts on Air Quality 5-9 Table 5.9 Noise Generated by the Construction Machinery at the Project 5-10 Area Table 5.10 Calculated Values of the Leq at Different Distances from the 5-10 Project Area Table 5.11 Noise Impacts 5-11 Table 5.12 Waste Generation and Disposal Impacts 5-12 Table 5.13 Impacts on Landscape 5-13 Table 5.14 Impacts on Ecosystem/Flora and Fauna 5-15 Table 5.15 Impacts on Economy and Livelihood 5-16 Table 5.16 Impacts regarding Occupational Health and Safety 5-17 Table 5.17 Summary of the Impact Assessment and Mitigation Measures 5-19 Table 6.1. Environmental and Social Impacts of Alternative Projects 6-2

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LIST OF TABLES (CONTINUED)

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Table 6.2. Comparative Overview of the Options for Maximum Volume and 6-5 Duration of Exploitation of the Landfill Maljevac Table 6.3. Advantages and Disadvantages of Selected Alternative 6-6 Table 6.4. Overview of Remediation Phases 6-6 Table 7.1 Mitigation Plan 7-2 Table 7.2 Environmental and Social Monitoring Plan 7-9 Table 8.1 Chronological Overview of Development of Previous 8-2 Documentation Table 8.2 Identified Stakeholders 8-7 Table 8.3 Stakeholder Groups and Methods of Communication 8-8

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LIST OF FIGURES

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Figure 1.1 Location of the Coal and Ash Disposal Site and Related Facilities 1-2 Figure 1.2 Location of the Future Cassette III (lands of Village Zbljevo) 1-3 Figure 1.3 Steel Pipeline for Transporting Ash and Slag (11 September 2018) 1-5 Figure 1.4 Distribution of Hydro-Mixture around the Landfill 1-5 Figure 1.5 The Current State of the Maljevac Landfill (Cassette II) (11 1-6 September 2018) Figure 1.6 Site Layout of the Maljevac Landfill 1-10 Figure 2.1 EIA Procedure in Montenegro 2-7 Figure 3.1 Overview of the Filled Cassettes 3-2 Figure 3.2 Drainage System at Cassette II 3-3 Figure 3.3 Display of the Characteristic Profile of the Cassette with Layers 3-5 Figure 3.4 Formed Protection Layer around the Cassette Perimeter 3-8 Figure 3.5 Planned Mosaic Distribution of Herbal Culture on Cassette II 3-9 Plateau Figure 3.6 Paleški Stream Catchment Basin 3-10 Figure 3.7 Planned Route for Paleški Stream Relocation 3-11 Figure 3.8 Microstructure of the Pump Station 3-13 Figure 3.9 Current status of sedimentation channel (September, 2018) 3-16 Figure 4.1 Project Area and the AoI 4-1 Figure 4.2 Spatial Position of Facilities in the Region 4-2 Figure 4.3 TPP “Pljevlja’’ and Landfill ”Maljevac’’ 4-3 Figure 4.4 Geological Map of the Maljevac Landfill and the Surrounding Area 4-4 Figure 4.5 Map of Seismic Reionization of Territory of Montenegro 4-10 Figure 4.6 Isolines for a Return Period of 475 Years 4-10 Figure 4.7 Nickel (Ni) Concentrations in mg/kg in Pljevlja Sampling Sites 4-15 (2009-2017) Figure 4.8 Arsenic (As) Concentrations in mg/kg in Pljevlja Sampling Sites 4-15 (2009-2017) Figure 4.9 Lead (Pb) Concentrations in mg/kg in Pljevlja Sampling Sites 4-15 (2009-2017) Figure 4.10 Locations of the Automatic Stationary Stations for Air Quality 4-18 Monitoring Figure 4.11 Measurement Points for Air Quality Monitoring in Spring 2018 4-20 Figure 4.12 Types of Land Character in the Area of Pljevlja Municipality 4-21 Figure 4.13 The Maljevac Landfill in November 2016 4-22 Figure 4.14 Map with Protected Area Network in Montenegro 4-24 Figure 4.15 Emerald Network in Montenegro 4-25

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LIST OF FIGURES (CONTINUED)

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Figure 4.16 Part of the Emerald Site (Cehotina Valley) Near the Landfill 4-26 Maljevac Figure 4.17 Forest Communities in the Area of Pljevlja Municipality 4-28 Figure 4.18 Road Network of Municipality of Pljevlja 4-31 Figure 4.19 Monastery of Sveta Trojica and Husein Pasha's Mosque 4-35 Figure 5.1 Project Area and the AoI 5-2 Figure 5.2 Percentile Distribution of the Land Use around the Maljevac Landfill 5-13 Area Figure 5.3 Population in Settlements in the Area according to Census Results 5-16 (1981-2011) Figure 6.1. Final Shape of the Landfill in the Variant 1 6-3 Figure 6.2. Final Shape of the Landfill in the Variant 2 6-4 Figure 6.3. Final Shape of the Landfill in the Variant 3 6-4 Figure 6.4. Final Shape of the Landfill in the Variant 4 6-5

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LIST OF ABBREVIATIONS

AoI Area of Influence BAT Best Available Techniques BOD Biochemical Oxygen Demand CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora CLRTAP Convention on Long-range Transboundary Air Pollution COD Chemical Oxygen Demand EA Environmental Assessment EHS Environmental, Health and Safety Guidelines Guidelines EIA Environmental Impact Assessment EMAS Environmental Management System EMEP European Monitoring and Evaluation Programme EMP Environmental Management Plan EPA Environmental Protection Agency EPCG Elektroprivreda Crne Gore AD Nikšić EPCG Elektroprivreda Crne Gore EQS Environmental Quality Standard ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan EU European Union GIIP Good International Industry Pract GIS Geographical Information System IA Implementing Agency IBRD International Bank for Reconstruction and Development IMS Integrated Management System IPPC International Plant Protection Convention IUCN International Union for Conservation of Nature IWMCP Montenegro Industrial Waste Management and Clean-up Project LCP Large Combustion Plants

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LIST OF ABBREVIATIONS (CONTINUED)

MAC Maximum Allowable Concentration MARD The Ministry of Agriculture and Rural Development MSDT Ministry of Sustainable Development and Tourism NEPA Nature and Environmental Protection Agency of Montenegro NGO Non-Governmental Organization OP Operational Policy PAH Polyaromatic Hydrocarbons PAP Project Affected People PM Particulate Matter (Dust) PMU Project Management Unit PPE Personal Protective Equipment RAP Resettlement Action Plan SLMP Safety Labour Management Plan SSIP Site-Specific Implementation Plans TPP Thermal Power Plant WB World Bank WQI Water Quality Index

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EXECUTIVE SUMMARY

1. Overview

Remediation of industrial waste disposal sites and management of the ongoing disposal of industrial hazardous wastes in order to reduce contamination of Montenegro’s natural resources and public health risks are among the key strategic goals of the Government of Montenegro. In this regard, a loan (Loan No. IBRD 84280 ME) has been obtained from the World Bank (WB) for the Industrial Waste Management and Clean-up Project (IWMCP) to remediate five selected industrial waste disposal sites. The Nature and Environmental Protection Agency (NEPA), which operates under the Ministry of Sustainable Development and Tourism (MSDT), is the Implementing Agency (IA) of the Project. In this context, one of the selected sites is Coal and Ash Disposal Facility in Pljevlja. This 53.5 ha facility for disposal of ash from the lignite fired Pljevlja TPP in Pljevlja is owned and operated by EPCG.

The overall aim regarding this site is gradual closure and reclamation of the disposal facility, while a place for continued disposal of ash on the existing site will be found until the conditions for the transition to a new location are satisfied. This aim also includes preventing the further pollution of the waters of the Paleški Stream and Vezišnica River. In this context, this Environmental and Social Impact Assessment (ESIA) Report is prepared for the Project, which is to be financed by the funds obtained from the World Bank, formulated to include:

 Relocation of the Paleški stream  Remediation of Cassette II

2. ESIA Requirements

The Project is a Category A project according to the WB categorization therefore an ESIA including an Environmental and Social Management Plan (ESMP) has to be prepared in accordance with the WB safeguard policies (mainly OP 4.01). Previously, during the preparation of the IWMCP, an ESIA for the Purpose of Remediation of 5 Environmental Black Spots was developed in 2012. Then, the EIA report (EIA Elaborate) was prepared in accordance with the Montenegrin EIA regulation for the purpose of depositing the by- products generated at TPP Pljevlja at the location of the existing Maljevac Landfill (including the Project assessed in this ESIA), which was approved by NEPA in 2017. In addition a Resettlement Action Plan (RAP) has been prepared by EPCG in 2017 in line with national legislation and WB policies (OP 4.12) for the whole project formulation covering the Project and the Project Plus (stabilisation of the landfill dam and rehabilitation of the landslide, remediation of Cassette I, construction of Cassette III and remediation of Cassette III and closing the Maljevac Landfill).

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

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3. The Project

As a part of the Project, recultivation of Cassette II of the Maljevac Landfill will be conducted in accordance with the Rulebook on the characteristics of the site, conditions of construction, sanitary, and technical conditions, manner of operation and closure of landfills. The disposal of ash and slag at Cassette II would be completed by the end of 2018, while recultivation works would start in 2019. The targets of the reclamation are mainly the following:

- Permanent prevention of ash dispersion by wind - Creating a pleasant environment for the inhabitants around the landfill and the possibility of using the re-cultivated areas - Restoring the damaged ecosystem - Controlling flowing and pollution of surface waters

Recultivation of Cassette II would include the following works:  Correction of the part of the embankment to the final level of K + 832 m asl and the partition embankment between Cassette I and Cassette II at K+ 833 m asl;  Terrain levelling and recultivation and closing of Cassette II (up to the partition embankment between Cassette I and Cassette II, which will stay operational and will be recultivated in the Phase 2 of recultivation of the Cassette I).  Rehabilitation of the slopes on the fourth and fifth embankment step;  Construction of drainage wells and a new precipitator on the fifth embankment step and lining the fifth embankment step and covering the current leachate collection channel with marly clay

The biological phase of optimal recultivation involves a complex of biotechnical and phytomeliorative measures for grassing of the landfill cassette as well as cultivation of forest cultures. After the ash disposal in the Cassette II is completed, three layers that have the protective role and are significant for preparation for biological recultivation will be placed during the technical recultivation phase.

The Paleški Stream is located southwest of the Maljevac Landfill and at the moment passes through the concrete collector running through the landfill. This collector has become permeable for leachate from the landfill, and in this way, it causes uncontrolled pollution of clean waters of the Stream and River Vezišnica. With the aim of preventing further mixing of leachate from the ash and slag landfill with the waters of the Paleški Stream, it is planned to relocate the Paleški Stream out of the landfill area. Spring waters and atmospheric waters (precipitation/surface runoff) from the associated basins reaching Paleski would be transported to the Borovičko lake as clean water through adequate channels with a width of 30 m and length of 1,876 m (Section-1; 848 m and Section-2; 1,028 m) .

4. Baseline (Current) Conditions

Ash and slag landfill Maljevac (the Project site) is located about 800 m southwest of the TPP Pljevlja, which is located in the borders of Pljevlja Municipality, in the mountainous northern part of Montenegro. Village Zbljevo is located in the immediate vicinity of the Landfill, where the nearby environment of the area of TPP is sparsely populated, and Zabrdje, Kalušići, Komina, Radosavac and Grevo settlements are located in the wider surroundings.

According to the most recent (2018) analysis performed to determine the water quality of the Paleški Stream, both its upstream and downstream were found to be out of all the classes of the pertinent regulation due to the high chemical oxygen demand (COD) and cyanide levels. In addition to the surface water quality determination studies, a set of groundwater samples was taken from the body and base of the dam and once again it is found that the samples are out of all the classes of the pertinent regulation due to its high turbidity, electrical conductivity, suspended particles, COD, and nitrites levels. It can be concluded that the Paleški Stream is currently under the pollution stress created by both the TPP Pljevlja and Maljevac Landfill.

In order to determine the soil quality, soil samples were taken from the sampling locations around the Maljevac Landfill. The analyses results showed that soil quality fulfil the conditions of the rulebook and it can be said that the landfill does not have significant impact on the surrounding soil.

Air quality in the town of Pljevlja is mostly affected by the extremely high content of dust, high concentrations of smoke and soot (especially during the winter period) as well as high concentrations of PAH (benzo(a)pyrene) in floating particles of ash, smoke and soot, which are carcinogenic substances. The monitoring results indicate that, besides the industrial sources, city combustion plants and individual combustion plants contribute to the high degree of air pollution. Air quality monitoring in vicinity of the Maljevac Landfill revealed that PM10 concentrations are generally below the limit values specified in the related regulations. In addition, noise monitoring revealed that there is no significant noise nuisance due to the landfill.

Anthropogenic landscape is dominant in the area of Pljevlja. In the city and its surroundings the impact of the urbanization and the mining-energy-industrial zone is clearly seen. There are no protected areas, cultural heritage sites, important bird areas or Emerald site in the area of influence (AoI) of the Project. The Project site (Cassette II) is already located in the area of Maljevac Landfill and only the relocation route of the Paleski Stream is passing through undisturbed areas (mainly agricultural land). The slopes of Maljevac Landfill are covered with vegetation which was formed by self-cultivation, and it mostly consists of sporadic grass cover and low bushy vegetation.

Municipality of Pljevlja has total area of 1,346 m², which represents 9.7% of the total territory of Montenegro and a population of 30,786 inhabitants. Major economic activities in the area are related to public administration and mining as well as the employment opportunities created by the TPP, and agriculture. In Zbljevo, which is the closest settlement to the Project area, about 36%of the active population is unemployed, while most of the households have at least one regular income from pension or salaries. Most of the household’s livelihood is based on regular monthly income, whether a salary or

pension. In addition, most of the population in villages use woods, fruits grown in own yard and vegetables from own garden.

5. Environmental and Social Impacts

Ash and slug from the TPP have been disposed to the Maljevac Landfill for decades. In the present situation, the Maljevac landfill has various adverse environmental and social impacts. As a result of the implementation of the Project, an overall significant positive impact on the environment is expected. However, during the construction works for the relocation of Paleski Stream and remediation of Cassette II, there would be rather short term, temporary negative impacts with low to medium significance as provided in the previous sections. There would not be any cumulative or transboundary impact due to the Project due to the scope and location of the Project. There would be temporary positive social impacts (such as employment) during the construction phase as well.

6. Project Alternatives

The remediation and further operation alternatives for the Maljevac Landfill were studies in the scope of technical studies and the Project assessed in this ESIA is a part of the preferred alternative for this purpose. The environmental and social evaluation showed that the preferred alternative have limited negative impact on local population due the construction works and heavy traffic and landowners due to expropriation (for Cassette III), while having significant positive impact by eliminating the risk of dam collapse, significant positive effect on water quality after relocation of Paleski stream and significant positive effect on landscape and air quality after rehabilitation and greening of the landfill.

Alternative routes for relocation of the Paleski Stream have been studied and the optimum route and method was selected in accordance with prescribed Urbanistic-technical conditions, which will provide the solution most similar to natural flowing conditions of the stream. Due to the state of the surface after completion of ash dumping on Cassette II, and specific pedological, microclimate and climate conditions, optimal reclamation with grass planting and forestation was selected.

7. ESMP

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

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

Table 1. Summary of the Impact Assessment and Mitigation Measures

Issue Mitigation Measures Land Use, Erosion and Slopes of embankments will be landscaped and planted. Landslide Risks Erosion control measures will be taken in all areas of works against erosion risks. Driving of machinery within surface waterbodies will be prevented. Maintenance, refuel, and construction machinery cleaning will be carried out at dedicated Surface and Groundwater locations with proper containment and drainage. Resources Oil and fuel will be stored in places with secondary containment. Site specific emergency plans will be prepared to respond any incidents and spillages. Topsoil will be removed, stored, and handled in such a manner that it would be used during finishing works. Non-controlled and unplanned access road openings will be prevented. Soil Quality Drainage channels will be constructed. Operational plans for winter maintenance would be developed. Soil quality will be monitored during operation stage including control of the top soil in the village Gradac Donji. Working sites will be frequently watered in land preparation and construction phase. Temporary spoil storage areas will be positioned not to be vulnerable to wind erosion. Air Quality EPCG will designate a liaison staff, in case of complaints related with air quality that could be received from the neighborhood settlements. Construction will be limited to day-hours (07:00-19:00). Noise Natural acoustic barriers and screens will be used. Systematic collection of solid waste during construction and operation phases will be Waste Generation undertaken and wastes will be disposed at licensed facilities specified by national authorities or handed over to a company authorized to collect the subject waste. Preparation of a landscape restoration plan in line with the remediation design for Cassette II Landscape including the realistic requirements to minimize short term visual intrusion from the site operations and to maximize the long term recovery potential of the landscape. Clearing up and removal of vegetation will be minimized to the extent necessary for the execution of works. Ecosystem / Flora and Measures will be taken to prevent animal deaths in the project area and on access roads. Fauna Checks and photographic recording for germination success of planted areas and for natural regeneration/vegetation will identify locations and areas of disturbance, successes and failures.

Table 1. Summary of the Impact Assessment and Mitigation Measures

Issue Mitigation Measures Technical measures, such as fencing and intermediate cover, will be taken to prevent the entrance of fauna to the landfill site. Passages over the new Paleski Stream bed would be formed/allowed as appropriate for the fauna species. Land acquisition will be done in a manner which ensures transparency and accountability, and which ensures that compensation is paid in accordance to the law in force. Appropriate disclosure of information, consultation, and the informed participation of affected Socioeconomy persons and community will be implemented. Procurement of the land has been started on 'willing buyer/willing seller' basis. EPCG has developed a Resettlement Action Plan. Contractor will follow the national requirements with respect to "chance finds" which may Cultural heritage emerge during construction. EPCG and the contractor of works are jointly responsible with regard to workers health and safety. This would include both management measures and reporting and investigating any Occupational/Works Health incidents, i.e. Implement international HSE standards in all contracts. and Safety A Health and Safety Management Plan would be developed as well as undertaking training programmes, inspections and reward/penalty schemes to enforce safe working practices. An Emergency Action Plan will be developed in lien with the emergency plan and procedures Emergency Situations of the EPCG.

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

Table 2. Summary of Monitoring Activities

Issue Parameter to be Monitored Erosion and Landslide Slopes and relevant signs Risk Surface Water and Water quality parameters (sampling and analysis) as required in relevant legislation Groundwater Number of spill/leakage incidents and corrective measures taken in accordance with national Soil and international standards and soil quality parameters (analysis) as required in relevant legislation Air Quality Dust and PM 10 Noise Working hours and Noise levels (dB) Waste Management Waste management plan, records and temporary waste storage areas Landscape Related grievances records Flora and Fauna Survey for flora and fauna species Having alternative access to the parcels close to the construction site, and related grievances Socio-economy records HS records (on accidents, employment, training) emergency preparedness plan, personnel Workers/ Occupational grievances, and periodical ESMP performance review and monitoring reports, existence and Health and Safety validity of the legal environmental and health and safety permits, Traffic Traffic management plan, selected route and time for transport of material

8. PUBLIC PARTICIPATION AND INFORMATION DISCLOSURE

The Project as a part of a larger project framework was subject to previous public consultations during development of the ESIA for Remediation of Five Contaminated Sites, as well as within the national EIA procedure and the public consultation during the RAP process. A meeting was also held with the representative of village Zbljevo in the initial phase of ESIA development. Thus, these consultations are considered as first round of discussions related to scope of this ESIA. A public consultation/participation meeting would be conducted within the scope of the ESIA studies following the completion of the draft report in line with the WB standards.

1. INTRODUCTION

1.1. Project Background

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

In this context, one of the selected sites is Coal and Ash Disposal Facility in Pljevlja. This 53.5 ha facility for disposal of ash from the lignite fired Pljevlja TPP in Pljevlja is owned and operated by EPCG, the Montenegrin state-owned power company. The location of the site in Montenegro and the general view of the disposal facility and related facilities (i.e. TPP, and coal mine) are shown in Figure 1.1.

Previously IRM-Bor produced a Report on the stability of slopes of the dam at elevation of K+827m asl in 2015 with the aim of checking the possible conditions for the continued disposal at this site. Subsequently, the Preliminary Design was developed for continuation of deposition of combustion by-products from the TPP Pljevlja at the existing Maljevac Landfill. After this study, Elektroprivreda Crne Gore (EPCG) developed a project formulation for remediation activities on coal and ash disposal facility Pljevlja (for improving the quality of environment in the surrounding area) and construction of and additional disposal space (Cassette III) in the area of village Zbljevo (see Figure 1.2). This construction will ensure deposition of ash and slag to be produced in the TPP for the following 7 years.

In this project formulation, technical solutions, which enable realization of all activities in phases, have been developed in the way that each of the phases provides enough space for deposition of the annual production of ash and slag, all in line with the accepted Main Design, Elaborate on the assessment of environmental impact (an EIA Report for the project formulation was prepared in accordance with Montenegro legislation and approved by the competent authority), Technical specifications, Law on Spatial Development and Construction of Structures, Rulebook on the manner of preparation, scale and detailed contents of technical documentation. The project solution enables generation of new disposal space, which will allow deposition of the total amount of 4.451.427m3 of ash and slag, whereby the landfill camber will reach the elevation of K+832 m asl, all in compliance with national environmental standards.

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Figure 1.1. Location of the Coal and Ash Disposal Site and Related Facilities

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Figure 1.2. Location of the Future Cassette III (lands of Village Zbljevo)

1.1.1. Location and Description of the Coal and Ash Disposal Facility (Maljevac Landfill)

The Thermal Power Plant Pljevlja (TPP) is located in the industrial zone of Pljevlja, at about 7 km from the city of Pljevlja and on the fourth kilometer of the road Pljevlja – Djurdjevica Tara - Zabljak, with an altitude of 760 m. This site is located in the alluvial plane on one side and on the other side along the river Cehotina, between the limestone hill Velika Plijes in the southwest and the Strazica exaltation on the northwest side. Coal and Ash Disposal Facility (Ash and Slag Landfill "Maljevac") is at a distance of 800 m southwest of the TPP. About 100 m south of the landfill there is a sawmill, and about 800 m north-east of the site a coal crushing plant is located.

The environs of the TPP is sparsely populated, but in the wider surroundings there are several small settlements; Zabrdje, Kalusici, Komina, Radosavac and Grevo. The closest settlement to the Maljevac landfill is Zbljevo, and close to the future dumpsite there is Sumani, Ljuce, and Borovica. The source of the Paleski creek is located southwest of the Maljevac landfill. The spring forming the Paleski stream is at an elevation of 1,100 m. The length of the stretch of the Paleski stream flowing through the valley is 2.9 km long. Paleski stream flows into the river Vezisnica at an elevation of 750 m. Vezisnica River is located to the north of the Maljevac landfill and flows towards Pljevlja where it reaches the river Cehotina.

The process of coal combustion in thermal power plants produces a certain quantity of ash, which should be disposed at an engineered facility - landfill. For the purpose of storing/disposing the by-product of the TPP, in 1982, the embankment (dam) "Maljevac" was built in the valley of Paleski stream near the village Zbljevo and the coal and ash disposal facility was formed. The project documentation for the landfill was made by the project organization Energoprojekt-Hidroinženjering, Belgrade, in 1979 (the Main Design),

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while annexes were added to the existing documentation in 1988, 1996 and 2003 for the purpose of increasing the height of the dam.

The dam was built in several phases. In the first phase, a basic dam of clay and stone was built, with crest elevation at 790.5 meters above sea level (asl) with a height of 27.5 m and in the second phase, 1st, 2nd, 3rd, 4th and 5th embankment steps were successively constructed up to the elevation of 813.20 m asl.

Considering that it was necessary to provide additional space for ash disposal to sustain operation of the thermal power plant, height of the embankment was further increased. The current camber of the embankment, which borders the Cassette on the downstream side, was built up to the elevation of K+826 m asl. The space of the active Cassette is limited by the embankment at an approximate height of around K+832 m asl, which also represents the final level for deposition of ash and slag at the Maljevac landfill in all variants.

In the context of establishing the Maljevac landfill, Paleški Stream, and the temporary creeks running in to the stream, was diverted using an atmospheric reinforced concrete collector of 1,338 m length. The collector was set up by the valley of the Paleski stream along the bottom of the ash and slag landfill and passes through the body of the dam.

The collector consists of the main and secondary parts. After the project, which involved extension of the disposal area and stabilization of the dam, i.e. rehabilitation of the 1st, 2nd and 3rd stair, the collector was extended to 1,460 m length, and the secondary one was created (which is armored), in the length of about 600 m.

1.1.2. Technology and Current Condition of the Landfill

The Maljevac landfill belongs to the group of wet landfills, as fine crushed waste (slag and ash) in the form of a hydrocarbon is transported hydraulically by pipelines with pumps from the TPP to the landfill. The ash transportation system from the TPP is hydraulic, where a mixture of water and ash (in the ratio of 1:6 to 1:10) is taken through the steel pipeline to the landfill where the ash is deposited. Water is taken from the landfill area by gravitation through the overflow construction, located on the right side of the landfill and the return pipeline, to the ash and slag pump station, and in this way forms a closed system of recirculation of the transport water. The transport of ash and slag hydro-mixture is carried out from the pumping station ("excavator" station) located at the basement level of the TPP. Two centrifugal pumps are used for this purpose with a capacity for reaching 6000 KPa and water mixture flow rate up to 700 m3/h. Since the active Cassette II has reached the height of K+832 m asl at the outflow point, the current system will completely satisfy the new conditions for transport of the water mixture. The present steel pipeline is seen in the Figure 1.3.

As a rule, outflow points are located on the side of the Cassette opposite from the concrete chamber, since the maximum time for sedimentation of fine ash particles is ensured in this way. Depending on the required conditions, 4 outflow points may be ensured, instead of 2. Higher number of outflow points is necessary in case the length of the release pipe-for overflow, (surface area taken by the Cassette itself) is large. One of the possible ways in which the water mixture may be distributed around the landfill is shown in Figure 1.4 below.

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The system for transporting of hydro-mixture has been in operation, with minor modifications, since the beginning of the landfill formation in 1982. The system proved to be reliable and flexible in day-to-day operational work and no major problems were encountered during the several decades of operation.

Figure 1.3. Steel Pipeline for Transporting Ash and Slag (11 September 2018)

Figure 1.4. Distribution of Hydro-Mixture around the Landfill

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The landfill is designed in Cassette mode. This means ash disposal is done in individual Cassettes until they are closed at designed levels. Since 2003, the disposal has been made by forming two Cassettes with ash embankments, with crest elevations reaching 831 and 832 m asl.

In the Maljevac Landfill, ash and slag from the TPP Pljevlja are currently deposited in the currently active Cassette II. Embankment of Cassette II has already been built up to K + 832 m asl at certain points, while at some other points embankment reaches the height of around K + 830 m asl. Camber of Cassette II virtually represents a correction of the embankment, up to the elevation point of K+833 m asl. The newly-formed embankment has 6,0 m wide crown and is located at K+833 m asl and has a 1:2 inclination of the interior and external slopes. After completion of the works on the correction of the peripheral embankment, the ash and slag disposal will be continued up to the level of K + 832 m asl, whereas the accumulation space between the level K+833 m asl and K+832 m asl will be used as the retention area in case of high precipitation. According to the degree to which Cassette II was filled up in January 2017, correction of the embankment and increasing the elevation up to K+833 m asl create conditions for deposition of ash and slag into the active Cassette II in the total amount of 180.877m3.

During the phase of exploitation of the Maljevac landfill, based on the results of technical observation and subsequently performed tests, an analysis of stability of the existing dam was performed. In accordance with the results of this analysis the works on stabilization of the Maljevac dam were completed in 2014 by construction of stabilizing ballast, which provided conditions for static and dynamic stability for further safe disposal of ash and slag. Current state of the Maljevac Landfill can be seen in Figure 1.5.

Figure 1.5. The Current State of the Maljevac Landfill (Cassette II) (11 September 2018)

In addition, during the operation of the landfill, the existing main collector for the Paleški Stream has become water permeable for leachate from the landfill, and this causes pollution of the clean waters of the Paleški Stream and Vezišnica River.

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1.2. Project Formulation Structure

The Main Design developed for the overall project, aiming at the continued operation and recultivation of the Maljevac landfill in phases, includes the following main elements:

 Relocation of the Paleški stream  Remediation of Cassette II  Stabilisation of the landfill dam and rehabilitation of the landslide  Remediation of Cassette I  Construction of Cassette III  Remediation of Cassette III and closing the Maljevac Landfill

The relocation/diversion of the Paleški Stream and remediation of Cassette II is formulated as the Project to be financed by the funds obtained from the World Bank. This ESIA Report is prepared for the Project, which intends to mitigate some of the ongoing impacts of the ash and slag disposal activities on the environment. Thus, in this report hereafter, “the Project” refers to the activities of remediation of Cassette II and relocation/diversion of the Paleški Stream.

The other elements included in the Main Design are planned to be performed in phases and they will be financed from the EPCG’s individual sources of financing, which are defined, and hereafter referred, as the Project Plus in the ESIA report. Those elements are considered as associated facilities and activities in the ESIA report and approached accordingly for assessing the impacts.

1.2.1. Overview of the Project

The Project which will be financed by the World Bank funds covers the following components and aims the remediation of Cassette II and restoring the water quality in the Paleski Stream:

1. Relocation of the Paleški Stream

2. Recultivation of Cassette II, which includes the following works:  Correction of the part of the embankment to the final level of K + 832 m asl and the partition embankment between Cassette I and Cassette II at K+ 833 m asl;  Digging ash and slag from the current Cassette and terrain levelling;  Filling up Cassette II up to the planned average level of K + 832 m asl;  Recultivation and closing of Cassette II (up to the partition embankment between Cassette I and Cassette II, which will stay operational and will be recultivated in the Phase 2 of recultivation of the Cassette I).  Rehabilitation of the slopes on the fourth and fifth embankment step;  Construction of drainage wells and a new precipitator on the fifth embankment step;  Lining the fifth embankment step and covering the current leachate collection channel with marly clay.

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1.2.2. Overview of the Project Plus

The Project Plus will be financed from the EPCG’s individual source of financing and covers the following components:

1. Remediation of Cassette I with the following works:  Making surpass on the section of the embankment in Cassette I, which has not reached the final level of K+832 m asl;  Filling up Cassette I up to the planned average level of K + 832 m asl;  Recultivation and closing of Cassette I.

2. Construction of Cassette III with the following works:  Pumping out the water from the part of Cassette III into the precipitator on the fifth embankment step by using the submersible pump, if the volume of accumulated water jeopardises the process of performing the works on construction of the peripheral embankment;  Clearing out the part of the terrain below the embankment in Cassette III by using the necessary mechanisation (removing the surface layer of ground which will later be used for covering the landfill slopes during recultivation) and depositing the excavated soil on a temporary storage;  Construction of the drainage system in Cassette III, laying out drainage pipes for collection and transport of landfill leachate from the Cassette, in line with the applicable regulations. A drainage system made of adequate polyethylene drainage pipes will be installed, and water will be gravitationally diverted towards the newly built sedimentation channel on the fifth embankment step. Drainage filter filling will be formed above these pipes. Concrete overflow chambers will be formed on the internal side of the main embankment of Cassette III, and they will be used for collection of this water and its drainage towards the new precipitator;  With the aim of protecting the landfill from surface and atmospheric water, the plan is to construct concrete peripheral channels;  On the north side, the peripheral channel has 1 m wide foundation, 1:1 inclination of slopes and depth from 0.5-1.5 m, and it takes in and drains surface water from the incoming runoff and landfill cover;  Construction of the peripheral embankment will be carried out in phases(five phases in total);  Installation of pipeline (Ø 350 mm) for effusion of ash-slag water mixture around the ledge of Cassette III, with the defined effusion spots and this will be done in phases of construction of the peripheral embankment.

3. Remediation of Cassette III and closing the Maljevac Landfill

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1.2.3. Dynamics and Timing of Reclamation Works

According to the Main Design, the Maljevac landfill is divided into Cassettes I, II and III. The final fill elevation will be K+832 m. The planned dynamics of the work on the landfill envisages the closure of Cassette II at K + 832 m up to April 2018. Continuation of the work of the landfill is reflected in the closing of Cassette I. Cassette I would be closed by October 2019. In the period from October 2019 till September 2025, Cassette III would be closed in several stages.

Based on the dynamics of work (i.e. closure of Cassettes I, II and III of the Maljevac landfill), it is necessary to perform phase reclamation of the Cassettes. In this context, the schedule for completion of ash and slag disposal to the Cassettes and start of reclamation works are summarized in Table 1.1 below.

Table 1.1. Reclamation Phases

Location Phase Completion of Cassette Beginning of reclamation Cassette II 1 2018 2019 Cassette I 2 2019 2020 Cassette III 3 2025 2022

Reclamation will take place in the following stages:

1. Phase 1 includes works on reclamation on Cassette II and rehabilitation and reclamation of level 4 and 5 with the creation of the sediments

2. Phase 2 includes works on reclamation on Cassette I

3. Phase 3 includes the reclamation works on Cassette III in several stages: - reclamation of the slope to the K+821 - reclamation of the slope to the K+828 - reclamation on Cassette III - slopes and plateau of Cassettes (K + 832 m)

This phased approach would provide adequate scape for ash and slag disposal to be generated at the TPP and ensure sustaining the operation of the TPP and production of electrical energy for further 7 years (approximately). An overview of the entire Maljevac Landfill, including the current Cassette I and Cassette II, as well as the planned Cassette III, is shown in the Figure 1.6.

Surface of the area which is projected for construction of the new Cassette III is 5.85 ha. The projected surface of the area covered by the dam is 4.30 ha, while surface of the north peripheral channel is 3,60 ha. The total surface area, which will be subject to recultivation upon completion of the operation phase of the landfill is 48.75ha.

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Figure 1.6. Site Layout of the Maljevac Landfill

1.3. Applicable EIA and ESIA Procedures and Status

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

Following the above mentioned ESIA study an EIA report was prepared in accordance with the Montenegrin EIA regulation. This EIA Elaborate was developed for the purpose of depositing the by-products generated at TPP Pljevlja (due to combustion of coal) at the location of the existing Maljevac Landfill (on the UP in the area of DSP of Municipality of Pljevlja), and approved/permitted by the NEPA in April 2017. This document included an assessment of environmental impacts of the entire remediation project formulation for Maljevac landfill with applicable mitigation and monitoring measures to be applied during remediation works and also during operation of the landfill. Public consultation was conducted following Montenegrin EIA legal requirements.

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For the needs of implementing the project formulation (especially for the construction of Cassette III) on continuation of utilization and phase reclamation of the ash and slag landfill Maljevac of TPP Pljevlja, the Resettlement Action Plan (RAP) has been prepared by EPCG in 2017. The RAP represents policies, procedures and processes to be applied during project implementation while mitigating negative social impacts with reference to entities affected by the project. It was developed for the needs of land expropriation and relocation in compliance with requirements of the WB (OP 4.12) and it is harmonized with the national legislation.

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

This ESIA report for Remediation Activities on Coal and Ash Disposal Facility presents the ESIA and EMP in accordance to WB requirements (prior to the start of the remediation works, as an update of the ESIA and EMP carried out previously during preparation of the IWMCP). The present document provides the background to the proposed remediation activities on landfill Maljevac as well as an assessment of their likely environmental and social impacts, both beneficial and adverse. Proposed enhancement and mitigation measures, as well as monitoring needs, are outlined where necessary together with an assessment of responsibilities for their implementation.

1.4. Scope and purpose of the ESIA Report and ESMP

The ESIA report and ESMP cover the issues, impacts, mitigation and monitoring measures of the Project activities aimed at remediation of Cassette II of the Ash and Slag Disposal Facility and relocation of the Paleski Stream (activities that are to be financed from the WB Loan) in detail. At the same time, the ESIA addresses briefly the Project Plus and issues related to the activities that will be financed by EPCG since this would be in accordance with the treatment of associated facilities by the WB policy on ESIA.

The key scope related to the preparation of the ESIA report is to provide and fulfill legal preconditions and World Bank requirements for the start of implementation of construction works related to the remediation activities on Cassette II and relocation of Paleski Stream (the Project). The purpose of this ESIA is to:

 update and revise the ESIA prepared in the preparation phase with new information based on the development of site, activities that were undertaken since 2012 and agreement between the Government of Montenegro and the WB on the scope of activity;  assess the likely impact that the option (and alternatives) for investment proposed by the comprehensive analysis may have on the environmental of the site and their corresponding region, social situation and public health, outside the resettlement and land acquisition measures;  identify and estimate costs related to mitigation measures and monitoring activities, including proposed staffing and training requirements related to ESMP;  ensure that the affected communities are appropriately engaged in issues that could potentially affect them;

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 ensure that the procedure of public consultation is carried out and documented according to the WB requirements.

1.5. Structure of the ESIA Report

The ESIA report and the ESMP for the Project have been prepared in accordance with the Annex B and Annex C of the OP 4.01. The information provided in the report was presented in detail under these headings, to the extent that the best available data allowed. Accordingly, the chapters included in the ESIA Report may briefly be explained as follows:

• Chapter I Introduction; provides an introduction to the Project and ESIA Report, providing project details and environmental and social impact studies. • Chapter II Policy, legal and administrative framework; explains national and international legal requirements, and also identified environmental agreements that are relevant to the project. • Chapter III Project description; is a description of the project including its location, components, technical specifications, associated construction and operation activities, and a proposed schedule for implementation. • Chapter IV Environmental and social baseline conditions; describes the baseline conditions in and around the proposed project area, including physical, biological and socio-economic conditions. • Chapter V Environmental and social impacts of the project; assesses the potential positive and negative impacts of the project, identifying mitigation measures. • Chapter VI Project alternatives; is an analysis of feasible alternatives to the proposed project techniques, design and operation, including a “no project” alternative. • Chapter VII Environmental and social management plan; describes the necessary management strategies, monitoring activities, and responsibilities for implementation of the identified mitigation measures. • Chapter VIII Public participation and information disclosure; provides information about public consultations conducted, public comments and their treatment and plan for further consultation with identified stakeholders.

In line with the World Bank OP 4.01, supplementary information, such as the list of the preparers and contributors, references, related data and documents, etc., which is relevant to the contents of the chapters listed above, is provided in the appendices of the ESIA Report, including the list of preparers as Appendix 1.

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2. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

2.1. Legal Framework for Environmental Protection and Conservation

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

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

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

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

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

Major steps have been taken in Montenegro during the last decade towards alignment with the EU environmental legislation, and also toward integration of environmental considerations in other policies. National Strategy on Sustainable Development was adopted in 2016. National Waste Management Plan was prepared and adopted in 2015. National Strategy on biodiversity was adopted in 2016. National Strategy on climate change was adopted in 2015. Strategic master plans on wastewater were adopted in 2004 and 2005, while their revision is expected in 2018. National Waste Management Plan for the period 2015-2020 describes the handling and management of waste in Montenegro.

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2.2. Legal Framework for Health and Safety

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

2.3. Legal Framework for Expropriation and Resettlement

The Constitution of Montenegro lays down the legal basis for expropriation of land and protects property rights, only exceptionally allowing the possibility of limiting these property rights in case when it is imposed by public interest and established by the law or based on the law. According to the Law on property-legal relations, no person may be deprived of his/her property or of the rights deriving from it, except in cases concerning the public interest determined by law. In case of deprivation (complete expropriation) or restriction (partial expropriation), rightful compensation for the property not lower than its market value at the time of expropriation is guaranteed. The beneficiary of expropriation may submit the expropriation proposal only after the determination of the public interest in expropriation.

The Law on Expropriation (’’Official Gazette of the Republic of Montenegro“, No. 55/00, 28/06 and ’’Official Gazette of Montenegro“ No. 21/08, 30/17) guides the land/property management and serves as a general framework for the land/property expropriation on the territory of Montenegro. The Law provides the right to appeal at many stages of the expropriation procedure, such as administrative and judicial appeals (i.e. against the decision on public interest, the decision on expropriation, and regarding compensation), among other rights of affected citizens (those with formal legal rights).

2.4. Montenegrin/European Environmental Legislative and Permitting Framework

2.4.1. EU Directives

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

 Directive 2001/42/EC (SEA);  Directive 2011/92/EU (EIA), which codified Directive 85/337/EEC and its amendments by Directive 97/11/EC, Directive 2003/35/EC and Directive 2009/31/EC;  Directive 2003/4/EC (access to environmental information);  Directive 2003/35/EC (public participation and access to justice in EIA procedures and procedures for the issuance of IPPC permits);  Directive 2004/35/EC (environmental liability), as amended by the Directive 2006/21/EC (mining waste), Directive 2009/31/EC (geological storage of carbon dioxide) and Directive 2013/30/EU (safety of offshore oil and gas operations); Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 2 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 2 / 12 First Draft of ESIA Date: December 2018

 Directive 2008/99/EC (on the protection of the environment through criminal law);  Waste Framework Directive 2006/12/EC;  Landfill Directive 1999/31/EC;  Hazardous Waste Directive 91/689/EEC, with accessories 94/31/EC, 166/2006;  Sludge directive from wastewater treatment plants 86/278/EEC;  Waste Incineration Directive 2000/76/EC;  The Packaging and Waste Directive 94/62/EC, with accessories 2005/20/EC 2004/12/EC, 1882/2003;  Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste.

2.4.2. Horizontal Legislation

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

The Law on the Environmental Impact Assessment (EIA) (“Official Gazette of the Republic of Montenegro“, No. 80/05, “Official Gazette of Montenegro“, No. 40/10, 73/10, 40/11, 27/13, 52/16) is fully harmonized with the EU directives regulating this area. The Law regulates the EIA procedure for projects that can have a significant impact on the environment, the content of the study, the participation of interested authorities and organizations and the public, the assessment and approval process, notification of projects that can have a significant impact on the environment of another state, supervision and other issues. The EIA is intended for the projects in the field of industry, mining, energy, transport, tourism, agriculture, forestry, water management and utilities, as well as for all projects planned in a protected natural asset and in a protected environment of a fixed cultural property. The Law contains separate chapters dedicated to reporting, keeping records and providing information for inspection, also for public consultation. All the national waste facilities in Montenegro will be subject to carrying out an EIA according to the regulation.

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

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2.4.3. Nature Protection

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

2.4.4. Air Quality

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

Exceedances of the limit values of PM10 particles have been detected in several municipalities (Pljevlja, Nikšić, and Podgorica). Besides detected exceedances of PM10 particles in the ambient air occasional high values of SO2, NOx and CO emissions from stationary sources have been detected, especially in Pljevlja. Air quality Plans were drawn up for all the municipalities mentioned above (for Pljevlja in 2013, Nikšić 2014 and Podgorica 2015), so that all relevant zones are covered by air quality plans so far.

Although fully transposed, the Directive 2001/81/EC (national emission ceilings - NEC) is not fully implemented in Montenegro. The National Programme for Progressive Reduction of National Emissions has not yet been established. The reason for that lies in the future regime of the key source of emissions of SO2 and NOx in the country - the Thermal Power Plant in Pljevlja. According to the decision of the Ministerial Council of the Energy Community D/2013/05/MC-EnC, TPP Pljevlja can use the opportunity to work for the maximum of 20,000 working hours in the period 2018 - 2024, after which it would stop working or it would go through a significant reconstruction which assumes installation of the equipment for preventing emissions of NOx and SO2, to comply with the required standards. TPP Pljevlja decided to apply for the use of “opt-out” mechanism in line with

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the decision of the Ministerial Council of the Energy Community D/2013/05/MC-EnC on the implementation of Directive 2001/80/EC on large combustion plants (LCP). TPP Pljevlja would reduce its emissions for around 50% in the period 2018-2024, by reducing its working hours in the given period.

2.4.5. Waste Management

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

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

2.4.6. Water Quality

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

2.4.7. Industrial Pollution

Control of industrial pollution is governed mainly by the Law on Integrated Pollution Prevention and Control – IPPC (“Official Gazette of Montenegro“, No. 80/05, 54/09, 42/15, 54/16). The Law regulates the conditions and procedure for issuing an integrated permit for installations and activities that may have negative effects on human health, environment or material goods. The Law states that for existing installations, the operator is obliged to obtain an IPPC permit no later than January 1, 2018. According to the Decree on types of activities and installations for which the integrated permit is issued ("Official Gazette of Montenegro" No. 07/08), TPP "Pljevlja" belongs to item 1.1 Thermal power plants with thermal inputs above 50 MW. NEPA issued the IPPC permit to TPP Pljevlja in March 2018 followed by the Program of adjustment measures with prescribed conditions (Annex 1 of the permit).

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2.5. National EIA Procedure

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

1. Screening as the stage of determining whether an EIA is required; 2. Scoping as the stage of determining the scope or extent of the environmental impact assessment; 3. Review as the stage of reviewing the EIA study to see if it has been undertaken to an acceptable standard and in accordance with the legal requirements.

According to Montenegrin Legislation, the EIA Procedure is shown schematically as a flowchart in Figure 2.1 below. This procedure is in full compliance with the EU EIA Directive (2011/92/EU) and the general implementation in the world. The NEPA is the competent authority for the EIA process for projects where project development consent (e.g. construction permit) is issued by a state (national) authority. The local self- government unit responsible for environmental protection is ‚the competent authority for other projects for which approvals, permits and licenses are issued by local authorities.

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

The Project “Planned Remediation Activities on Coal and Ash Disposal Facility Pljevlja, Montenegro” is included in the List 1 of the EIA Decree within the point 11. (a) Installations for the treatment or removal of hazardous waste by incineration, chemical, mechanical or biological treatments as well as landfills for temporary and permanent storage of hazardous waste.

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Proposal identification

EIA required Screening No need for EIA

Scoping Initial environmental examination Impact analysis

Mitigation and impact management

EIA Report Public Resubmit involvement

Review Redesign

Decision-making Not approved

Approved Ic

Implementation and post EIA monitoring

Figure 2.1. EIA Procedure in Montenegro

2.6. International Environmental and Social Regulatory Framework

2.6.1. International Treaties and Conventions

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

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

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

In addition to the Aarhus Convention, the certain number of international conventions ratified by Montenegro will be considered during the elaboration of the ESIA. The list of relevant conventions and applicable Montenegrin laws and regulations are given in Appendix 2 of this ESIA report.

2.6.2. World Bank Group Environmental and Social Framework and Safeguard Policies

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

These policies include the following:

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

OP 4.01 Environmental Assessment (EA)

The Bank requires Environmental Assessment (EA) for projects proposed for obtaining the Bank support, in order to ensure that they do not have, or mitigate potential negative environmental impacts. The EA is a process in which breadth, depth, and type of analysis depend on the nature, scale, and potential environmental impact of the proposed project. The EA evaluates a project's potential environmental risks and impacts in its area of influence; examines project alternatives; identifies ways of improving project selection, siting, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts; and includes the process of mitigating and managing adverse environmental impacts throughout project implementation. The EA takes into account the natural environment (air, water and land); human health and safety; social aspects; and trans-boundary and global environmental aspects.

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

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

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

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

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

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

 Annex A: Definitions  Annex B: Content of an Environmental Assessment Report for a Category A project o Executive summary o Policy, legal, and administrative framework o Project description. o Baseline data o Environmental impacts o Analysis of alternatives o Environmental management plan (EMP). Covers mitigation measures, monitoring, and institutional strengthening (as outlined in OP 4.01, Annex C) o Appendices (list of EA report preparers—individuals and organizations, references, record of interagency and consultation meetings, tables/figure presenting the relevant data referred to or summarized in the main text, list of associated reports (e.g., resettlement plan or indigenous people’s development plan)  Annex C: Environmental Management Plan o Mitigation

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o Monitoring o Institutional measures o Implementation Schedule and Cost Estimates

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

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

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

The Montenegrin requirements for the EIA procedure are quite similar to the requirements of the WB, but there are some differences which are presented in the Table 2.1 below.

Table 2.1. Gaps between the World Bank OP 4.01 and Montenegrin EIA Procedure

Subject Montenegrin requirements WB requirements Screening Categorization and screening is based Screening is based on the type, location, on the EIA decree with the List 1 of sensitivity, and scale of the proposed installations and facilities requiring an project, identifying key issues including EIA and the List 2 of activities for which any resettlement and cultural property the Ministry or local authority determine concerns. whether an EIA is necessary. Categorization Category 1. (significant impact) Category A: and EA Installations and facilities to be Projects likely to have significant documentation assessed for their impact on the adverse environmental impacts that are content environment requiring full EIA (List 1). sensitive (irreversible). The study must also incorporate the Full Environmental Assessment is comments and suggestions of required, usually an ESIA. The governmental and non-governmental Environmental and Social Management organizations as well as the results of Plan (ESMP) is an integral part of the the public consultations. ESIA. Category 2. (moderate impact) Category B: Ministry (or local authority) screens the Projects with environmental impacts less project and decides whether an EIA is adverse than those of category A. These required (List 2). The law defines impacts are site-specific and, in most facilities/installations which undergo cases, mitigation measures can be screening and criteria for screening, designed more readily than for category such as size, cumulative impact, use of A projects. natural resources, sensitivity, etc. Scope of Environmental Assessment Category 3. (Low impact or no impact) (EA) is usually narrower than in All facilities and installations below the Category A projects. Usually, only an threshold levels regulated in the EIA ESMP is required. decree. Category C: Projects with minimum or no adverse impact. Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 2 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 10 / 12 First Draft of ESIA Date: December 2018

Table 2.1. Gaps between the World Bank OP 4.01 and Montenegrin EIA Procedure

Subject Montenegrin requirements WB requirements No EA is required. No action is required after screening. Public Public consultations are the The borrower is required to consult consultation responsibility of the competent project affected groups and local NGOs and disclosure institutions. about the project’s environmental and Projects from list 1: social impacts and take their views into Public disclosure and public account. consultation will be held after EIA is For Category A projects: submitted to the competent authority. It is necessary to hold public Projects from list 2: consultations at least twice: (1) shortly Projects from list 2 are made publicly after the screening and before the terms available after the documentation of reference are finalized; and (2) once a regarding the decision on EIA draft EA study is prepared. procedure is made available. Information on the proposed objectives, Depending on the screening results (if project description and potential impacts decision is taken that an EIA is are provided for the initial public required), projects from the List 2 consultations. After finalizing the draft of undergo public disclosure and public the Environmental Assessment report, it consultation, just like the projects from is necessary to disclose the document, the List 1. in the local language. In addition, for Category A projects, the borrower For Projects for which an EIA is makes the EA Report draft publicly required, EIA should be disclosed 15 available for project-affected people. calendar days prior to the public For Category B projects: consultation. The public discussion It is necessary to hold public shall be organized and chaired by the consultations at least once during the Competent Authority. EIA procedure. Reports are to be made available to the NGOs and project-affected people. The disclosure process is complete only after the EA report is officially received by the WB. EA review and The Competent Authority shall decide Before formal clearance of approval on granting the approval or rejecting environmental and social aspects of the the application for approval of the EIA project, the WB reviews the results of Study, based on the report and the EA (especially consultations, ESMP proposals of the EIA Commission. The and institutional capacities), ensuring Competent Authority is obliged to that the EA is consistent with the ToR. inform the organizations and public concerned about its decision. Mitigation and For projects requiring an EIA, mitigation Mitigation measures are included in the monitoring measures and monitoring are described ESMP. Obligation to carry out the ESMP in the EIA study, which are also and additional measures contained in included in the Environmental Permit. the ESMP needs to be included in the For other categories for which an tender documentation/contract. Environmental Permit is issued, measures for protection of air, water, Monitoring Plan is included in the ESMP. soil, flora and fauna, waste management etc., and monitoring, are included in the permit itself.

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

2.6.4. Good International Industry Practice

Good International Industry Practice (GIIP) is defined as the exercise of professional skill, diligence, prudence and foresight that would be reasonably expected from skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally.1

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

1 Source: https://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/Sustainability-At- IFC/Policies-Standards/EHS-Guidelines/

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3. PROJECT DESCRIPTION

The history of the ash and slag disposal facility at Pljevlja (Maljevac Landfill) goes back to 1979. The landfill was designed by the project organization Energoprojekt- Hidroinženjering (Belgrade) in 1979 (the overall project) for disposal of the ash generated by combustion of coal at the Pljevlja Thermal Power Plant (TPP) to produce electricity. In line with this design, the ash and slag landfill for the TPP Pljevlja was formed by construction of the Maljevac Earth Embankment Dam in the valley of Paleški stream, near Zbljevo village. The landfill was improved and extended in 1988, 1996 and 2003 in accordance with the needs for increasing the disposal area and volume.

The works were carried out in phases and since 2003 the ash and slag disposal has been organised through the process of forming two cassettes (Cassette I and II) with ash and earth embankments. A third cassette (Cassette III) is planned to be established to create further space for continuing the disposal of ash and slag generated through operation of the TPP Pljevlja. In this context, it has been planned to close Cassette II in 2018.

The Coal and Ash Disposal Facility (Ash and Slag Landfill "Maljevac") is at a distance of 800 m southwest of the TPP, which ) is located in the industrial zone of Pljevlja, at about 7 km from the city of Pljevlja. About 100 m south of the landfill there is a sawmill, and about 800 m north-east of the site a coal crushing plant is located.

The Project being assessed under this ESIA study mainly consists of two components, as follows:

- Remediation/Recultivation of Cassette II - Diversion of the Paleški Stream.

The maps, layout and relevant drawings of the Project units are provided in Appendix 3 of this ESIA report. These two Project components are financed from the World Bank loan, while other works which will be carried out on the existing Cassette and the future Cassette III will be financed with the EPCG’s resources, as well as all the other accompanying construction works.

Recultivation of the Maljevac Landfill would be done in accordance with the Rulebook on the closer characteristics of the site, conditions of construction, sanitary and technical conditions, manner of operation and closure of landfills ("Official Gazette of Montenegro", No. 31/13 and 25/16) and DPP - and UTU number 1055-1846/2 from 15 September 2016. Degraded surface at the landfill is intended for planting, by using optimal recultivation - phases of technical and biological reclamation. Maljevac Landfill is divided into Cassette I, II and III and ash and slag disposal is done in individual cassettes till they are closed at projected levels. An overview of the filled cassettes is shown in Figure 3.1. In this context, when a cassette is full, recultivation activities would start for that cassette, while the other cassette(s) is still being used for disposal. Thus, remediation/recultivation activities would be conducted in phases as follows:

- Phase 1 - Recultivation works on Cassette II and rehabilitation and re-cultivation of 4th and 5th stairs with precipitation; - Phase 2 - Recultivation works on Cassette I; - Phase 3 - Recultivation works on Cassette III in several stages.

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Phase 1 is a part of the Project, which is included in this ESIA study.

Figure 3.1. Overview of the Filled Cassettes

3.1. Remediation/Recultivation of Cassette II

Phase 1 of the recultivation of the Maljevac Landfill includes works on Cassette II. The disposal at Cassette II would be completed by the end of 2018, while the recultivation works would start in 2019. The targets of the reclamation are mainly the following:

Different methods can be used for finishing the degraded surfaces of flotation dumps, ash and slag dumps/landfills. Disposal of the material to the degraded surface at the Maljevac Landfill will be performed by using the classical method. Trucks will be used for transport of materials for finishing surfaces, while a bulldozer will be used for the abutted earth material. Disposal of the material to the external slopes is done from the top (the highest level) to the bottom (lowest level) of the peripheral embankment.

Formation of layer I is performed through a synchronized operation of trucks and bulldozers, and the height of the layer would be 1.00 m. The same would be used for the second 0.70 m high layer. It is important to note that the drainage system is formed during the work on the formation of the second layer, as shown in Figure 3.2 below. Drainage pipes are set at intervals of 30.0 m, having a diameter of Ø125 mm with inclination of 0.2%, completely perfused, and collectors (without perforation) have a Ø200 mm diameter, with a slope of 0.15%. Strong, corrugated drainage two-layer pipes made of PEHD, SN4 were adopted, as they can well sustain various peak loads. The drainage

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pipe FDK Ø125 mm is placed in a 0.35 cm wide channel. KKØ200 mm drainage collectors are also buried in marly clay, i.e. they are placed in a 0.40 m wide channel on a layer of sand, 55 cm deep and filled with sand. After installing the drainage system, reconstruction works are carried out with easier mechanization, taking care not to damage the installed drainage systems.

Figure 3.2. Drainage System at Cassette II

Part of the atmospheric water which flows through the soil to the waterproof layer of the recultivated landfill is collected by a drainage system - shallow drainage system. Collector pipes, drainage perforated pipes and filter material are buried in a layer of already laid marly clay with a height of 1.00 m.

After installation of the drainage pipes and collector, the next step is backfilling of the landfill with soil and a layer of humus. The first layer - the bottom represents a layer of marl, 0.15 m high, which will be enriched with mineral fertilizer, and the second layer - the upper, represents a layer of fertile soil (humus) 0.15 m high. After completion of the second layer, the third layer is filled, which consists of two layers of 0.15 m depth. The third layer has the role to ensure the realization of biological recultivation. The total degraded areas that need to be recultivated at Cassette II are shown in the Table 3.1 below.

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Table 3.1. Total Degraded Areas for Recultivation

Location Areas Area (m2) Total (m2) Straight 96,800 Cassette II 108,815 Sloping 12,015

The enhancement of marl layers will be done by applying the agrarian method. The first will be fertilizing the layer with 350 kg/ha, then ploughing, and again fertilizing. In order to continue with the work, it is necessary to remove this layer and flatten it. Table 3.2 summarizes the required amount of material for forming the final layer of Cassette II and Table 3.3 presents the structure of the recultivated areas according to surface characteristics and sizes.

Table 3.2. The required Amount of Material for forming the Final Layer of Cassette II

Height of the 3 Location Phase Layer Material Volume (m ) layer (m) 1 1 Marl clay 108,815 2 0.7 A mixture of marl and limestone 78,050 Cassette II 1 0.15 Marlstone 16,725 3 0.15 Arable soil 16,725

Table 3.3. Structure of Recultivated Areas

Location Phase Surface Structure Use of the Surface Area (m2) Final layer – plateau Grassing, Afforestation 96,800 Cassette II 1 Final layer of slope grassing 12,015

3.1.1. Top Cover System for Cassette II

The biological phase of optimum recultivation involves a complex of biotechnical and phyto-meliorative measures for grassing of cassette as well as cultivation of forest cultures in order to revitalize the soil and restore the damaged ecosystem. After ash disposal in Cassette II (an average level 832 m ASL) is completed, three layers, which have the role of protection, as well as preparation for biological recultivation, are placed in the technical recultivation.

The projected schedule of works envisages the completion of the closure of Cassette II in 2018. Thus, function of Cassette II ends after drying the surface. When conditions for the undisturbed operation of equipment on the surface of the cassette are met, Phase 1 recultivation can start by April 2019. Technical recultivation of Phase 1 includes the recultivation of the slope and plateau of Cassette II.

In order to start construction of the recultivation layers, it is necessary to level out the cassette plateau first, according to the projected slopes for the drainage system. After this phase is completed, the next step is formation of the first layer of marly clay. Thickness of this layer is 1.00 m. After forming the first layer, the process involves filling of the 0.70 m thick second layer formed from marlstone and limestone mixture. When this phase is completed, the 0.3 m thick third layer is filled and planned, and fertile soil (humus) is used Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 3 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 4 / 19 First Draft of ESIA Date: December 2018

in this process. The third layer consists of two layers and its role is to ensure realisation of the biological recultivation. The first layer – bottom, represents a limestone layer, 0.15 m thick, which will be enriched with mineral fertilizer, while the second layer – upper, represents a layer made of fertile soil (humus), reaching 0.15 m in height. The total height of the recultivation layers is 2.00 m. The characteristic profile of the layers of Cassette II is shown in Figure 3.3.

Figure 3.3. Display of the Characteristic Profile of the Cassette with Layers

During the works on the recultivation of Cassette II, excavation work and landslide rehabilitation would be carried out in parallel. The projected amount of arable soil to be removed from this site is 48,000 m3. Therefore, the necessary quantity of arable soil will be transported to the slope and plateau of Cassette II.

The total amount of marly clay in the First Recultivation Stage is 108,815 m3 - for recultivation of Cassette II and 60,777.5 m3 - for recultivation of 4th and 5th stairs. Marl and limestone will be provided from the mine Pljevlja PK Potrlica, i.e. from the current production of overburden (tailings). Due to the capacity of the excavation of the tailings at PK "Potrlica", there is no problem in providing the necessary quantities of this material.

During recultivation works for Cassette II, there are several types of excavation:

1. Excavation of the surface layer of land for landslide rehabilitation; 2. Excavation of the surface layer of the land for relocation of the Paleški stream; 3. Excavation of the surface layer of the soil for construction of the northern and southern circumferential channels.

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In order to ensure the necessary quantity of arable soil (humus) for the formation of the final layer on the body of the landfill, it is necessary to establish a temporary landfill. The purpose of the formation of this landfill is to ensure the continuity of works on recultivation as scheduled. After the preparation of areas intended for recultivation (technical recultivation), the works of biological recultivation starts. In the first year (2019), the plateau and slopes of Cassette II will be closed (phase 1). An overview of works that will be carried out during recultivation is provided in the Table 3.4.

Table 3.4. Overview of Recultivation Works on Cassette II

Arrange the slope of the Cassette at the projected angle (1:2 ratio) Levelling the plateau of Cassette Material planning (marly clay), along the slope and along the plateau Technical Recultivation- of Cassette II Phase 1 Levelling and compacting the terrain with a roller Works on enrichment of the third layer (0.15 m) Loading and transport of arable soil, and planting on the slope and plateau of the cassette Works on grassing of the slopes Machine seeding of grass- and plateau of Cassette II leguminous mixtures, i.e. 50 kg / (2019) ha Rolling area with grass mixtures with rollers Wetting the area sown to grass germination and thereafter, depending on the meteorological conditions. Work on the formation of the Sowing grass - leguminous protective belt of bushy mixtures, sowing depth is between Biological recultivation vegetation and trees around the 1-2 cm periphery of the plateau of Rolling a toothed roller of sown Cassette II (2020) surfaces for the purpose of establishing as good a contact between soil and seeds as possible allowing for faster and evener spacing Sprinkling (irrigation) of planted and planted areas to the emergence of the grass (if the drying period is appropriate) and, depending on the amount of precipitation Works on afforestation of Forming two rows of bun on the plateau of cassette II using periphery of plateau of Cassette II bushy plants and woody plants Forming three rows of deciduous according to the mosaic woody plants schedule (2021 year) Forming two rows of evergreen woody plants

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3.1.2. Landscape Design

According to the information from the Spatial Plan of Montenegro, the wider area of Pljevlja belongs to the type of landscape unit “Pljevaljska površ”. The bigger part of the Municipality Pljevlja belongs to the area of high mountains, whereby their altitudes range from 1400 and 2200 m asl.

The biggest karst field in the valley of the Ćehotina River is Pljevaljsko polje (Pljevaljsko field) which covers the area of 16 km2. The Ćehotina River runs through the central part of the field and it represents the main recipient in this, as well as in a much wider area.

Anthropogenic landscape is predominant in the area of Municipality Pljevlja. Influence of the urbanised city environment and mining-energy-industrial zone is recognised rather clearly. The areas with mining pits and landfills, the Thermal Power Plan and Maljevac landfill, encompass the anthropogenic areas which are characteristic of the mining- industrial towns, which are marked by distinct changes in natural landscape, degradation of space, and often by distinct lack of arrangement and recultivation.

During the process of selection of the method for biological reclamation and selection of vegetation type in accordance with the long-term purpose of using the landfill area, the starting point was that the "Maljevac" landfill is located near the settlements of Zabrđe, Zbljevo, Kalušići, Komina, Radosavac and Grevo, as well as the town of Pljevlja.

The project aims to emphasise the ecological functions of the future forest-meadow ecosystem through biological recultivation. The mentioned future anthropogenic ecosystems should ensure a relatively healthy environment with clean air, aesthetic impressions in landscape areas rich in colours of grouped mixed types of deciduous and conifer vegetation and this would be ensured through absorption and filtration of solid pollutants.

On flat surfaces along the perimeter, the protective belts of trees and shrubs (15.5 m wide) will be planted, in the quantity of 2000 pcs/ha, which corresponds to formation of a square or triangular mesh of pits with a distance of 2.24 m. Protective belt of trees and shrubs will be planted on flat surfaces on the periphery of the plateau of the Cassette II in 2020, along the 15.5 m perimeter. The next phase involves creating green surfaces with a combination of conifer trees and bushes, and this should be performed two years of forming a grass cover. Planting will be done in the form of mosaically arranged groups of trees and shrubs, in order to obtain the appropriate character of the environment. For these purposes, Black Pine (Pinus nigra), Juniper (Juniperus communis) and Rhus (Cotinus coggyria Scop.) will be used. A shrub type Rhus (Cotinus coggyria Scop.) will be planted in two rows closer to the perimeter. After that, deciduous trees such as maple (Acer obtusatum Waldst. Ec Kit. Ex. Willd.) will be planted in three rows. In the end, two rows of conifer trees like Black pine (Pinus nigra) will be planted. This method of planting aims to form a shelterbelt and enhance the aesthetic effect. Figure 3.4 illustrates formation of the protection layer around the cassette perimeter.

Out of the total area that is planned for greening, the plan involves turning around 30% of the area into walking paths, bicycle paths and rest areas.

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Figure 3.4. Formed Protection Layer around the Cassette Perimeter

Formation of individual mosaics will be done in variants as follows:

1. Bushy deciduous plants and deciduous trees 2. Evergreen shrubs and evergreen trees

The mosaic distribution of the herbal culture on the plateau of Cassette II is shown in Figure 3.5. As the final result of the reclamation, the trees with grasslands and shrubs will be replaced with the formation of areas for passive and active rest. The function of newly formed greenhouse plays a role in improving the quality of the damaged environment, fitting the landfill into the surrounding landscape and creating pleasant conditions for staying in nature.

3.2. Relocation of the Paleški Stream

One of the main issues related to environmental protection at the Maljevac ash and slag landfill is pollution of the Paleški Stream. The existing collector for the Paleški stream, which runs through the landfill, has become permeable for leachate from the landfill, and in this way, it causes uncontrolled pollution of clean waters of the Stream and River Vezišnica. Apart from this issue related to pollution of surface waters, there is also the issue of accumulation/sedimentation of the deposit inside the collector, thus its permeability is lower at certain spots.

Source of Paleški stream is located south-west of the Maljevac Landfill. A 2.9 km long watercourse flows through the Paleški stream valley. There is a 350 m height difference between the spring source (located at 1,100 m asl) and the point of its confluence with the Vezešnica River (located at the altitude of 750 m asl). The Vezešnica River flows to the north of the Maljevac Landfill and joins the Ćehotina River.

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Figure 3.5. Planned Mosaic Distribution of Herbal Culture on Cassette II Plateau

The main concrete collector was made in the valley of Paleški stream, in the part which is installed along the bottom of the landfill, and it has the length of 1,338 m with wall thickness of 60.00 cm. The collector was extended in length up to 1,460.00 m during rehabilitation of 1st, 2nd and 3rd steps. The collector is set along the bottom of the ash and slag landfill and it passes through the dam structure. There is also a secondary collector with a length of 600m.

With the aim of preventing further mixing of leachate from the ash and slag landfill with the waters of the Paleški Stream, it is planned to relocate the Paleški Stream out of the landfill area. Spring water and atmospheric waters from the associated basins reaching Paleski would be transported to the Borovičko Lake as clean water through adequate channels. It is defined in the Project documentation that polluted drainage water is kept under the landfill, at the exit from the collector, and it is then pumped into the system of process water in order to prevent pollution of the downstream basin (i.e. water from Paleški stream).

The catchment area of the Paleški stream was determined based on the available topographic maps. The catchment area is divided in two sections. The first section, which 2 has a surface area of 1.6 km , transports the surface runoff to the Borovičko Lake. The second section takes the precipitation generated water into the existing Paleški Stream and through a peripheral channel, which takes up the surface area of 0.2 km2, which may

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be seen in Figure 3.6. The total maximum stream flow at the end of this section is (Qmax) 16.20 m3/sec.

Figure 3.6. Paleški Stream Catchment Basin

The proposed new Paleški Stream route passes through private parcels and the new river bed is planned with a width of 30.0 m. In this regard, the parcels in section I are; 696/1, 718/1, 717/1, 717/2, 717/3, 717/3, 716/2, 718/2, 720/2, 721/1, 721/2, 724/1, 724/2, 724/3, 724/4, 725/1, 725/2, 725/3, 726/1, 726/2, 726/3, 726/4, 727/1, 727/2, 727/3, 79/12, 79/13, 79/4, 84/1, 84/2,84/3, 85 I 87/2. The parcels in section II are; 203/1, 203/2, 208/1, 209, 207, 210, 189, 190, 202/1, 197/1, 197/2, 197/3, 197/4, 238/6, 238/7 (Main Design, Book XI,2018). The planned route for the Paleški Stream relocation is shown in Figure 3.7 including the parcels to be affected.

Section 1 - L1 will have a length of 848 m. Dimensions for the reinforced concrete channel would be constant along its length. It would have a trapeze shape, where width of its bottom is 0.5 m, inclination of slope is 1:1, height is 0.3 m and the concrete layer thickness is 10 cm.

Section 2 - L2 will have a length of 1028 m from the asphalt road to the confluence with Borovičko Lake. The designed stream flow is 16.20 m3/sec. Dimensions of the reinforced concrete channel would be same with section 1.

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Figure 3.7. Planned Route for Paleški Stream Relocation

At section 2, it is projected to have 3 tubular drainage openings, with two AB pipes 3 Ø2200 mm, and a maximum flow (Qmax) of 16.20 m /s at the following stations:

- Km 0+004 at intersection with the regional asphalt road Bobovo - Pljevlja - Km 0+421 for connecting the parcel, which will be divided due to building the channel - Km 0+882 at the intersection with the village road

It is planned to build 3 water containers for cattle at section 2. They will be constructed at the following stations:

- Km 0+150 in immediate proximity to the village road - Km 0+480 - Km 0+790

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Water containers for cattle represent an expansion of the channel, with slope inclination of 1:3 in order to facilitate reaching the water access point, and this also involves expansion of the stream bed. Width of the access zone is 2.0 m; its length is 5.0 m and it is backfilled with grit. Fence is set around the water container for cattle, and it is made of 1.0 m high square profile pipes.

The projected stream flow for the peripheral protective channel, located on the north side, 3 is (Qmax) 2.08 m /sec. It should be mentioned that a small section of the North Channel flows into the new Paleški Stream bed. Bearing in mind that there is low volume of atmospheric water in this particular case, this is a dirt channel. The southern protection channel is made of concrete and it has trapezoid shape, and its purpose is collection of water from that part of the landfill after rainfall.

The existing collector installed through the landfill, through which Paleški Stream used to run, will stay in use. This collector will now collect leachate from the lined up contact areas and a part of the surface water which is located between the protective peripheral channels and the landfill, whereby the collector will take the water back to the recirculation system of technological waters. It is assumed that amount of this water is rather low and that it will not cause a high load of pressure in the planned pump station, which will be used for pumping the polluted landfill leachate.

Relocation of Paleški stream conditioned the course of events in which drainage water from the landfill are transported via the existing collector to the newly projected pump station, which will transport this water to the evaporation pond on the fifth step (i.e. to the elevation of K + 814 m asl) through the pipeline. Site plan of the pump station is provided in Figure 3.8.

On the basis of the quantity of flow that needs to be transported from the pump station at the level K+760 m asl to the precipitator at the level K+814 m asl, single-stage centrifugal pump with a 68 m pump head, achieving a flow rate of 20 l/s with an electric motor of 30 kW was selected. It is planned to install two pumps, one of which would be in operation, while the other one would be the back-up pump. The pumps are located in the pump station building and equipped to prevent working in dry conditions. In front of the pump station, there is a drainage pipeline, to which overflow pipe is connected after the valve. The overflow pipe serves for preventing submersion of the pump station, in case of power failure.

A reservoir with a submersible pump is provided in the pump station and it collects the possible water loss inside the building and returns it to the drainage pipeline in front of the building.

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Figure 3.8. Microstructure of the Pump Station

A completely automated operation of the pump station is foreseen. Switching the pumps on and off is regulated by a level gauge that regulates the minimum and maximum levels in the accumulation.

According to the technical solution, hydraulic facilities include;

- water chamber (normal working level 760.00 m), - suction pipeline PS (short pipes, separately for each pump unit), - drainage pipeline PS (short pipes, separately for each pump unit), - main discharge pipeline (PEHD100, unchanged diameter DN160, total length 446.7 m, nominal pressure PN16 on the part of the route from the first 275 m, and class PN10 on the part of the route from the remaining 171.7 m), and - the pressure tank, precipitator (normal working level 814.00 m).

At the point of confluence of atmospheric waters (i.e. confluence of the channels and streams), a watertight extractor will be built, whereby its depth will be up to 3 meters, while its length will be up to 10 meters, for the purpose of prevention of water leakage through the ground and its further movement towards the collector. The construction is reinforced- concrete with mesh reinforcement. The construction of the pump station has a skeletal static system, filled with hollow clay blocks. The access to the pump station is prevised by the existing soil road.

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3.3. Reclamation and Recultivation of the 4th and 5th Step and Construction of the Precipitator

Measures for reclamation of localized damages on the slope of the 5th step are defined by the project documentation. Activities which will be taken in order to perform reclamation and maintain stability of the slopes are as follows:

- Cutting slopes, with the inclination of 1:3, up to the existing channel at the bottom of the step; - After cutting, performing earth backfilling up to the point of reaching the 30 cm thick layer, coupled with setting humus on the slopes, filling and placing HDPE foil.

Upon completion of the works on reclamation of the slopes of the 4th and 5th step, it is necessary to build a new precipitator on the 5th step, bearing in mind that the current precipitator will be back filled, and this should be done after recultivation of Cassette II. The principal role of the precipitator is collection of drainage, leachate and runoff water from the newly-formed Cassette III, as well as collection of runoff water from the existing cassettes.

Material excavated for the purpose of construction of the new precipitator will be used for back filling of the existing precipitator. Width of the bottom of the new precipitator is 10 m and it has the length of 402 m, while its slope inclination is 1:2. Designed inclination of the bottom of the precipitator is 0.1%. The final elevation point of the precipitator is 814 m asl.

Before construction of the precipitator, it is planned to build a receiving chamber, which will be used for collecting the pumped water from the pump station, at the exit point of the Paleški Stream collector, while it will also be used as a precipitator for collecting water during the process of sprinkling the surface of the active cassettes. Excess water from the chamber will be taken into the precipitator through PVC pipes with a Ø300 diameter. Water from the precipitator further flows over the overflow chamber, which has a Ø1000 mm diameter and 3.5 m height, into the steel pipeline with a Ø500 mm diameter. It is further transported through the existing pipeline to the excavator pump station into the existing recirculation system.

Infiltration of water from the precipitator into the landfill will be prevented by coating this facility with marly clay, which has permeability coefficient of 10-9 m/sec, whereby this layer would be 1.0 m thick. After operation of the precipitator and chamber is no longer required, upon the exploitation phase of the landfill is over, it is planned to perform back filling of these facilities, as well as recultivation of the 5th step, up to the elevation level 814,30 m asl.

Before back filling of the precipitator is performed, an HDPE pipe, with a Ø200 mm diameter, will be installed, whereby the pipe will be completely perforated and have the length of 400 m and longitudinal fall of 0.1%, and it will be used for taking all the leachate from the recultivated surface to the precipitator. A surpass should be made on the overflow chamber, which has a Ø1000 mm diameter, and this facility should be turned into a retention chamber, with a Ø1000 mm diameter which will be used for revision of the pipe network and potential cleaning of the drainage pipeline. The drainage steel pipe, with a Ø500 mm diameter, will still be operational. This leachate will further be taken through concrete channels and connected to the peripheral channel.

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The precipitator and the chamber should be back filled with tailings, up to the level of 814 m asl, without compression. The stipulated amount of material is 14,112 m3. After this, the process of back filling the soil is performed in a layer of 30 cm. Back filing will be performed by using the material generated by reclamation of the slope of the 5th step. After forming a layer of soil, the process of forming a lawn (i.e. planting lawn turf or planting grass seeds) will be performed. Surface area that will be grassed on the 5th step is 44,700.00 m2.

Formation of lawn represents an important process in revitalization of the degraded surfaces. Grassing of the degraded surfaces will be performed by the means of a new method of hydro-seeding. Advantages of the grassing method may be seen in prevention of eolian processes on degraded surfaces and improvement of slope stability.

3.4. Leachate Management

At the existing Maljevac Landfill there is a system for collection and recirculation of overflowing technological water. This waster is recirculated back to the ‘bagger pump station’ for preparation of hydro mixture of ash and water with ratios of 1:6 to 1:10. Additionally, atmospheric waters from the surface of the landfill are evacuated by the same principle.

Annual average production of ash and slag is 577,335 m3 and flow of hydro mixture is 0.019 m3/sec in average. In case of 8 months of operation, the average hydro mixture flow is 0.028 m3/sec. It can be calculated that average flow in the hydro transport system is (Qav) is 25 L/sec. Installed capacity of the bagger pump station is (Qpump) 650 m3/hour or 0.180 m3/sec.

Maljevac Landfill is generating the following types of water:

- Atmospheric waters (surface runoff) - Technological waters – it is drained as overflow water in one section, while the other part infiltrates the lower layers of the landfill - Leachate – part of the technological water which remains in the landfill.

3.4.1. Leachate Collection

Discharge of the technological water from the landfill consists of a system of concrete overflow shafts that are inside the active cassettes. Plastic pipelines take water from the landfill to the entrance of the horizontal precipitation channel where secondary deposition of the finest ash particles takes place.

At the exit from the sedimentary channel there is an overflow structure with two overflow openings which are connected with two overflow pipes where one has 500 mm diameter from the beginning to the end, while the other pipeline is 250 mm in diameter. By using these two pipelines, the overflowing technological water further drains to the pool next to the bagger pump station. The overflow construction will face small changes regarding lowering the overflow ledge, so the drainage waters can be discharged through the system. Horizontal precipitation channel will be moved down the 5th stair. The new precipitation channel will be coated with a layer of 1.00 m thick clay and 2.5 mm thick

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HDPE foil. This would serve for preventing penetration of groundwater into the body of the dam and to provide greater stability of construction. The existing channel is built in the ash and therefore certain amount of water is passing through affecting the quantities of water that will be recirculated. The current status of the sedimentation channel can be seen in Figure 3.9.

Figure 3.9. Current status of sedimentation channel (September, 2018)

The project design proposes that existing sedimentation channel is filled with clay, and that a new sedimentation channel is built in its proximate vicinity. Construction of the new sedimentation channel, which will be impermeable, will create conditions for safe drainage of overflow water and leachate from the landfill. The existing channel is made from ash, so leachate passes through freely and it is drained in the lower parts of the dam. This situation affects the level of ground water in the landfill, which directly impact the stability coefficient of the entire landfill slope.

The new channel will be a trapezoidal cross section with a 1:1 slope of 10.0 meters width at the bottom. The starting point of the newly projected horizontal precipitator is K+811.15 m asl. Level of the new channel on the stream in the collecting shaft is K + 810.70 m asl.

Due to the stability of the landfill, it is necessary to continuously drain the water from the body of the landfill. Technological water is partly discharged as overflow water while one part is submerging (i.e. infiltrates the body of the landfill). In order to achieve necessary coefficient of stability of the embankment, groundwater must be well maintained. The most efficient way to regulate the level of groundwater is construction of an appropriate drainage system for drainage waters. With adequate drainage system coefficient of safety of the embankment will be increased. Reducing level of the groundwater in the embankment body with efficient drainage system will be increase the volume of the cassettes for ash and slag disposal. If there is established adequate water drainage system, there will be better drying of the deposited material in the cassettes for ash

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disposal. It is important to point out that drainage pipes are connected to the overflow shaft.

Existing situation regarding the discharge of atmospheric waters from the active landfill is showing that waters are partly drained through the already installed drainage system and partly through the soil peripheral channel excavated around the landfill. Waters that are falling on the surrounding basins around the landfill as well as the Paleški stream are taken through the concrete collector below the body of the landfill.

3.4.2. Leachate Handling

Atmospheric waters related to the Maljevac Landfill can be divided in two groups as; waters that are falling on the catchment basins and reaching the landfill as surface runoff, and precipitation falling on the body of the landfill. In the scope of the Project it is planned to relocate Paleški Stream from the west side of the landfill and to take away the atmospheric waters that are falling on the catchment basin to the Borovičko Lake.

In order to protect atmospheric waters from the body of the closed landfill it is envisaged a system of concrete trapezoidal circumferential channels. Water will be collected in these channels and will be partially discharged into the downstream part of the dam, behind the main collector's outlet into the Paleški stream. The other part will go into the deviation of the Paleški stream, under the asphalt road towards Borovičko Lake. Planned network of peripheral channels will be connected to existing channels on the dam. Waters from the lid and sides of the landfill will be collected by the drainage system and the floor channels and further collected into the peripheral channel with pipes and corrugations. Waters from the 5th stair will be taken to the existing channel system.

Atmospheric waters that fall on the surface of the re-cultivated landfill are collected by the drainage pipe system. The average length of the pipeline per 1.0 ha is about 700 m. Water that is collected on this way is carried out through the channels and floor channels to the planned peripheral channels or the displaced riverbed of Paleški stream.

For the purposes of discharge of the waters that are located in the lower parts of the landfill, it will be necessary to build drainage wells on the plateau of 5th step, from which pumps will pump out water to the horizontal precipitator. In this way water level above the collector will be reduced and therefore the water pressure as well. Moreover, water filtering through the walls of the collector and the pollution of waters in the Paleški stream will be decreased.

Additionally, reducing water level in the lower layers of the landfill will directly affect the increase in stability coefficient. It is estimated that it is necessary to build 11 wells that can be realized at once or in 2 phases (6 + 5). The wells would be placed at the location of the old horizontal precipitation channel after its closure.

3.5. Drainage Works and Flood Control

The existence of the flowing water on the embankments, as well as the appearance of the coatings of the materials, indicate a high level of groundwater in the body of the landfill and this points at a very critical situation in terms of stability. In case of detecting such

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phenomena, urgent intervention is needed, and urgent rehabilitation measures should be implemented. This involves lowering the water level in the embankment body.

It can be achieved by pumping a certain amount of water from the body of the landfill or by extending the banks from the embankments to the interior, which reduces the level of the flow waters in the embankment itself. The occurrence of suffusion means washing away small particles from the embankment. Washing away and transporting particles from the embankment is causing creation of caverns, cavities in the body of the embankment which, as a consequence, may result in sudden collapse of certain parts of the embankment.

If planned dynamic of the construction of the embankment is not reached, which is envisaging a minimum difference between the height of the embankment crown and the water level in the accumulation area of 1 m, due to the heavy precipitation or accidental drops of various objects in the accumulation space of the active cassette, it can cause partial closing of the openings on overflowing shafts and local embankment spilling. Therefore, it is necessary (at least at the beginning and at the end of the shift) to visit the landfill and record all the observations into the observation log. Frequency of these observations should be done on a daily basis. All observed changes should be recorded in the observation log with the exact description, geodetic coordinates and photos of critical sites.

3.6. Personnel Requirements

The Developers of ESIA were provided with a tabular overview of the job classification at the Elektroprivreda Crne Gore (EPCG) JSC Nikšić, Department for Integrated Management System (IMS), which is divided into three departments, as follows:

 Department for quality systems - 3 employees,  Department for safety and health at work - 4 employees;  Department for environmental protection - 3 employees.

In line with the Rulebook on job classification in the Thermal Power Plant Pljevlja, Landfill Manager was one of the classified work positions where 5 work positions for environmental protection were classified as follows:

 Expert for safety and health at work - 1 employee;  Expert for environmental protection - 1 employee;  Expert for protection and rescuing - 1 employee,  Technician for fire protection and environmental protection - 1 employee,  Administrative staff - 1 employee.

Elektroprivreda Crne Gore JSC Nikšić has adopted the QUALITY POLICY No. 10-00- 11228, dated 13 March 2018 and it was signed by the President of the Board of Directors. Management of the Elektroprivreda Crne Gore JSC Nikšić and all its employees are committed to continuous improvement of the Integrated Management System (IMS), through environmental protection and protection of health at work, in line with the requirements set by the standards ISO 9001:2015, ISO 14001:2015 and OHSAS 18001:2007 in the areas of organisation of production of electrical energy, electrical energy supply, buying and selling of electrical energy, construction and maintenance of Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 3 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 18 / 19 First Draft of ESIA Date: December 2018

energy facilities, as well as designing and carrying out supervision within the defined activities.

3.7. Machinery and Equipment Requirements

In order to start levelling Cassette II plateau with the inclinations necessary for drainage, it is first necessary to bring levels of the peripheral embankments to the average elevation point of K+832 m. Also, it is necessary to remove part of the material (ash) from the south slope, due to filling the empty space and bringing the slope to the projected condition with a 1:2 inclination. The filled space at the southern slope of the Cassette II shall then be compressed by a roller. The total volume of material has been estimated to be about 22,000 m3. A bulldozer will be used for performing the prevised activities.

Upon regulation of Cassette II slope, it is necessary to perform compression of the material (i.e. ash, with the goal of increasing safety of the slope and stabilisation of the terrain). Compression and levelling will be performed by using a roller.

For the purpose of levelling the surface of Cassette II, upon filling it up, a grader will be needed in order to provide the projected drop structures for the purpose of installing the drainage system. This machine will be used with the aim of levelling out the surface of the Cassette II plateau, which is in the form of dried ash, in line with the projected drop structures.

A construction truck and bulldozer will be needed for forming the final layer of Cassette II. The type of machine which will be used for transporting the material for technical recultivation of the Cassette II are the trucks with capacity of 17.5 m3 and carrying capacity of 28 t.

3.8. Project Schedule

The planned schedule/dynamics of the works on the landfill previses filling Cassette II to the level of K+832 m asl in 2018 and start of recultivation in 2019 and completion of recultivation in about a year.

The other works that will be performed on the landfill include filling up of Cassette I by October 2019 and filling of Cassette III in several phases from October 2019 until September 2025. It is necessary to perform recultivation of the cassettes in phases. In this way the dynamics of works on the landfill will be tracked and recultivation activities will be performed on the cassettes after each of them are taken out of operation respectively.

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4. ENVIRONMENTAL AND SOCIAL BASELINE CONDITIONS

4.1. Study Area and Sources of Baseline Information

The Project area is located in the borders of Pljevlja Municipality, which is located in the northern part of the Republic of Montenegro, in the region of mountainous Montenegro. The Project area consists of Cassette II of the Maljevac ash and slag landfill and the adjacent area where Paleski Stream would be relocated. Maljevac Landfill is located at 800 m southwest of the TPP and the closest settlement to the site is Zbljevo. TPP is located in the industrial zone of Pljevlja, at the fourth kilometer of the road Pljevlja - Đurđević Tara - Žabljak, with an altitude of 760 m.

4.1.1. Potential Area of Influence of the Project

Potential area of influence (AoI) of the Project would include the geographical area that potential impacts of the Project could extent. In this regard, the AoI for physical and biological environment would include the Project footprint (Cassette II area), the upstream and downstream of the Paleški Stream and the new stream bed reaching to the Borovica Lake. In terms of socioeconomic environment, the AoI would include the close-by settlements mainly Zbljevo and Podrogatac. The close vicinity of the Project area and the AoI can be seen in Figure 4.1.

Figure 4.1. Project Area and the AoI

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4.1.2. Sources of Baseline Data

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

4.2. Characteristics of the Physical Environment

4.2.1. Topography, Geology, Hydrogeology and Hydrology of the Region

4.2.1.1 Topography

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

In the immediate vicinity of the town of Pljevlja is a lagoon of charcoal called "Potrlica" that covers the northern, north-western, eastern, central and southern parts of the basin, and the site "Cementar" is located on the northwest side of the lagoon (see Figure 4.2). West of PK Cementara (cement factory) there is TPP "Pljevlja", and the ash and slag disposal site “Maljevac” is located at a distance of about 800 m.

Figure 4.2. Spatial Position of Facilities in the Region

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The area of Thermal Power Plant Pljevlja (TPP) is located in the industrial zone of Pljevlja. Nearby environment of the TPP is sparsely populated, but in the wider surroundings there are several smaller settlements: Zabrdje, Kalušići, Komina, Radosavac and Grevo. In the immediate vicinity of the ash and slag disposal site "Maljevac" there is the village Zbljevo. The ash and slag landfill Maljevac and the TPP can be seen in Figures 4.3.

Figure 4.3. TPP “Pljevlja’’ and Landfill”Maljevac’’

The Maljevac landfill belongs to the group of wet landfills. The landfill was formed by construction of the Maljevac dam in the valley of the Paleški stream near the settlement Zbljevo. The source of the Paleški stream is located southwest of the Maljevac landfill. Through the valley the stream flows for 2.9 km and there is a 350 m elevation difference between the source of the stream (at 1100 m elevation) and the Vezišnica River (at 750 m asl), which Paleski Stream joins. At the moment Paleški stream flows in a collector of 1338 m length, which is set up downhill the valley of the Paleški stream along the bottom of the ash and slag landfill and passes through the body of the dam.

About 100 m south of the landfill there is an industrial facility – sawmill. There is the TPP at about 800 m north-east of the site and on the east side there is a crushing plant for grinding coal located at a distance of about again 800 m from the landfill.

4.2.1.2. Geology

In the territory of the Municipality of Pljevlja, clastic and carbonate sediments of carbon perm, perma, perm-triassium, then clastic and carbonate sediments and volcanic wall triads, sedimentary and magmatic walls from the Jurassic period, flysch sediments from the Jurassic-Cretaceous period (marls, clay, coal, coal clay neogenes) and quaternary creations are found. Figure 4.4 shows the geological map of the site with the wider environment.

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Figure 4.4. Geological Map of the Maljevac Landfill and the Surrounding Area

On the site of the Maljevac Landfill there are lake sediments from the Middle Miocene (M2), with sub-marine and sandy clays as the oldest member of the Middle Miocene (M12), coal layer, i.e. carbon zone (M2-2) and, ultimately, roof marls (M3). Miocene floor clays lie transgressive and discordant across the paleo-lobe, which consists of Palaeozoic sediments (C, P) and Triassic (T1, T2 1 and T2 2).

Palaeozoic sediments are represented by argillosists, limestone, clay, conglomerates, sand and slides. The sediments of the Early Triassic are sand, marl and limestone. Anise sediments are represented by limestones and dolomites, while limestones with rosaries of Ladinian age. Quaternary alluvial sediments (al) are present in the valley of the Vezisnica River and its larger tributaries.

4.2.1.3. Hydrogeology

Due to complexity of the lithological composition and structure of the porosity, various formation types are present in the area of Pljevlja; compacted, karstic, karst-cracking and cracked type. The reduced type released with the free level and under pressure has certain distribution within alluvial (gravel-sandy) sediments, along the river bed of Ćehotina River and its tributaries, as well as within the neogenic basins; Maoški, Mataruški, Otilović, Pljevlja and Glišnik.

The karstic and karstic-cracked type is present in the area of Ljubišnja, Lisac, Gradina, Jabuka and paleoheroes of neogene basins. On this part of the terrain, surface swelling of atmospheric waters is mostly lacking, except through the Ćehotina watercourse and its tributaries that used deep canyon valleys. Developed karst forms (sinks, spores, sorghum) enable direct infiltration of ground waters, which are circulated in a wide network of karst channels of various shapes and sizes into deeper parts of the terrain, where the broken carcasses are formed.

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The cracked type is represented in the area of magmatic, metamorphic and bound insoluble sedimentary rocks, most often within the diabase-rocks formation represented by sand, rosaries, clays, diabases, as well as layered limestone and dolomites with rosaries from the Jurassic era. This sort of aquifer is emptied through a series of sources of small prowess as Dzikin spring near Donji Gradac.

Although Pljevlja is a city with a relatively small amount of annual precipitation, geomorphologic, geological and climatic characteristics have caused the area to have a very developed network of watercourses. All water currents, rivers, streams and torrents in the area of Pljevlja are being poured into Ćehotina. The largest tributaries are Breznica and Vežišnica. There are also hot springs that enrich its natural balance. Breznica springs on the northern edge of the basin from a cave at a height of 800 m. The length of the stream is 3.5 km. It is an important tributary because it flows through the center of the city and the city uses the Breznica River as a domestic water source. Vezisnica is the left tributary of the river Cehotina. The length of the river is about 15 km. The waters of the Great Peripheral Canal, the waste waters from the TPP and the Paleški Stream flows into the Vešišnica River. The great peripheral channel was built for the purpose of collecting water from the area of the Borovica and accepting the waters of the Šumani brook, and the Red stream and the Tavnik spring.

The area of the Maljevac Landfill is characterized by the presence of compacted, cracked, and karst type soils. The wall masses are distinguished by crack-cavernous porosity with a system of differently oriented cracks that intersect the wall mass in depth, as well as inter-grain porosity, where supercapilar porosity prevails. This structure caused different hydrogeological functions of the rock masses, i.e. their division into (1) hydrogeological collectors, (2) hydrogeological complex and (3) hydrogeological isolators.

Hydrogeological collectors are deposits of intergranular, cracked and cavity-cavernous porosity. These are fine diluvial materials on the surface of the terrain, then pebbly alluvial deposits, as well as layered and bank limestone and dolomite. They show good, medium to poor waterproof properties. Hydrogeological complexes make neogene deposits. They are locally watertight to waterproof characteristics. They are trapped within the paleo-liver depression. Within the neogene complex, clayey-marlaceous sediments with coal particles are predominant, where there is a frequent change in the filtration characteristics in depth, depending on the local cracks and the racemic zones, which makes them into the hydrogeological complex. Hydrogeological insulators are Palaeozoic sediments are; filites, argilloscopes, marls, pedestrians, glints and shards. Waterproof characteristics have clays, clay marls, pedestrians with thin clays of coal and clay (M2).

Particularly important is the presence of water-impermeable clays as hydrogeological insulators in the area of the Maljevac Landfill, which can have a significant influence on the technical solutions for the exploitation of the Maljevac landfill.

4.2.1.4. Hydrological Characteristics

In terms of hydrology, the area of Municipality Pljevlja is mainly in the Ćehotina river basin and its tributaries. Out of the total surface area of the Municipality Pljevlja (1347 km2), the Cehotina basin takes up 994.6 km2 (74%), the Tara basin covers 318.8 km2 (24%), while the Lim basin covers surface area of 33.6 km2 (2%). The watercourses of these basins have their specific hydrographic characteristics.

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The source of the Cehotina River is located under the foot of Stozer Mountain and direction of its flow is South East-North West, all the way to the point of its confluence with the Drina River. The total surface area of the Cehotina basin is 1404 km2. The hydrographic network includes a considerable number of smaller tributaries, rivers and streams, with the most significant being; Voloder (with drainage area of 57 km2) and Vezisnica (with drainage area of 99.6 km2). The length of Cehotina in Municipality Pljevlja is 64.9 km. The total length of significant streams in the Cehotina river basin on the territory of Montenegro is 198.2 km. Considering that the Pljevlja basin, including the river Cehotina, is marked by a rain-snow regime, water level is the highest in spring, due to strong spring rains and intense snow melting.

The length of the Tara River in the Municipality Pljevlja is 40.5 km. Its most important tributaries are Draga (length 12.5 km) and Selacka rivers (length 8 km). A part of the territory of the Municipality Pljevlja belongs to the river basin of Lim (north part from Gradac). The waters are drained by the Poblacnica River, which has a length of 5.1 km.

There are a large number of springs in the Municipality Pljevlja (more than 100). Most of them are used for local water supply. Drinking/domestic waters in the Pljevlja water supply system is obtained from the following sources:

 Carst spring Jugostica  Carst spring Breznica  Springs in area of Potpece, Mandojevac, Zmajevac and Bezarska  Water reservoir Otilovici

Water capping for the carst spring Jugostica was built in 1898 and reconstructed in 1985. This carst spring is 7 km away from Pljevlja. According to the data gathered from literature regarding the results of examinations on samples of raw water sources, the physico-chemical characteristics and the bacterial characteristics of this water show extreme values for water turbidity, electrical conductivity, total number of germs and type of identified microorganisms. No sanitary protection zones have been identified for the affected spring, and the direct protection of the capping facility is very poor.

The Breznica Stream (Bezdan) is located about 1 km northeast of Pljevlja, between Borovec (K 1129 m) and Golubinje (K 986 m), at the approximate elevation point 780 m asl. A watercourse with the same name is formed from the spring, and it is a main tributary of the Cehotina River. The quality of the water indicates presence of bacterial pollution. The waters from the Breznica Stream (as well as the source Jugostice) are subject to occasional turbidity after heavy precipitation. No sanitary protection zones have been identified for this water source. The only element that was established is the zone of indirect spring protection. In recent years, there has been a decline in the volume of this source during summer period that has led to almost completely excluding this source from the water supply system.

The Mandojevac Stream, Zmajevac and Bezar carst sources are located about 12 km south of Pljevlja, in the upper basin of the Vezisnica. The quality of water is better than the previous two sources. All spring-water capping systems are concrete, have rectangular shape, and their size ranges from 15 - 20 m2. All objects are protected by a wire fence, which is in a satisfactory condition only around the Bezgarska source capping system, while the other two sources have been destroyed, thus there is free access to the

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sources. The Zmajevac capping system is located up the stream, so there is a risk that this part of stream may get damaged due to large water inflow. No sanitary protection zones have been identified for this group of sources.

Reservoir Otilovici on the Cehotina River was formed in 1981, primarily for the needs of TPP Pljevlja. Since 1986, stored water has been used in the city water supply system as well. Volume of the Reservoir Otilovici is 18 × 106 m3.The pump capacity limits the amount of water supplied to about 80 l/s. Without further purification, Otilovici water will not fulfil the conditions for the quality of drinking water. Zone of sanitary protection has not been established as a source of drinking water. The dam and entrance structures are under the supervision of a permanent protection service. The water from the reservoir Otilovici is transported to the water treatment plant on the Velika Plijes Hill before distribution to the water supply network.

Borovicko Lake was formed about 15 years ago in the former coal basin Borovik. The surface area of the lake is about 22 ha, with the depth of 1-40 m. Two streams, Ljucanik and Smrdan are poured into the lake, and there are plenty of underground sources with good quality water. Water flows from the lake to the river Vezisnica. The area around the lake is uncultivated and wavy, covered with reed in the coastal belt. Currently, the Borovicko Lake is used for fishing and recreation.

The valley, where the ash and slag landfill was built, runs in south-west direction, and the surface area of the basin is 2.79 km2, while the length of the basin is 2.9 km. The altitude difference in the basin is 350 m (the lowest elevation point is 750 m asl and the highest is 1100 m asl). Runoff from the basin flows into the Paleski Stream, downstream of the landfill, and then into the Vezesnica River. The valley is dry for most of the year, but after strong precipitation, temporary runoff is generated in the valley surrounding the landfill.

4.2.2. Erosion and Land Use

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

The site is a landfill of electrolytic ash and slag from coal combustion in the TPP. Electro filtration ash belongs to a group of bases (carbonate) ash, with relatively high in CaO content and relatively low in SiO2 content. In this sense, the landfill itself is typically anthropogenic land, where the previous natural layer is practically destroyed by human intervention.

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4.2.3. Climate

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

Air temperature

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

Precipitation

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

Humidity, Cloudiness and Occurrence of Fog and Soot

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

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

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Winds

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

4.2.4. Seismicity

The wider area of municipality of Pljevlja belongs to the seismically relatively quiet region with a degree of seismic intensity of VII-degree MCS scale (see Figure 4.5), while the level of the expected maximum soil acceleration agmax is 0.11, or 11% of the acceleration of the Earth's gravity within the return period of 475 years (Figure 4.6).

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

4.3. Quality of Physical Environment

The baseline environmental quality at the Project location and its surroundings is evaluated and presented in this ESIA Report based on; annual Information on the state of the environment in Montenegro as a result of the State Environmental Monitoring Program, regular measurement results of EPCG at the TPP Pljevlja and surroundings; measurement carried out during the preparation of technical documentation for the Maljevac Landfill Rehabilitation Project, and measurements carried out during preparation of the Special Purpose Spatial Plan for TPP Pljevlja.

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Figure 4.5. Map of Seismic Reionization of Territory of Montenegro

Figure 4.6. Isolines for a Return Period of 475 Years

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4.3.1. Water Quality

Water quality of the rivers Ćehotina and Vezišnica (regular state monitoring)

The quality of Vezišnica and Cehotina rivers is regularly monitored through state measuring station. Determination of the water quality class has been performed by comparing the relevant values of water quality parameters with the limit values in the Regulation on classification and categorization of water (Official Gazette of Montenegro 2/07). By purpose, water is divided into water that can be used for; drinking and food industry, water that can be used for fishery and shellfish farming and water that can be used for bathing (see Table 4.1).

Table 4.1. Regulatory Classification and Categorization of Surface and Groundwater

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

Regulation on Classification and Categorization of Surface and Ground Water has established Environmental Quality Standard (EQS) values for all main rivers in Montenegro, in the format AnSnKn where: code A is a category for water representing basic physico-chemical standards, S, Š or C is the assessment for fisheries water and K is the assessment for bathing water. According to the quality of water that needs to maintain or provide for achieving good status of water, Ćehotina and Vezisnica rivers are classified as presented in Table 4.2.

Table 4.2. Required Quality of Cehotina and Vezisnica

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

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

The river Vezisnica was sampled at 1 location, upstream of the confluence of Ćehotina and the water required the A1SK1 class. The state of quality in 2017 was far from desired and only 25.0% of certain parameters were in the prescribed class, so this watercourse is still assessed as the most polluted. The water is mostly affected by the wastewater of TPP Pljevlja, human activities along its course and low water flow. Table 4.3 provides comparison of required and established quality class of Cehotina and Vezisnica per parameters.

Table 4.3. Comparison of Required and Established Quality Class of Cehotina and Vezisnica

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

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

PER PARAMETER PER

A Out of all classes A3 A2

- classes O2 S, Š S, Š C, Š S, Š S, Š BOD5 Out of all A3 A3 A3 A3

CLASS CLASS classes COD A2 A2 Out of all classes A3 A2 Iron A1 A2 A3 A2 A1 Ammonia Out of all Out of all A2, S Out of all classes A3, C

BLISHED BLISHED classes classes Chlorides A A A A A Sulphates A1 A2 A3 A2 A2

ESTA Phosphates Out of all Out of all Out of all A2 Out of all classes classes classes classes

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

Water Quality of Paleski Stream (results of regular monitoring of EPCG)

During 2018, EPCG hired a certified laboratory CETI LLC (Centre for Ecotoxicological Research Podgorica) for the purpose of monitoring. Thereby, targeted measurement of the surface water quality on the Maljevac landfill was performed. The analysis was done on all parameters in accordance with the Regulation (Official Gazette of Montenegro 2/07). Table 4.4 shows the water quality analyses results for the parameters that exceed the legally permitted limit value in the water samples from the Paleški stream, both upstream and downstream from the Maljevac Landfill, conducted in June 2018.

Table 4.4. Results of Analysis of Water Samples from the Paleški Stream (Upstream and Downstream from the Maljevac Landfill)

Analysis results MPC per class Paleški stream Paleški stream – MAC MAC MAC PARAMETERS Unit MAC A – upstream downstream A1 A2 A3 < than Cyanides mg/L 0.010 ±0.001 0.085 ±0.009 0.001 0.005 0.005 MDL* Chemical Oxygen mg/L 20.7 ± 1.2 1.9 ± 0.1 1 2 4 8 Demand (COD) * Minimum detection limit (MDL)

Determination of the water quality class in Paleski Stream was performed by comparing the relevant values of water quality parameters with the limit values in the Regulation on classification and categorization of water. According to the results of physical-chemical analysis, water samples from Paleski stream that have been taken upstream and downstream from the landfill belong to none of the classes of the Regulation on classification and categorization of water because of increased COD and cyanide concentrations.

Groundwater Quality (results of regular monitoring of EPCG)

Determination of the groundwater quality in the area was performed by comparing the relevant values of water quality parameters with the limit values in the Regulation on classification and categorization of water (Official Gazette of Montenegro 2/07). Water was sampled in June 2018 at the existing piezometers (PZ1 and PZ2) - from the body and from the base of the dam of Maljevac Landfill. The results are provided in Tables 4.5. The analysis was done on all parameters in accordance with the Regulation (Official Gazette of Montenegro 2/07) and the following table shows only water quality analyses results for the parameters that exceed the legally permitted limit value.

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water because of increased turbidity, electrical conductivity, suspended particles, COD (chemical oxygen consumption) and nitrite levels.

Table 4.5. Groundwater Analysis Results

Analysis results MPC per class Landfill – dam Landfill – base MAC MAC PARAMETERS Unit MAC A MAC A2 body (PZ1) body (PZ2) A1 A3 Turbidity NTU 1150 ±78 69±5 1 5 5 10 Electrical µS/cm 1307 ±7 1237 ±7 300 400 600 1000 conductivity Total suspended mg/l 1673.6 118 0 10 20 50 particles < than Nitrites mg/l 11.1 ±0.02 4.8 ±0.01 0.003 0.005 0.02 MDL Chemical Oxygen mg/l 137 ± 8 8.3 ± 0.5 1 2 4 8 Demand (COD) O2

4.3.2. Soil Quality

The program for the testing of harmful substances in the soil has been implemented since 1999 in accordance with the Environmental Law and the Ordinance on permitted quantities of hazardous and harmful substances in the soil and methods for its examination (Official Gazette of the Republic of Montenegro 18/97). The maximum permitted quantities of hazardous and harmful substances are given in Appendix 5 together with soil quality analysis results.

4.3.2.1. Soil Quality in the Area of Municipality Pljevlja

In Pljevlja area soil sampling was performed continuously in the period of 2009-2017 at Village Komini and TPP Pljevlja tailings pond. Deviations from the prescribed concentrations have been observed in the analysis of soil samples taken at locations of TPP Pljevlja tailing pond (referring to the increased content of nickel in 2009, 2010 and 2012 and arsenic in 2009, 2010 and 2011). Content of lead was below the values, which have been stipulated as the norm by the Rulebook at all locations. Figures 4.7, Figure 4.8 and Figure 4.9 show concentration of certain Ni, As and PB measured in the period from 2009 to 2017.

In 2017, soil samples were taken at a site near the tailing pond of Pljevlja TPP and at Komini location. It was determined that the content of fluorine exceeds the maximum permissible concentration specified in the Rule book in these samples, while the contents of other inorganic and all organic parameters are within the prescribed values. The increased content of fluorine in soil samples from these locations is attributed to the characteristic composition of the soil in Montenegro, which is naturally rich in fluorine.

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Figure 4.7. Nickel (Ni) Concentrations in mg/kg in Pljevlja Sampling Sites (2009- 2017)

Figure 4.8. Arsenic (As) Concentrations in mg/kg in Pljevlja Sampling Sites (2009- 2017)

Figure 4.9. Lead (Pb) Concentrations in mg/kg in Pljevlja Sampling Sites (2009- 2017)

4.3.2.2. Soil Quality in Komini and Zabrdje Villages

In the scope of the “Study for Determination of Zero State Emission from TPP” (Study "0") of 2006, the Centre for Ecotoxicological Research of Montenegro stipulated taking 6 composite soil samples from arable and non-arable pieces of land in the villages Komini and Zabrđe. Over the years, these settlements have always represented the most vulnerable areas due to deposition of ashes and emission of ash and particles from TPP

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Pljevlja. The analysis was performed for parameters stipulated by the Rulebook on permissible concentrations of harmful and hazardous substances in soil and methods for their analysis (Official Gazette of the Republic of Montenegro, No. 18/97). According to the results of 2006, physical and chemical analyses of the soil samples meet the requirements of the Rulebook on the permitted quantities of dangerous and harmful substances in the soil.

4.3.2.3. Soil Quality around the Maljevac Landfill

Soil is a fundamental component of the environment and it is directly connected with the impact on the health of people as well as all the living beings. Activities related to the operation of the landfill cause degradation of the soil surface and they change its shape. Ash and slag have been deposited on the Maljevac landfill for several decades (since 1982) and it is necessary to expand the capacity of the landfill in order to ensure its further operation, so this process leads to degradation of the new soil surfaces.

Potential adverse negative effects may occur during dust emission from the dry areas of the landfill, in case the protective measures have not been implemented. In the event of this occurrence, dust particles will start spreading around the landfill. It is for this reason that certain analyses of the quality of the soil around the landfill have been performed in order to determine the condition of the soil. The analyses of the quality of the soil at the subject locations were carried out in 2012, 2014 and 2018.

In 2012 soil samples were taken from the vicinity of the landfill at 6 locations from a depth of 50 cm. According to the analysed parameters, it can be concluded the landfill does not have significant impact on the surrounding soil. In 2 samples increased pH levels, content of Ca, Na, Mg were recorded. In 2 of these locations higher values might be connected to dispersion of ash by wind, which occurs in those directions. The other sampling point was located in the area where a temporary slag landfill for waste from the town boiler room was used to be located. Detailed description of the sampling points as well as the results of the analysis is given in the National Environmental Impact Assessment of Maljevac Landfill (p. 201-203).

In 2014 soil sampling was performed at 4 locations (MM1; Stanimirović Milanko’s house, MM2; Lončar Milko, MM3; Milićević Tomislav and MM4; Džarić Ratka) in the vicinity of Maljevac Landfill. According to the results of the physicochemical analysis, soil samples taken at all the sampling locations fulfil the conditions of the Rulebook. A detailed description of the sampling points as well as the results of the analysis is given in the National Environmental Impact Assessment Report for Maljevac Landfill (p. 200-201).

In the vicinity of Maljevac Landfill (north and south of the landfill), soil sampling (taken as composite samples) was performed at 2 locations on 01 June 2018. Samples were analysed for the parameters stipulated by the Rulebook on permissible concentrations of harmful and hazardous substances in soil and methods for their analysis (Official Gazette of the Republic of Montenegro, No. 18/97). Results of the soil analysis from arable lands around the Landfill Maljevac did not show any deviation from the prescribed norms. Tabular presentation of the results of the analysis of these samples is given in Appendix 5.

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4.3.2.4. Ash and Slag Quality

The program of performing the Study “0” for the condition of the TPP Pljevlja environment stipulated taking composite samples of fly ash and composite samples of waste slag for the purpose of analysis. The sampling was performed in 2006 in the villages Komini and Zabrđe, which have always represented the most vulnerable areas in regards to deposition of ash. Analysis was performed for parameters stipulated by the Rulebook on permissible concentrations of harmful and hazardous substances in soil and methods for their analysis. Results of the ash and slag analysis are provided in the National Environmental Impact Assessment of Maljevac Landfill (p. 205-206). Analysis results for the fly ash show very high concentration of Boron. Results for slag only shows insignificant deviation from the prescribed soil quality due to a slightly high concentration of Nickel.

4.3.3. Air Quality

The most important act on air quality, namely the Law on Air Protection ("Official Gazette of Montenegro", No. 25/10), was adopted in May 2010. By adopting the Rulebook on the Manner and Conditions for Monitoring of the Air Quality (Official Gazette of Montenegro No. 21/2011 and 32/16), the Method of monitoring of air quality and data collection, reference methods of measurement, criteria for achieving of data quality, the way of providing data quality and its validation was prescribed. In the field of Air quality, the compatibility of national regulations with European legislation has been achieved almost 100% by the adoption of regulations in 2012, primarily the Regulation on Determination of the Types of Pollutants, Threshold Values and other Air Quality Standards ("Official Gazette of Montenegro", No. 45/08, 25/2012) and the Rulebook on the content and method of developing of annual air quality information (" Official Gazette of Montenegro ", No. 27/2012).

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

Air quality monitoring for sulphur dioxide, nitrogen (IV) oxide and suspended particulates (PM10 and PM2.5) in Pljevlja was monitored in the period from 2014 to 2018. An automatic stationary station was installed in Skerliceva Street in Pljevlja. The measuring station is moved to the new location - Gagovica estate, in December 5, 2016. Locations of the automatic stationary stations for air monitoring in Pljevlja are given in Figure 4.10.

The tables given in the Appendix 6 shows the upper and lower limits of grading (Annex 2 of the Regulation), target values of concentrations of heavy metals and polycyclic aromatic hydrocarbons and PM2,5 for the protection of human health (Annex 4 of the Regulation), critical levels for the protection of ecosystems and vegetation (Annex 6 of the Regulation), National target value of reduction exposure to PM2,5 (Annex 7 of the Regulation) and alert thresholds and notification thresholds (Annex 8 of the Regulation), given in Regulation on determination of the types of pollutants, threshold values and other air quality standards ("Official Gazette of Montenegro", 25/2012).

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Figure 4.10. Locations of the Automatic Stationary Stations for Air Quality Monitoring

4.3.3.1. Air Quality Monitoring in Pljevlja in the Period 2014 – 2018

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

Sulphur dioxide (SO2)

Pljevlja, as an industrial centre, is characterized by seasonal variation of the concentration of SO2. Sulphur oxides take a leading position among air pollutants in terms of quantitative representation and harmful effects on biological systems. Therefore, concentration of SO2 in air is taken as a reference parameter for assessing air quality or degree of air pollution. Appendix 7 presents the measurements results of SO2 in Pljevlja given in the Monthly reports of the Centre for Ecotoxicological Testing Ltd, for the period from January 2014 to July 2018. Based on those results, it can be concluded that concentrations of SO2 in the air during the heating season were significantly higher than the concentrations measured in the period from May to September.

Nitrogen dioxide (NO2)

Fossil fuels are the most important anthropogenic source for pollution of the atmosphere by nitrogen oxides due to their combustion in industry, in electricity production and internal combustion engines. In term of pollution, representation and biological effects, the most important oxides are nitrogen monoxide and nitrogen dioxide. Appendix 7 presents the

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measurements results of NO2 in Pljevlja given in the Monthly reports of the Center for Ecotoxicological Testing Ltd for the period from January 2014 to July 2018. From those results, it can be concluded that concentrations of NO2 in the air during the heating season were relatively higher than the concentrations measured in summer.

Particulate matter (PM10 and PM2.5)

The origin of suspended particles PM10 is diverse. They appear in urban surroundings as well as in rural surroundings. Main sources of PM10 are motor vehicles, heating in combustion plants, dust from construction sites and landfills, dust from agricultural lands, fires, industrial plants (thermal power plants, thermal treatment of ore, cement plants), etc. Suspended particles with a diameter of less than 10 μm are usually mixtures, which include smoke, soot, dust, salts, acids, and metals.

Appendix 7 presents the measurement results of PM10 and PM2.5 in Pljevlja given in the Monthly reports of the Center for Ecotoxicological Testing Ltd for the period from January 2014 to July 2018. The high impact of individual combustion plants on air quality during the heating season is best seen from these results. The results show that PM10 and PM2.5 concentrations in the air during the heating season were significantly higher than the concentrations from May to September.

4.3.3.2. Air Quality Monitoring in the Vicinity of Maljevac Landfill

In order to monitor the impacts of the Maljevac Landfill on air quality, air quality measurements were conducted in spring and autumn in the vicinity of the landfill by Centre for Ecotoxicological Testing in 2014. Pursuant to the “Rulebook on the manner and conditions for monitoring the quality of air” (“Official Gazette of Montenegro”, No. 21/11) air quality monitoring was performed at 4 locations/stations in the surrounding area over 14-day periods for all seasons (winter, spring, summer, autumn).

The results revealed that 90.4% of the PM10 measurement at MM2 station exceeded the prescribed limit value of 50 μg/m3, where at the other three measuring locations, 90.4% of the measurements were below the prescribed limit value. Mean values of the content of heavy metals and benzo(a)pyrene, at all four measuring locations and during all four measuring cycles, were below the prescribed limit and target values. The concentrations exceeding the allowed limits were mainly directly related to the weather conditions (strong wind). A detailed description of the sampling points as well as the results of the analysis is given in the National Environmental Impact Assessment of Maljevac Landfill (p. 201-203).

Air quality monitoring measurements were also made in Spring 2018 in the vicinity of the landfill by Centre for Ecotoxicological Testing. The measurement points used during this monitoring study are shown in Figure 4.11 below. All concentrations measured during the fourteen-day measuring cycle of PM10 particles were below the defined limit value of 50 µg/m³ at both measuring locations.

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Figure 4.11. Measurement Points for Air Quality Monitoring in Spring 2018

PM10 particles were also analysed in terms of content of heavy metals and benzo(a)pyrene, the pollutants for which air quality standards are stipulated on the annual level. The results indicate that the content of lead was significantly below 0.5 µg/m3 (the defined norm for mean annual value) at both measuring locations (MM1 and MM2). Additionally, content of arsenic, cadmium, nickel and benzo(a)pyrene was below the limit values which are defined with the goal of health protection.

4.3.4. Noise

The most recent measurement of noise levels in the vicinity of TPP Pljevlja was performed in 2008, at a distance of about 400-500m from the TPP, near the close by houses. The results did not exceed the limit values neither during the day nor the night time. There were no recorded complaints regarding the noise generated at the Maljevac Landfill either. The map showing the acoustic zones in the Municipality of Pljevlja In relation to the location of the Maljevac Landfill is presented in Appendix 8 of this report.

4.3.5. Waste Generation

The average amount of ash and slag deposited annually at Maljevac Landfill is about 292,000 tons. Fly ash is the product of burning coal and arises from inorganic substances melting in the thermal power plants. The fly ash particles have spherical shape with dimensions of 0.074-0.005 mm, are of low density, very mobile. Slag is a mineral mixture that consists of material melted in the combustion process and other parts of non- combustible material. It falls through the latticed stokehole and is rapidly cooled and extinguished in water. The Maljevac landfill belongs to the group of wet landfills, as fine crushed waste (slag and ash) hydraulically in the form of a hydrocarbon is transported by pipelines with pumps from the TPP to the landfill. The ash transportation system from the TPP is hydraulic, where a mixture of water and ash (in the ratio of 1:6 to 1:10) is taken through the steel pipeline to the landfill where the ash is deposited.

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CETI conducted physical chemical testing of ash and slag in 2018 and accordingly the ash and slag from Maljevac landfill was classified as non-hazardous waste. In this regard, this ash and slag falls under group 10 (wastes from thermal processes), subgroup 10 01 (wastes from power stations and other combustion plants) and type 10 01 01 (bottom ash, slag and boiler dust) and 10 01 02 (coal fly ash)

4.3.6. Landscape Features

In the Spatial Plan of Montenegro, the wider area of Pljevlja belongs to the Mountain landscape type and "Pljevlja area" unit. The greater part of Municipality Pljevlja belongs to the area of high mountains with altitude between 1400 and 2200 meters asl (Ljubisnja, Kovac, Gradina, Klik, Crni Vrh, Mihajlovica, Ravna Gora, Stozer, Bunetina). The lower parts of the relief are represented by Kosanica, Jabuka and fields (Maocko, Matarusko, Otilovicko, Pljevljsko, Brvenicko, Glisnicko and Racevicko) in the Basin of Cehotina River (Figure 4.12).

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

Figure 4.12. Types of Land Character in the Area of Pljevlja Municipality

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Anthropogenic landscape is dominant in the area of Pljevlja. In the city and its surroundings the impact of the urbanization and the mining-energy-industrial zone is clearly seen. Areas of open pit mining tailing ponds, thermal power plant and the Maljevac Landfill (Figure 4.13) include anthropogenic elements typical of mining and industrial cities, with expressive changes in natural landscape, degradation of space and often expressive disarray in conditions of absence of recultivation.

Figure 4.13. The Maljevac Landfill in November 2016

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

Recultivation at the end of the landfill exploitation is of great ecological significance. This will contribute to reduction of air pollution, slowing down speed of wind blows, mitigating extreme temperatures, reducing high levels of underground and capillary waters, protecting against excessive insolation, reducing slip and preventing soil erosion, enhance visual landscape of area, calming effect on people's psyche and in providing active and passive recreation.

4.3.7. Radioactivity

Coal-fired thermal power plants represent a factor for redistribution and concentration of the natural radioactivity on the local level, because the volume of coal is decreased through combustion of the organic component in the coal, which inevitably leads to the increase in concentration of the natural radionuclides in ash and slag. After combustion, Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 4 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 22 / 35 First Draft of ESIA Date: December 2018

ash and slag are dispatched to the landfill, where the content of natural radionuclides is piled up, and it may represent a health risk in some cases due to presence of the concentrated radioactive material. The degree of radiological impact of the deposited material on the environment greatly depends on the content of natural radionuclides in the deposited ash and slag.

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

Content of radionuclides in the ash from the Maljevac landfill is significantly higher than the content of those radionuclides in the coal, because this is a normal process of concentration of radionuclides from coal into the ash during the combustion process in the TPP furnaces, but even these concentrations are significantly lower than the naturally highest concentrations in the soil in Montenegro.

Analyses of the ash and slag from the Maljevac landfill were performed in 2016 for the purpose of getting a general overview of the potential contamination, and these analyses were performed in two independent laboratories, as follows: Centre for Ecotoxicological Research Podgorica (CETI) and Institute of Nuclear Sciences Vinča.

Analysis performed by CETI showed that the activity of the radionuclides in the delivered samples was below the maximum allowed values for all the analysed radionuclides, which is in line with the provisions of the Article 23 and Article 24 of the Rulebook on the limits of radioactive contamination of the environment and decontamination procedures (Official Gazette of FRY, No. 9/99, 1/2003). Additionally, content of all the analysed radionuclides in the samples were below the limit values defined for letting out and discharging, in line with provisions of the Article 9 and Article 15 of the Rulebook on methods of collecting, keeping, processing and storing of radioactive waste (Official Gazette of Montenegro, No. 058/11).

Results of the analysis performed by the Institute of Nuclear Sciences Vinča indicate that the content of radionuclide in the analysed sample is below the limits of radioactive contamination, defined for industrial waste material (Rulebook on limits of radioactive contamination of people, work and living environment and manner of performing decontamination, Article 12, “Official Gazette of the RS”, No. 38/2011), whereby the analysed sample satisfies the requirements for disposal in the environment in terms of radioactivity.

4.4. Biological Environment

The baseline biological environment is assessed and documented based on the available data and documentation (such as the Local Action Plan for Biodiversity of Municipality of Pljevlja) and National EIA (EIA Elaborate) prepared and approved by the Montenegrin Authorities in 2017.

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4.4.1. Nature Protection and Key Biodiversity Sites

There are no protected areas in the area of influence of the Project. Two areas protected by the national legislation are located in the wider area at a distance to the Project area, on the part of territory of Pljevlja Municipality. One of those sites is a part of the Durmitor National Park with canyon of Tara River, protected as World Heritage site – UNESCO which is abound with exquisite richness in terms of flora and fauna. The other area consists of mountain pine associate (creeping pine, Pinetum mughi montenegrinum) on Mountain Ljubišnja. Map with protected area network in Montenegro is given in Figure 4.14.

Figure 4.14. Map with Protected Area Network in Montenegro

In the area of Municipality Pljevlja, there are 28 registered types of habitats of international importance, among which spruce forests on Ljubišnja stand out as most important. It should be noted that autochthonous vegetation is located in the area of the Biserka River bed. This natural micro-reserve deserves special protection.1

1 Local Biodiversity Action Plan of Municipality of Pljevlja Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 4 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 24 / 35 First Draft of ESIA Date: December 2018

There are 32 proposed Emerald sites (under Bern Convention) in Montenegro (see Figure 4.15). Two proposed Emerald sites have been located within the territory of Municipality Pljevlja. The first is in the area of Ljubisnja Mountain in the wider zone of the Project (about 18 km from the area of Maljevac Landfill on the west). The surface area of the Emerald zone on Ljubisnja is 4,332ha with six NATURA type of habitats identified. Ljubisnja is also on the list of potential IBA (important bird area) sites.

Figure 4.15. Emerald Network in Montenegro

Cehotina valley is the second Emerald site on the territory of Pljevlja with the surface area of 133.56 ha and with the following habitat types identified (according to the Resolution 4 of Bern Convention):

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

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

- Birds: Emberiza hortulana, Falco biarmicus, Ficedula albicolis, Ficedula parva, Lanius collurio, Pernis apivorus, Picus canus. - Migratory birds: Troglodytes troglodytes, Turdus merula, Upupa eppops, Thurdus philomelos. - Mamals: Ursus arctos, Canus lupus.

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- Amphibia: Bombina variegata. - Fish: Hucho hucho, Cottus gobio. - Invertebrate: Stephanopachys substriatus.

Part of this Emerald site is in the vicinity of the Project area as can be seen Figure 4.16.

Figure 4.16. Part of the Emerald Site (Cehotina Valley) Near the Landfill Maljevac

4.4.2. Terrestrial Flora and Vegetation

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

The following species are present in canopy layer of the forests; Carpinus betulus, Betula verrucosa, Pyrus pyraster, Prunus avium, Ostrya carpinifolia. Canopy layer of undergrowth is floristically poor and it is marked by low area coverage (10 to 30%). The species which have the highest level of existence in the floor of bushes are Corylus avellana, Carpinus betulus, Fagus moesiaca, Juniperus communis. Ground flora species have the coverage of 20 to 100%, but this species is marked by higher frequency in terms of stands with higher coverage. The species which are the most numerous and have the biggest coverage in this canopy layer are Pteridium aquilinum, Festuca vallesiaca, Veronica officinalis, Hieracium sp. All other species occur in significantly lower number

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and they have lower degree of representation. The poor diversity of flora and predominance of acidophilic and pioneer species indicate a strong degree of degradation

Research related to lichen in the area of Pljevlja Municipality has shown that there are 120 taxons of lichen and 3 types of lichen-mushrooms. Out of the total number, 16 taxons of lichen and 3 lichen-mushrooms have been recorded for the first time in Montenegro, which does not necessarily mean that the above-mentioned species are rare, but it just indicates that the lichen flora in Montenegro is not well explored.

Data about the findings in terms of moss is sporadic. The most important findings are related to the Buxbaumia viridis (bug moss) species, which was found in a coniferous forest on Mountain Ljubišnja, and in a mixed coniferous-broad leaf forest, which is under the national and international status of protection.

Forest elements occur sporadically in the wider study area, usually in the form of stand of trees between meadows and backyards. Larger stands of trees spread along the slopes of the nearby hills. Mala Pliješ hill, which is located in the vicinity of the project area, is almost completely covered with overgrown forest. Figure 4.17 shows the general map of forest communities in the area of Pljevlja Municipality.

Landfill Maljevac itself, specifically its slopes, are covered with vegetation which was formed by self-recultivation, and it mostly consists of sporadic grass cover and low bushy vegetation. Along the banks of the Vezešnica River, in the 5-15 m wide band, there are black alder thickets. Thicket in this area brings along the species such as European ash, hornbeam, elm, while common oak (e.g. Ainetum glutinosae) is represented sporadically. The list of most important vascular plants is given in Appendix 9.

4.4.3. Terrestrial Fauna and Habitats

The area of Pljevlja is marked by diverse habitats, and fauna composition and distribution largely depend on diversity of habitats, so it may be deduced that fauna in this zone is rather diverse. The list of most important terrestrial fauna species in the region is given in Appendix 9.

Invertebrates represent the most numerous groups of fauna, and among them, the largest number of species belongs to the group of insects. Deciduous, mixed and conifer forests represent habitats for many insect populations, out of which two species from the group of red wood ants should be mentioned, Formica polyctena and Formica pratensis. In terms of beetles, two species are protected on the national level: Lucanus cervus L. (stag beetle) and Oryctes nasicornis L. (European rhinoceros beetle). From the rich family of butterflies, 3 species are protected; Papilio machaon L. (Old World swallowtail), Iphiclides podalirius L. (scarce swollotail) and Parnassius apollo L. (Apollo butterfly). Stone crayfish (Austropotamobius torrentium) populates rivers Ćehotina, Lim and Tara and is on the Habitat Directive Annex II. Helix vladica gastropods may be found on stony grassy slopes, as well as in forests and this species is protected by the national legislation.

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Figure 4.17. Forest Communities in the Area of Pljevlja Municipality

Research performed in the limited area of Ljubišnja has shown that herpetofauna of this region is diverse; 9 amphibian species and 11 reptile species (4 types of lizards and 7 types of snakes) are present. Pools, wetland areas, numerous channels on cultivated meadows and fields, as well as streams in oak and beech forests represent suitable habitats for amphibians.

Numerous bird species are protected as rare or endangered species by national legislation such as crested lark (Galerida cristata), Golden eagle (Aqulla chysaetos), Western capercaillie (Tetrao urogallus) ect. About 41 bird species have been identified on Ljubisnja Mountain (proposed IBA site) such as Eurasian wren (Troglodytes troglodytes), grey tit, Parus montanus Northern goshawk (Accipiter gentilis), European blackbird (Turdus menda).

Diversity of habitats on the territory of Municipality Pljevlja is indicative of rich fauna of mammals. Large mammals prefer deciduous and mixed forest biotope, which have the highest degree of representation on Ljubišnja, as well as on the far north-west area of the Municipality. The following species belong to the deciduous and mixed forests; rob deer, bear, boar, wolf, fox, rabbit, weasel, marten, squirrel and different types of mice. The Ćehotina river valley represents a suitable habitat for bats, especially in the part where the gorge is located. The following bats are listed for the region; Hypsugosavii -Savi’s pipistrelle, Pipistrellus pipistrellus – common pipistrelle. Presence of bats in the town itself has not been documented, and this is mostly due to air pollution. There are no protected mammals in the project area of influence. It should be indicated that the Project area is an area that has already been degraded by human activities where ecosystem has already reached a balance. Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 4 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 28 / 35 First Draft of ESIA Date: December 2018

4.4.4. Aquatic Fauna

In terms of fish fauna in the area of Municipality Pljevlja, Ćehotina River, and its largest tributary are the only ones which provide a complete development cycle of fish population because they have a stable water flow during the entire year. The Voloder river is the hatchery for Salmo labrax (Black Sea salmon), and Cottus gobio (European bullhead) species has also been found here, marked by stable and numerous populations. Out of the species registered on the Habitats Directive list, the following species have been found in the Ćehotina River; Hucho hucho (huchen), Chondrostoma nasus (common nase), Barbus sp. (Pagani). Species which are on the Bern Convention list is the following; Thymallus thymallus (grayling). Although it is not protected, the species which stands out as important from the aspect of ichthyology is Salmo trutta (brown trout) - Black Sea trout, which may be found along entire stream of the River Ćehotina. The list of most important aquatic fauna species in the region is given in Appendix 9.

4.5. Socioeconomic Environment

4.5.1. Settlements

Municipality of Pljevlja has total area of 1,346 m², which represents 9.7% of the total territory of Montenegro. It is belonging to the mountainous area with average altitude between 1,000 and 1,200 m asl. Municipality of Pljevlja from the northwest and west has border with Bosnia and Herzegovina (municipalities Foca and Cajnice), from north and northeast with the Republic of Serbia (municipalities Priboj and Prijepolje), from southeast and east with municipality of Mojkovac and Bijelo Polje and from southwest with the municipality of Zabljak. TPP is located in the industrial zone. In the broader surrounding of TPP Pljevlja there are settlements such as; Zabrdje, Kalusici, Komini, Radosavac and Grevo. Only settlement Zbljevo is located nearby the landfill Maljevac.

4.5.2. Demographic Characteristics

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

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4.5.3. Employment

From the total number of active population 69.3% is employed in 2011. Major economic activities of the active employed inhabitants from Pljevlja are related to public administration (14.5%) and ore and stone extracting (13.7%) according to Census of 2011. Unemployment rate in municipality of Pljevlja is one of the highest in Montenegro and it was 25% in 2017.

4.5.4. Education

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

4.5.5. Vulnerable Groups

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

4.5.6. Health and Social Security

Municipality of Pljevlja has health protection system based on two institutions: Public health service ‘Community health centre Pljevlja’ and Public health service ‘Pljevlja hospital’. Pljevlja hospitality has internal, infectious, surgical, orthopedic and urological departments. Lack of medical staff as well as inadequate equipment is main causes of insufficient quality of health protection. Pljevlja inhabitants are facing respiratory problems, infections, metabolism issues, but due to lack of relevant data it cannot be concluded that such issues are caused directly by the negative impacts and presence of industrial sector (TPP, Coal Mine, landfill Maljevac, sewage system, landfill Jagnjilo, scattered individual landfills). It can be considered that number of illnesses is increasing and Municipality of Pljevlja is facing decrease in birth rate (SES, Page 85).

4.5.7. Social Infrastructure and Services

Transportation network

Compared to the main road network of Montenegro, the municipality of Pljevlja has an unfavorable traffic position. The mode of transport on the territory of the municipality is road traffic. Figure 4.18 shows the road network of the Municipality of Pljevlja.

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Figure 4.18. Road Network of Municipality of Pljevlja

Municipality of Pljevlja is connected with the neighboring countries with the main road M-8 (towards border with Serbia) and regional roads R-3 (towards border to Bosnia and Herzegovina) and its part (towards Priboj), R-10 (Trlica-Slijepac most-Bijelo Polje) and R- 21 (Gradac-Sula-towards Bosnia and Herzegovina). There is also network of local roads within the municipality where total length of the road network is 533.6 km, while there are 368 km of the local roads of which 31.5% has asphalt basis. Cars are dominant in the traffic (79-94%). Nearby the project location there is a network of the local roads while regional road Pljevlja-Djurdjevica Tara-Zabljak is passing by the eastern part of the landfill (1km).

Electricity

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

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Telecommunication

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

Tourism

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

Social Infrastructure

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

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

4.5.8. Economy in the Municipality of Pljevlja and Livelihoods

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

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

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

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Pljevlja LLC for production, trade and services, which is also the main concessioner for forest exploitation.

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

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

In Zbljevo, which is the closest settlement to the Project area, about 36%of the active population is unemployed, while most of the households have at least one regular income from pension or salaries. Most of the household’s livelihood is based on regular monthly income, whether a salary or pension. In addition, most of the population in villages use woods, fruits grown in own yard and vegetables from own garden, so they barely buy these products from the market.

4.5.9. Affected Settlements by the Project

Municipality of Pljevlja has in total 158 settlements, while the area in the vicinity of the landfill is relatively sparsely populated. Nearby landfill Maljevac there is the settlement Zbljevo. The Project consists of remediation/recultivation of Cassette II and relocation of the Paleski Stream. In this regard, for the first component of the Project no settlement is going to be affected directly.

The settlement of Ljuća is potentially affected to a smaller extent because of relocation of Paleški stream to Borovičko Lake is planned to go through part of this settlement and the Project impacts only the land owned by physical persons. However, it is important to point out that relocation of Paleški stream has positive effects on local residents, especially on persons whose land will be used for relocation purpose, due to the possibility to use water for irrigation of agricultural areas after relocation, which has not been possible so far.

For the needs of relocating Paleski stream and diversion of waters of this stream into Borovicko lake, it is necessary to expropriate land, which is currently agricultural (mostly meadows, pastures and fields to a smaller extent). It is important to emphasize that there are no structures (neither residential nor auxiliary) on these lands.

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A separate resettlement action plan (RAP) has been prepared by EPCG for the land acquisition needs of the Project Plus including for the needs of relocating Paleski Stream and diversion of this stream to Borovicko Lake. It is consisting of three parts:

 Part 1: RAP for the needs of construction cassette III of Maljevac landfill – site for disposal ash and slag  Part 2: RAP for the needs of relocating Paleski stream and diversion of this stream to Borovicko lake  Part 3: RAP for 300m long area from the border of the new cassette III of Maljevac in compliance to the Rulebook on detailed features of the site, conditions of construction, sanitary and technical conditions, manner of operation and closure of landfills (Official Gazette of Montenegro, n.31/13 and 25/16)

RAP is representing policies, procedures and processes to be applied during project implementation while mitigating negative social impacts with reference to entities affected by the project. It is developed for the needs of land expropriation and relocation caused by implementation of the project, in compliance with requirements of the WB – International bank for reconstruction and development and its 4.12 Operational policy and it is harmonized with the national legislation. The details regarding all expropriation and resettlement related issues can be found in this RAP.

4.6. Protected Areas and Cultural Heritage and Assets

In the territory of the Municipality of Pljevlja there are two categories I cultural monuments (monuments of extreme importance); Sveta Trojica Monastery and Husein Pasha's Mosque, which are at a distance of 6 km and 4 km to the Project site, respectively (see Figure 4.19). In addition, there are 4 category II cultural monuments (monuments of great significance); the Monastery of Dovolja (39 km from the Project site), Dubocica Monastery (3.5 km from the Project site), Archaeological site of Komini (1 km from the Project site) and Monastery of St. Arhanđela Mihaila. In addition to the above mentioned legally protected cultural monuments, there are a large number of other assets of cultural and historical heritage in the Municipality of Pljevlja, which testify to the continuity of the lives of people in this area since early prehistoric times.

In the minor area/vicinity of the Maljevac Landfill and the Project area of influence there are no monuments protected by law, nor other important cultural and historical heritage assets that need special attention during implementation of the Project. In the wider surrounding area there is an archaeological site in Komini (1 km from the Project site).

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Figure 4.19. Monastery of Sveta Trojica and Husein Pasha's Mosque

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5. ENVIRONMENTAL AND SOCIAL IMPACTS

A large amount of ash and slug is generated as a by-product of operation of the TPP Pljevlja, and these have to be disposed in a sustainable and environmentally sound way. In this context, ash and slug have been disposed to the Maljevac Landfill for decades. The location and extent of the Maljevac Landfill and the scope of the Project are provided in detail in the relevant Chapters of this ESIA Report. To summarize here, the Project includes the following components:

- Remediation/Recultivation of Cassette II - Diversion of the Paleški Stream.

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

The other elements included in the Main Design are planned to be performed in phases and they will be financed from own sources of the EPCG (Project Plus), and they are briefly described in Chapter 1.

5.1. Area of Influence and Impact Assessment Approach

5.1.1. Area of Influence

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

In this regard, the AoI for physical and biological environment includes the Project footprint (Cassette II reclamation area), the upstream and downstream of the Paleški Stream and the new stream bed route reaching to the Borovica Lake.

In terms of the socioeconomic environment, the AoI includes the close-by settlements mainly Zbljevo and Podrogatac. In addition, Pljevlja is considered as the main settlement unit where these villages are also connected, so certain assessments are based on Pljevlja. The close vicinity of the Project area and the AoI can be seen in Figure 5.1.

5.1.2. Impact Assessment Approach

The assessments of possible environmental and social impacts that the Project should manage during the activities to be carried out in the construction and operation phases are described in the following sections. Table 5.1 presents an interaction matrix that summarizes each environmental and social element and the possible actions that might cause an impact (negative or positive) at different stages of the Project.

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Figure 5.1. Project Area and the AoI

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

In this context, as step 1, Chapter 4 presented data on environmental quality, among other information. In the same chapter, parameters of pollution generated by the long-term operation of the landfill are given and trends/changes in some of those are analyzed. These analyses represent the baseline conditions at the start of the proposed Project, but not the zero state which would represent the state prior to the beginning of operation of the landfill.

As step 2, impacts are assessed and the magnitude (e.g. wide, local and restricted) and severity (e.g. high, medium, low) of the impacts are taken into consideration when determining the significance of the impact. The magnitude is classified based on the extent of the impact, while the severity is categorized according to the sensitivity of the receiver/source exposed to the impact, as much as possible. A significance matrix that is given in Table 5.2 combines the sensitivity information with the magnitude of impacts. The significance of the impact is first designated without mitigation measures and then evaluated with proposed mitigation measures. This evaluation would serve to determine the significance of the residual impacts (impact left after employing mitigation measures).

While it is important to identify the initial significant impacts associated with the Project, the key focus of impact assessment has been to define the significance of residual Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 5 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 2 / 24 First Draft of ESIA Date: December 2018

impacts after the application and/or consideration of mitigation measures. In this regard, a summary table is provided at the end of this Chapter to indicate the potential significance of impacts and residual impacts.

Table 5.1. Impact Interaction Matrix (before Mitigation Measures)

Source of Impact and Environmental and Social Factors Activity Environmental Social

National Economy

Land Use Properties Topography Soil Environment Geology Biological Environment Surface Waters Groundwater Air Environment Background Noise Level Traffic Load Landscape and Visual Env. Protected Areas SocioeconomicLocal Env. Community Health and Safety Occupational Health and Safety Land take/Provision (new bed of Paleski Stream and temporary soil storage areas) Construction Works (including access roads and site organization

Relocation of Paleski Stream

Landslide Rehabilitation

Reclamation of Step 4 and 5

Recultivation of Cassette II

Generation and Disposal of

Waste Traffic – Construction

Vehicles Vehicle/equipment use and

maintenance

Employment of Workforce

Supplementary operations

(maintenance of Cassette II)

Possible Negative Impact Possible Positive Impact

The overall aim of employing mitigation measures is bringing the residual impacts to acceptable levels. In terms of designing mitigation measures; avoid (make changes so that the impacts is avoided altogether), minimize (apply measures to reduce size of the

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impacts), repair (take action to repair and/or restore the affected environment) and offset (measures to offset or compensate for the impact) mitigation hierarchy has been followed.

Table 5.2. Impact Significance Matrix*

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

The Project aims to reduce and eliminate some of the negative impacts of the Maljevac Landfill on the environment by closure and remediation of Cassette II and relocation of the Paleški Stream. These are expected to have the following outcomes:

 Elimination of the impact of the landfill on the Paleški Stream water  Reduction of pollution in the ground water in the surrounding area  Reduction of air pollution and soil pollution in the surrounding area

The Project implementation mainly includes construction activities on Cassette II (use of construction vehicles, materials and methods to be used on the Cassette for closure and recultivation), the new channel to be established for diversion of the Paleski Stream. During these activities there would be some adverse impacts on hydrology, soils, environmental quality, ecosystem and socioeconomy of the region.

5.2. Impacts on Physical Environmental Characteristics

5.2.1. Impact on Hydrogeology and Hydrology

In order to prevent the further pollution of the water of Paleski stream and river Vezisnica induced by the leachate from the landfill, the Paleski stream together with the waters from the accompanying basin will be redirected to Borovicko Lake by appropriate channels. Because of that the hydrology of the Project area will be changed.

Hydrological analysis of the Paleski catchment area was performed during preparation of 2 the Main Design. The first section, which takes up a surface area of 1.6 km , transports the surface runoff to the Borovičko Lake. The second section takes the precipitation generated water into the existing Paleški Stream through a peripheral channel, which takes up a surface area of 0.2 km2. The total stream flow at the end of this section is 3 16.20 m /sec (Qmax).The new route of Paleski stream has been designed according to the above calculation with a total length of 1876m, with associated culverts and water containers for the cattle. The potential impacts of the Project on hydrology and hydrogeology of the area would be generally positive.

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5.2.2. Impacts on Erosion, Landslide and Land Use

The landfill itself is a typical anthropogenic land, where the former natural layer is practically destroyed by the intervention of man. In the extent of the Project, the main change of the land use will be caused by relocation of the Paleski stream meaning that the land use will be changed permanently. However, relocated section would be about 2 km long and the channel would be not being too wide. Thus, the land take for relocation the Paleski stream bed would cover a rather small surface area.

Other impacts on land use will be mainly during the construction phase of the Project in regard with the excavation where fertile soil is to be obtained. The excavated material is planned to be used for the reclamation of the Cassette II. Significant erosion impact is not foreseen in the Project area. Slopes of embankments would be landscaped and planted both to improve the visual effect and to reduce potential for landslides. The foreseen activities of stabilization of the dam and rehabilitation of the landslide within the reclamation works will reduce possible sliding and prevent soil erosion. Table 5.3 summarized the potential impacts of the Project on erosion and land use.

Table 5.3. Impacts on Erosion and Land Use

Impact Affected Project Definition of Type of Significance Ecosystem Source of Impact Phase Potential Impact Impact Before Component Mitigation Land use was changed in the area by construction of Land use change, the Maljevac Landfill (in all Current Adverse / erosion and High phases), and erosion and situation Negative landslides landslides occurred at the sections of embankments Land Land use change in the relocation route of Paleski Adverse / Construction Land use change Low Stream and material sites Negative used for obtaining fertile soil Operation/ Erosion and sliding Adverse / Erosion and landslide risks Medium Construction on the slopes Negative

5.3. Impacts on Physical Environmental Quality

5.3.1. Impacts on Water Quality

Maljevac landfill is made by partitioning of a part of the Paleški stream valley by constructing an earth (embankment) dam. Source of the Paleški stream is buried deep between the heights of Rogotac (1.080 m asl) and Borovo hills (1.097 m asl). There is a 350 m elevation difference between the source and the point of its confluence with Vezešnica River. The Vezešnica River flows to the north of the Maljevac Landfill and joins Ćehotina River. To collect the flow of the Paleški stream itself, as well as the joining temporary sources, a collector was built (armed-concrete), and Paleški stream was taken into the collector. This collector passes under the landfill and according to the monitoring results it is infiltrating seepage from the ash and slag landfill, thus polluting the waters of Paleski Stream.

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Based on the results of analyses from 2006 and 2012, it was seen that waters of Paleški stream upstream of the landfill belongs to the category of clean spring water. In the downstream of the landfill, a high number of water quality parameters exceed the allowed limits; pH, electrical conductivity, sulphate, calcium, nitrogen, and cyanide. Based on the latest analysis results (June 2018), the Paleški stream water is out of the required classes, at both upstream and downstream of the landfill due to the high levels of COD and cyanide. In addition, Cehotina and Vezesnica Rivers where the Paleski Stream joins have rather bad quality due to the sewage waters of the city Pljevlja and wastewater of TPP Pljevlja.

All of these lead to the conclusion that the tunnel became porous and that water from the landfill is leaching both into the groundwater and into the stream. These results should also be taken into account regarding relocation of the Paleški stream, which will be diverted into the Borovičko Lake. Because, It is stipulated by the water requirements that the quality of the Paleški stream water must have the same or better quality than the Borovičko lake water.

The Project aims to mitigate the already existing impacts on water quality in the area, so once implemented it would have positive impacts on surface and groundwater quality. The potential impacts of the project on water quality would be during the construction phase due to uncontrolled disposal of waste, potential leakage from construction vehicles/equipments maintenance and fuelling, and soils reaching the surface water as sediments. Table 5.4 summarizes the anticipated impacts on surface and groundwater quality

Table 5.4. Impacts on Water Resources (Surface Water and Groundwater)

Impact Affected Definition of Project Type of Significance Ecosystem Source of Impact Potential Phase Impact Before Component Impact Mitigation Paleski Stream and its receiving waters Vezisnica and Ćehotina are Change of Current affected by contaminated leachate water quality Negative Medium situation and drainage water from the (pollution) Surface waters Maljevac landfill (streams and Uncontrolled disposal of waste, oil Change of rivers) and fuel leakage from construction Construction water quality Negative Medium vehicles, sediments (soil) reaching (pollution) surface waters by runoff Relocation of the Paleski Stream Improvement Beneficial / Operation of water quality Positive Ground waters are affected by Change of Current contaminated leachate and water quality Negative Medium situation drainage water from the ash landfill (pollution) Groundwater Uncontrolled disposal of waste, oil Change of and fuel leakage from construction Construction water quality Negative Medium vehicles (pollution) Recultivation of Cassette II and Improvement Beneficial / Operation forming of drainage system of water quality Positive

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5.3.2. Impacts on Soil Quality

Examination of soil quality in the vicinity of the Maljevac Landfill (presented in Chapter 4) revealed that landfill did not have a considerable impact on the surrounding lands and soils. The main impact was land take to build and expand the landfill. The Project aims to remediate Cassette II of the landfill and this would create a positive impact on the area with regard to soils in the long run.

The potential impacts of the Project on soil quality would be due to use, fuelling, maintenance and repair of the construction vehicles, waste disposal and to a rather smaller extent dust generation and dispersion/deposition of the particulates on the lands around the construction sites. There would also be soil loss at the land take areas (for the Paleski Stream) as discussed in the previous sections.

The main impacts on soil quality would be during the construction phase (so limited duration). Most of the above mentioned potential impacts could be easily controlled with standard measures. For example, forming designated areas with containment for vehicle washing, maintenance (such as oil changing, etc.), fuelling would prevent spilling of oil and fuel into the surrounding soil, and groundwater. In case of accidental oil and fuel spillage necessary emergency actions such as cleaning off the spilled oil using an absorbent and removal of the contaminated surface layer of the soil would be implemented. Table 5.5 summarizes the potential impacts of the Project on soil quality.

Table 5.5. Impacts on Soil Quality

Impact Affected Definition of Project Type of Significance Ecosystem Source of Impact Potential Phase Impact Before Component Impact Mitigation Dust dispersion from the Current Soil landfill and deposition on the Negative None situation contamination soils in the vicinity Soil contaminated by Soil Inadequate maintenance Construction Negative Medium and fuelling of the vehicles spillage and and construction machinery natural drainage at non designated areas, Soil uncontrolled waste disposal Operation contaminated by Negative Medium spillage

5.3.3. Impacts on Air Quality

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

The emissions from construction vehicles are estimated based on the specifications and standards regarding the drive motors of the construction equipments/machines and the Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 5 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 7 / 24 First Draft of ESIA Date: December 2018

planned number of machine hours. All the drive machines must meet the norms for the emission limits stipulated by the EU Directive 97/68/EC, which defines standards for the manufacturers.

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

Table 5.6 with the Stage III B emission standard shows general values of the emission of harmful gasses and dust (particulate matter), which were calculated according to data about the prevised working machines and their respective machine hours (calculation in line with EU Stage III). Considering that calculated emissions will represent the maximum allowed values, actual levels of emission will be lower. Thus, the estimated emissions may be seen as the so-called worst-case scenario in terms of emission of exhaust gasses.

The number of construction vehicles to be used at the same time and location is the highest during the process of making surpass on the existing landfill, construction and repair of the peripheral embankments, and lining the surface with 1 m thick impermeable clay material. In these activities a Loader, Trucks, a Bulldozer and a Roller would be used. Table 5.7 presents the calculated emissions caused by the operation of the mentioned number of construction machinery.

Table 5.6. Stage III B Emission Standard for Non-road Diesel Engines

power CO HC NOx PM Cat. Date kW g/kWh L 130 ≤ P ≤ 560 2011 January 3.5 0.19 2.0 0.025 M 75 ≤ P < 130 2012 January 5.0 0.19 3.3 0.025 N 56 ≤ P < 75 2012 January 5.0 0.19 3.3 0.025 P 37 ≤ P < 56 2013 January 5.0 4.7* 0.025

*NOx+HC

Table 5.7. Calculated Emissions from Construction Machinery

Engine Emission of Gas emission limit values (g/h) PM (g/h) Type of power exhaust gases equipment 3 CO HC NO PM (kW) (m /s) x 10 Loader 137 0.096 479,50 26.03 274.00 3.42 Trucks 162 0.567 2835.00 153.90 1620.00 20.25 Bulldozer 178 0.124 623.00 33.82 356.00 4.45 Roller 85 0.059 425.00 16.15 280.50 2.12

Table 5.7 shows gas emissions from the internal combustion engines of the machinery. The values reflect the scenario of continued operation of the machines over the period of

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24 hours. Bearing in mind the effective period of operation of machines and the number of working days, the limit values are as follows; CO 0.605 g/s; for HC 0.032 g/s; for NOx 0.351 g/s; for PM10 0.004 g/s. The estimated results indicate that use of these construction machines would not cause negative impacts on air quality in the area. Table 5.8 presents the potential impacts on air quality and impact significance.

Table 5.8. Impacts on Air Quality

Impact Affected Definition of Type of Significance Ecosystem Source of Impact Project Phase Potential Impact Before Component Impact Mitigation Change of air Dust generation Current situation Negative Low quality Exhaust gas Change of air Construction Negative Low Air emissions from quality construction Change of air machinery and dust Operation Negative Low generation quality

5.3.4. Impacts of Noise

Emission limits for noise generated through the operation of machinery in the open spaces are determined by the EU Directives (2000/14/EC and 2006/42/EC) and they have been applied in this Project. Law on Environmental Noise Protection (“Official Gazette of Montenegro, No. 28/11, 28/12 and 1/14) and the Rulebook on threshold values of environmental noise, the method of determining the noise indicators and acoustic zones and methods of assessing the harmful effects of noise (“Official Gazette of Montenegro, No. 60/11) were applied for the assessment of potential noise impacts. Noise to be generated by the construction machinery for the purpose of performing the works on the Maljevac Landfill, according to the data from the EIA Elaborate, is as follows:

 Truck: 83 dB  Bulldozer: 88 dB  Loader: 71 dB  Roller: 80 dB

Results of calculation of emission values of the noise levels generated through operation of the construction machinery, over the course of performing the planned project activities at the subject location, are provided in the Table 5.9. The noise would be generated by multiple sources so the overall noise level is calculated by the following equation:

Lr  10  log 100.1Lrj ;dB(A) j

Where, Lr = Total generated noise level

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Table 5.10 provides the calculated values of Leq (equivalent continuous sound pressure level) for different distances from the Project location.

Table 5.9. Noise Generated by the Construction Machinery at the Project Area

Equipment Types and Number External sound level1 dB(A) Truck – 5 83 Bulldozer - 1 88 Loader – 1 71 Roller – 1 80 Total 92.406

Table 5.10. Calculated Values of the Leq at Different Distances from the Project Area

Distance from the Project Site Noise level in dB(A) 25 meters 53 50 meters 46 100 meters 39 150 meters 35 200 meters 32

Calculation of the values of Leq with respect to distance was made using a mathematical model with the following input data:

 Total generated noise level (92.406 dB(A)  Operation duration of machinery (6 hours effective in a shift of 8 hours),  Height of noise source (2 m),  Noise absorption (coefficient 0.5).

According to the Rulebook on threshold values of environmental noise, the method of determining the noise indicators and acoustic zones and methods of assessing the harmful effects of noise (“Official Gazette of Montenegro”, No. 60/11) and the Decision on determining the acoustic zones in Pljevlja, the Maljevac area belongs to the Industrial zone. At the border of this zone, noise must not exceed the noise limit values set for the zone. In this case, the zone it borders is the Quiet zone, located in the agglomeration in which the noise limit values for day time and evening conditions are 40 dB, while the night time limit value is 35 dB.

Based on the estimations provided above, it may be stated that the noise levels in the provided conditions – for the Quiet zone in the agglomeration, will be above the limit values in the 100 m diameter from the source of noise, during the process of performing the works. The least favourable case was considered while performing the calculations and it reflected simultaneous operation of all the machinery, at the same time and at same place, which is difficult to achieve in practice.2 Table 5.11 presents the potential impact of noise and impact significance.

1 According to ISO 6395 and EU Noise Directive (2000/14/EC). 2 Landfill Maljevac is located outside of all the noise zones which are defined within the Noise map for Municipality Pljevlja. The reason for this is that Spatial Plan of the Municipality Pljevlja was in force at the time, and it stipulated establishing a new ash and slag landfill in Šumani, i.e. closing the Maljevac landfill. This Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 5 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 10 / 24 First Draft of ESIA Date: December 2018

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

Table 5.11. Noise Impacts

Impact Affected Project Definition of Type of Significance Ecosystem Source of Impact Phase Potential Impact Impact Before Component Mitigation Machinery and equipments Current Increase in noise Negative None generating noise situation levels Local Increase in noise Construction Negative Low Communities Construction machinery levels generating noise Increase in noise Operation Negative Low levels

5.3.5. Impacts of Waste Generation

Waste generated during the construction can be divided into 3 main categories accordingly to the type of works:

- Waste from excavation for access roads and relocation of Paleski Stream (surface, layers) - Waste generated in relation to the reclamation of the Cassette II (polluted soil, etc.) - Other waste (municipal waste)

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

 waste engine oils (13 02 06* synthetic motor oils, gearbox and lubricating oils): 240 liters (approx. 210 kg)  oil filters (16 01 07*oil filters): 10-15 kg  batteries (16 06 01* lead-acid batteries): 80 kg  absorbents and wiping cloths (15 02 02* absorbents, filter materials (including oil filters that are not otherwise specified) wiping cloths, protective clothing, which are contaminated with dangerous substances): up to 20 kg  antifreeze (16 01 14*antifreeze which containing dangerous substances): 40 liters (approx. 45 kg)  brake fluid (16 01 13*brake fluid): 5 liters (approx. 5.2 kg)

The wastes arising from the Project activities would be disposed to the existing landfills or an authorized waste company would be engaged for their disposal, except for waste rock solution was abandoned in the meantime, thus the Maljevac landfill still remains active as one of the facilities used as part of the operation process of the TPP Pljevlja. Upon completing the consultation with the authors of the Noise map for Municipality Pljevlja, it could be stated that the Maljevac landfill is located in the industrial zone on the Noise map, along with the other TPP Pljevlja facilities, as it was noted in the Decision on establishing the acoustic zones for Municipality Pljevlja. Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 5 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 11 / 24 First Draft of ESIA Date: December 2018

and soil, which will be disposed at the Maljevac landfill, in accordance with the specification of the municipality.

From this it can be concluded that the types and volumes waste generated during the maintenance of the landfill and operation of the Project will be small. Occasional hazardous wastes may arise from maintenance operations, clearance of drainage facilities and separators, and clean-up of accidental spills. The management of mentioned types of waste will be carried out in accordance with the EPCG Waste Management Plan. No significant impact is predicted to arise from resource use or waste disposal during operation in regard to maintenance of the landfill. Table 5.12 summarizes the potential impacts and impact significance of waste generation.

Table 5.12. Waste Generation and Disposal Impacts

Impact Affected Definition of Type of Significance Ecosystem Source of Impact Project Phase Potential Impact Before Component Impact Mitigation Waste generation on site activities and ash and Generation and slag disposal on site, Current situation Negative Low disposal of waste which is classified as non- Local hazardous waste Communities Generation and and Construction Negative Low disposal of waste Environment Waste generated due to use of machinery and Operation (maintenance of Generation and domestic waste Negative Low the rehabilitated disposal of waste part of landfill)

5.3.6. Impacts on Landscape Characteristics

The ash and slag landfill has been in the exploitation phase for more than three decades, which caused loss of land and change in landscape characteristics. Cassettes I and II of the Maljevac Landfill have already been constructed and the total area of the degraded land is 23 ha. Landfill is located in the Paleški Stream valley and is surrounded by plateaus on both sides. Agricultural landscape represent the dominant form on the west and the north side, while forest vegetation is present in the proximate vicinity of the landfill on the east side. Residential facilities are located in the vicinity of the landfill on the west and southwest side. Orchards are the most prominent in the arable areas and they beautify the landscape around the landfill.

By examining the cadastral parcels on which the landfill is located, as well as the green buffer zones around the landfill, it was seen that land is divided into several types around the landfill. Percentile distribution of the types of land is shown in the Figure 5.2. Agricultural lands around the Maljevac Landfill takes up around 60% of the total surface area, being the dominant land use and landscape type.

The Project involves the remediation of Cassette II and relocation of Paleski Stream. Thus, there would not be any significant negative impact on landscape characteristics due

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to the proposed Project. After completion of restoration the impacts to the landscape will be reversed and, depending on the quality of restoration work, the area could gain significant amenity value.

0,00% 0,25% 0,58% Dams and embankments 3,43% Trench, pit 0,99% 2,57% 0,06% 0,05% Tailings landfill 0,44% 0,10% Facilities under construction 0,00% Graveyard 6,38% Karst 7,94% Road 29,35% Garage Yard 19,87% Ancillary building Family residential house 2,24% 22,63% Orchard Forest Pasture Field 3,11% Meadow Uncategorized roads Infertile land

Figure 5.2. Percentile Distribution of Land Use around the Maljevac Landfill Area

In fact, already imposed impacts on landscape and visual and aesthetic effects, would be restored by applying recultivation of the degraded areas and creating a water surface by taking the Paleski Stream out of the underground collector. Table 5.13 presents the potential impacts on Landscape and impact significance.

Table 5.13. Impacts on Landscape

Impact Affected Project Definition of Potential Type of Significance Ecosystem Actual impact Phase Impact Impact Before Component Mitigation The lands being used by the Maljevac Landfill are already converted to Current Loss of land and visual industrial use and Negative High situation impacts landscape/visual characteristics of the area was changed Visual impacts of Landscape Construction Negative Medium construction activities Already realized impacts Loss of land and visual on the landscape will be impacts reversed and, depending Operation on the quality of Positive restoration work, the area could gain significant amenity value

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5.3.7. Impact of Radioactivity

Coal-fired thermal power plants represent a significant factor for redistribution and concentration of the natural radioactivity on the local level, because the volume of coal is decreased through combustion of the organic component in the coal, which inevitably leads to the increase in concentration of the natural radionuclides in ash and slag.

Content of radionuclides in the ash from the Maljevac landfill is significantly higher than the content of the same radionuclides in the coal, because this is a normal process of concentration of radionuclides from coal into the ash during the combustion process in the TPP furnaces, but even these concentrations are significantly lower than the naturally highest concentrations in the soil in Montenegro. Therefore, it can be concluded that potential impact of Project activities on radioactivity would be negligible.

5.4. Impacts on Biological Environment

5.4.1. Impacts on Nature Protection and Key Biodiversity Sites

In the Project are and the AoI there are no protected areas. In the wider area there is the Ljubisnja Mountain as a potential Emerald and IBA area. The Project will not have any impact on this area, which is 18 km away from the Project site.

In the comparatively close area to the Project site there is a peripheral side part of Emerald area, the Cehotina valley (Dolina Cehotine) that follows the Vezisnice river (more details given in Chapter 4.4.1.). As a pre-identified Emerald area, which contains ecologically valuable species and habitats, Cehotina valley should be a part of the future national ecological network. The planned activities of the Project will not take place in this Emerald zone and the activities within the Project Plus (such as forming of the new cassette in the area of Zbljevo village) are not in this zone either. Therefore, no impact is expected on this site during execution of the Project. Significant indirect positive impact is expected on this zone with the relocation of Paleski Stream since this relocation will stop the spilling of leachate from Maljevac landfill into the Paleski stream and further to the rivers Vezisnica and Cehotina, which will stop the negative impacts on that Emerald area’s aquatic ecosystems.

5.4.2. Impact on Ecosystems

Deposition of ash and slag has been carried out for more than three decades on Maljevac Landfill (since 1982), which had already affected the flora and fauna in the area (e.g. loss of habitats due to land take, movement of terrestrial fauna away from the landfill site, etc.). The ecosystem in the area reached a balance with the operations of the Landfill. In this regard, the proposed Project (remediation of Casette II) would not cause any further considerable impacts on the flora and fauna. Thus, the overall state of things would not get worse, and the already reached equilibrium would not change. In fact, some positive impacts on flora and fauna might be expected after closing the landfill, specifically upon the performed recultivation, whereby the damaged ecosystem shall be rehabilitated.

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5.4.3. Impact on Flora and Fauna

With regard to the relocation of the Paleski Stream component of the Project, there would be some land take on the new route of the river bed and at these areas the terrestrial environment would be converted to aquatic environment. Thus there would be some loss of flora, but the width of the river bed would not be too high (around 30 m is the width of the entire route including new river bed with the embankments and auxiliary channels), so the loss of flora species would not be significant. In addition, the terrestrial fauna species would still have the chance to survive in the surrounding area, which minimizes the impacts on those species. Table 5.14 summarizes the potential impacts on ecosystem and flora and fauna together with significance of impacts.

Table 5.14. Impacts on Ecosystem/Flora and Fauna

Impact Affected Project Definition of Type of Significance Ecosystem Source of impact Phase Potential Impact Impact Before Component Mitigation Land take for Maljevac landfill already converted the area to industrial use (loss of Loss of habitats vegetation) and due to the Current high anthropogenic elements Negative Medium situation in the area the fauna species Disturbance of moved away from the site. fauna species However, ecosystem in the area reached a new balance Land take for Paleski Stream Loss, relocation, construction fragmentation and activities and disposal of waste degradation of Loss of vegetation, habitats existing habitats and flora populations due to Construction and loss of flora Negative Medium Habitats and land take for Paleski Stream populations relocation Flora/Fauna Movement of terrestrial fauna Disturbance of away from the construction fauna species sites, during construction Fragmentation of habitats along the new route of Paleski Stream, but creation of new Paleski Stream relocation Negative / Operation habitats for fauna Low Recultivation of Cassette II species Positive

Formation of new vegetation on Cassette II

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5.5. Impacts on Socio-economic Environment

5.5.1. Impacts on the Local Population

Exploitation of coal in Pljevlja is lasting for decades. The population change in this time period can be followed from Census data (1981 – 2011). The change of population in the villages comparatively close to the Project area can be followed from Figure 5.3 given below. According to the results from Census data, total population of the six settlements increased by 16.4%, while the population in Pljevlja municipality decreased by 9.6% between 2003 and 2011.

The proposed Project is not expected to have any significant impact on the local population. Impacts on the population would be caused mainly due to the Project Plus (due to the planned construction of Cassette III), since there would be a need for expropriation for the land required in the buffer zone (300 m distance from the landfill). For this impact a separate resettlement action plan (RAP) was prepared and relevant mitigation and compensation measures were developed.

700

600

500

400

300

200

100

0 Zbljevo Komini Kalusici Zabrdje Borovica Sumani

1981 1991 2003 2011

Figure 5.3. Population in Settlements in the Area (Census Results; 1981-2011)

5.5.2. Impacts on Economy and Livelihoods

The Project consists of remediation of Cassette II and relocation of the Paleski Stream. Remediation of Cassette II and construction works for the relocation of Paleski Stream would have positive impacts on the local economy and livelihoods through employment and trade opportunities. There would be some limited adverse impacts on the livelihoods of the persons having property on the relocation route of the Paleski Stream. The proposed new Paleški Stream route passes through some private parcels (as described in Chapter 3) which would need expropriation. This issue for the Paleski Stream relocation was considered and studied in the RAP report prepared by the EPCG. For the affected persons all compensation and relevant mitigation measures are developed and presented in this RAP. Table 5.15 summarizes the potential impacts together with their significance. Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 5 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 16 / 24 First Draft of ESIA Date: December 2018

Table 5.15. Impacts on Economy and Livelihood

Impact Affected Project Definition of Potential Type of Significance Ecosystem Source of impact Phase Impact Impact Before Component Mitigation Expropriation of private Land already taken by land Negative High the Maljevac Landfill Loss of agricultural land Current on these parcels situation Land to be expropriated Employment and trade for construction of the Positive opportunities planned Cassette III Expropriation of limited Local Land take for Paleski number of private economy and Stream relocation parcels Negative Medium livelihoods Loss of agricultural land Construction on these parcels Construction works for Employment and trade Positive Paleski Stream opportunities Remediation of Employment and trade Positive Cassette II opportunities Opportunity of having Paleski Stream Operation clean water for Positive relocation irrigation

5.5.3. Impacts on Local Public Infrastructure

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

5.5.4. Community Health and Safety

Key identified reasons for potential negative effects on people’s health and safety is seen in air, soil and water pollution as well as noise. Previous sections presented the results of relevant assessments and it could be seen that the proposed Project would not have significant effects on the health and safety of the community. There might be limited risk associated with the traffic during the construction works especially regarding the relocation of Paleski Stream. By realization of the Project (operation phase) some positive impacts would be expected.

5.6. Impacts on Cultural Heritage

Natural resources which have specific values are located in the wider area around the Maljevac landfill, but they are not in the close by region. The proposed Project and the overall Maljevac Landfill would have no considerable impacts on the cultural heritage sites and monuments identified in the region.

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5.7. Occupational/Workers Health and Safety (HS)

Occupational health and safety is an issue related to all construction and operation works and is an integral part of project management. As the project owner EPCG has already established procedures and practices related to the HS requirements in line with national legislation and international practices as a part of its management system. During the realization of the project potential HS impacts would be manly the risk of accidents associated with construction works. These impacts are summarized in Table 5.16 together with their significance.

Table 5.16. Impacts regarding Occupational Health and Safety

Impact Affected Definition of Type of Significance Ecosystem Source of impact Project Phase Potential Impact Before Component Impact Mitigation Ash and slag disposal Current Situation Accidents Negative Low activities Workers Construction activities Construction Accidents Negative Medium Recultivation of Cassette II Operation Accidents Negative Low

5.8. Summary of the Environmental and Social Impacts and Mitigation Measures

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

The only permanent adverse impact would be due to relocation of the Paleski Stream. This would include; loss of some limited amount of private/agricultural lands due to land take of some private parcels in terms of social impacts. Since the land take from private parcels would be rather limited (the future stream bed would have a width of 30 m and the relocated route would be about 2 km long), negative social impacts would have low significance. In terms of biological impacts some habitat loss/fragmentation due to establishment of the new stream channel would take place, but also new habitats would be developed with the new running stream. Therefore, negative biological impacts would have a low significance while some positive impacts would also be expected. Table 5.17 summarizes the potential adverse impacts and proposed mitigation measures together with significance for the potential and residual impacts. The expected positive impacts, the subjects where no impacts (i.e. cumulative and transboundary impacts) are expected and the negligible negative impacts are not included in Table 5.17.

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Table 5.17. Summary of the Impact Assessment and Mitigation Measures

Impact Significance Environmental and social Significance Impact Mitigation Measures of Residual Factor Before Impacts Mitigation Construction Phase Land use  Slopes of embankments would be landscaped and planted to reduce potential for surface erosion. Erosion, change  Permanent erosion control measures will be taken in all landfill Maljevac (such as embankments) against erosion risks Landslide and Low/Medium Low Erosion and Land Use  Suitable warning signs (landslide risk, slippery conditions, etc.) and reflective markings indicating steep slopes would be located in Landslide risk line with good engineering practice or as agreed with the local authorities  Driving of machinery within surface water, streams or on their banks will be prevented. Uncontrolled  Maintaining, refuelling and cleaning of construction machinery will be carried out at dedicated locations with proper containment disposal of and drainage and related waste material would be stored at a controlled area waste, oil and  Training will be provided to machine operators regarding sensitivities and working procedures in works near water Surface and fuel leakage  Checking all machines and equipment for leaks prior to use. Groundwater from Medium  Oil and fuel will be stored in places with secondary containment. No drums will be placed directly on the ground. Low Resources construction (Water Quality) vehicles,  Storage and handling of fuels, oils and other hydrocarbons will be controlled, involving measures to prevent soil and water sediments (soil) contamination. Designs will include storage on sealed surfaces and within secondary containment and refuelling of all plant, reaching surface vehicles and machinery will not be allowed within 50 m of any watercourse. waters by runoff  Precautions such as planting against erosion..  Preparing site specific emergency plans to respond to any incidents or spillages of hazardous material to water environment.  Limiting the construction area/work sites  Removal, storage and handling of topsoil (especially for the route of Paleski stream relocation) in such a manner that it would be Inadequate used during finishing works for recultivation, reinstatement, bio-restoration and stabilization of slopes maintenance  Parking, washing, maintenance and fuelling of the construction machinery would be done at designated sites with concrete ground and fuelling of and in the event that soil is contaminated by spillage, affected layer would be removed in line with the relevant regulation the vehicles and  All packaging waste material for oil and other petroleum derivatives would be stored at a controlled area. construction Soil Quality Medium  Storage and handling of fuels, oils and other hydrocarbons would be done at designated areas with solid grounds (not soil) and Low machinery at located at least 50 m away from any watercourse. non designated areas,  Opening of non-controlled and unplanned access roads to any part of the Project site (on the course of the relocation route of uncontrolled Paleski Stream) will be forbidden waste disposal  Systematic collection of solid waste during construction (including food and material packaging, and other types of waste) would be undertaken and wastes would be disposed at licensed facilities specified by national authorities  Drainage channels will be constructed in accordance with the topographical conditions of the Project Area.

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Impact Significance Environmental and social Significance Impact Mitigation Measures of Residual Factor Before Impacts Mitigation Since the impact significance is low standard mitigation measures would be employed:  Frequent watering of work grounds will be done during dry periods and water intended for this purpose must be used in quantities Exhaust gas that will not result in generation of run-off emissions from  Speed limits will be enforced on the Project area and public roads to limit the levels of dust generation. Air Quality construction Low  Vehicles delivering material will be covered. Low machinery and  All vehicles, equipment and machinery used for construction will be regularly maintained and inspected/certificate to ensure that dust generation the exhaust emission levels conform to the standards prescribed.  No works causing dust formation are allowed when strong wind is blowing in the direction of the settlement Gradac.  Loading and unloading will be carried out without scattering Since the impact significance is low standard mitigation measures would be employed:  Raising workers awareness that noisy activities would be minimized  Construction time will be limited to day-hours (07.00 to 19.00) Construction  Use of modern equipment and machines with noise suppressors machinery Noise Low  Regular maintenance of construction vehicles and equipment Low generating noise Avoiding the simultaneous operation of several noisy machines, when possible.   Using natural acoustic barriers or screens around the machines, such as trees and topographical factors.  Regular maintenance of access and temporary roads and limiting the speed of vehicles  Leaving engines idling at the site will be avoided unless absolutely necessary. Waste generated Since the impact significance is low standard mitigation measures would be employed: due to use of  Systematic collection of solid waste during construction (including food and material packaging, and other types of waste) would be Wastes Low Low machinery and undertaken and wastes would be disposed at licensed facilities specified by national authorities domestic waste  All packaging waste material for oil and other petroleum derivatives would be stored at a controlled area.  Preparation of a landscape restoration plan in line with the remediation design for Cassette II including the realistic requirements to minimise short term visual intrusion from the site operations and to maximise the long term recovery potential of the landscape Loss of land and  The landscape plan should be closely related with the planned works concerning the Paleski stream diversion and the creation of a Landscape Medium Low visual impacts new flow.  Autochthonous species would be selected for the re-cultivation and preference be given to the creation of habitats that reflect the natural appearance of the site prior to the construction operations

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Impact Significance Environmental and social Significance Impact Mitigation Measures of Residual Factor Before Impacts Mitigation  Clearing up and removal of vegetation will be minimized to the extent necessary for the execution of works  Topsoil will be scraped off, where there would be excavation or levelling of ground and stored to protect flora types.  Scattering of wastes with the wind within and out of the project area will be prevented by collecting and temporary storage of waste at designated areas. Loss and  Fauna species will survive in the adjacent areas where no physical disruption occurs. There are no endemic or rare species in the fragmentation of landfill Maljevac area, so there is no risk on the population of those species. Flora and Fauna existing habitats Medium  Recultivation would create alternative habitats to the local fauna as operations progress Low and disturbance  Construction activities will be taking place gradually in order to leave enough time for fauna species to leave the construction sites of fauna species  In order to allow fauna elements to continue their natural inhabitancies of the area, noise levels will be kept at minimum.  Measures should be taken to prevent animal deaths in the project area and on the access roads and new roads should not be opened unless it is necessary.  Incineration or burying of wastes by any means at site and/or dumping of wastes to nearby roads or water resources will absolutely prohibited.  Land acquisitions will be done in a manner which ensures transparency and accountability, and which ensures that compensation Land take for is paid in accordance to the law in force. Paleski Stream  Appropriate disclosure of information, consultation, and the informed participation of affected persons and community will be Socio-economic relocation and implemented. Medium Low Environment consequences  Temporary and permanent business and employment opportunities will be provided during construction and operation phases of on economy and the Project livelihood  Procurement of the land has been started on ‘willing buyer/willing seller’ basis  The project owner (EPCG) developed a RAP complying with national and international requirements Since the impact significance is low standard mitigation measures would be employed:  Contractor will follow the national requirements with respect to “chance finds” which may emerge during construction.  Contractor is not allowed to perform excavation, demolition, alteration or any works that may harm the properties of any cultural Cultural Heritage Chance Finds Low monument. Low  In case of chance finds, the Contractor shall mark and secure new identified sites (with a protective railing or other means of protection) to avoid damage in the course of construction of the Cassette III and relocation of the Paleski stream and immediately notify the relevant authority.

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Impact Significance Environmental and social Significance Impact Mitigation Measures of Residual Factor Before Impacts Mitigation  The project owner (EPCG) and the contractor of works are jointly responsible with regard to workers health and safety. This would include both management measures and reporting and investigating any incidents, i.e. Implement international HSE standards in all contracts  With regard to workers health and safety, contractor will identify potential risks before commencement of works. The emergency response provisions will include a Site Safety Plan, which will also indicate a contact person available in the event of an accident. Site Safety Plan is submitted to the Project Owner (or Supervision Consultant) for approval. Contractor will ensure the following in Workers terms of workers/occupational health and safety: (Occupational) Accident risk Medium • Drugs and alcohol are not used on site. Low Health and • Contractor is to include a provision for safe working environment and safety measures and personal protective equipment Safety (PPE) for all workers in his/her Site Safety Plan, including gloves, hard hats, goggles, ear protection and safety footwear. • Site Safety Plan is to include a provision for first aid to be administered on site and a trained person must be engaged in line with the Law on Occupational Health and Safety (‘’Official Gazette of MNE’’, No. 034/14). • Contractor shall provide to his workers potable water supply, toilets and water supply for washing. • Safety Labour Management Plan (SLMP) is required to ensure health and safety provisions • Contractor shall perform all project activities following the SLMP and all Montenegrin laws and by-laws Operation Phase Land use  Slopes of embankments would be landscaped and planted to reduce potential for surface erosion. Erosion, change  Permanent erosion control measures will be taken in all landfill Maljevac (such as embankments) against erosion risks Landslide and Low/Medium Low Erosion and Land Use  Suitable warning signs (landslide risk, slippery conditions, etc.) and reflective markings indicating steep slopes would be located in Landslide risk line with good engineering practice or as agreed with the local authorities  Drainage wells are projected at the landfill embankment, which aims for preventing any potential groundwater pollution from reaching the area beyond the landfill area. Thus, it is not expected that the ground water pollution will have indirect, negative impact on the quality of the surrounding soil Soil  For the operation phase; operational plans for winter maintenance would be developed Soil contamination Medium  Slopes of embankments would be landscaped and planted to improve the visual effect and to reduce potential for erosion Low with spillage  Permanent erosion control measures will be taken in all landfill areas Maljevac.  Soil quality will be monitored during operation stage including control of the top soil in the village Gradac Donji.  20 surface soil samples from various agriculture land will be taken and analysed and risk assessment of residual contamination would be made.

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Impact Significance Environmental and social Significance Impact Mitigation Measures of Residual Factor Before Impacts Mitigation Since the impact significance is low standard mitigation measures would be employed:  With the aim of protecting the air from potential scattering of during extremely windy and dry weather conditions, the existing system for sprinkling the landfill with water will be used Dust emissions,  All trucks/vehicles to be used will be provided with suitable and adequate coverings and obey the speed limits Air Quality exhaust Low  The operational activities will be carried out in accordance with the local regulation and Rulebook on the manner and conditions for Low emissions monitoring the quality of air  The Project Owner (EPCG) will also designate a liaison staff, in case of complaints related with air quality that could be received from the neighbourhood settlements, for the evaluation of the complaints and where necessary, for the planning and implementation of corrective actions. Since the impact significance is low standard mitigation measures would be employed:  Equipment which will be installed will be used in line with the regulations, standards and norms for that type of equipment, so that noise and vibration will exceed the defined values  The maintenance of the project units and equipment will be carried out regularly Machinery Noise Low  The Project Owner (EPCG) will take into account the sound power levels of the equipment given in the technical Low generating noise specifications/data sheet, in the selection of inverter, transformer and other electrical equipment  Engines and other noisy parts of the construction equipment should be equipped with mufflers  Finally, site personnel should be informed about the need to minimize noise and about the health hazards of exposure to excessive noise Waste generated Since the impact significance is low standard mitigation measures would be employed: due to use of  Systematic collection of solid waste during construction (including food and material packaging, and other types of waste) would be Wastes Low Low machinery and undertaken and wastes would be disposed at licensed facilities specified by national authorities domestic waste  All packaging waste material for oil and other petroleum derivatives would be stored at a controlled area. Since the impact significance is low standard mitigation measures would be employed:  Checks for germination success of planted areas and for natural regeneration/vegetation will identify locations and areas of Fragmentation of disturbance, successes and failures. habitats along  Any outbreaks of pioneering herbaceous species have to be avoided and controlled through regular checks. the relocation  Technical measures against generation of adverse emissions will be taken for protection of fauna types. route of Paleski  Technical measures, such as fencing and intermediate cover, will be taken to prevent the entrance of fauna to the landfill site, Flora and Fauna Low Low Stream, but while access of fauna to the new Paleski stream riverbed will be enhanced due to creation of a new habitat. creation of new  Passages over the new Paleski Stream bed would be formed/allowed as appropriate for the fauna species. habitats for  The Project includes remediation of Cassette II and in this context cultivation works after closure will provide stabilization of topsoil fauna species layer in the landfill area. Subsequently, regional vegetation will cover the area with natural processes in time. Therefore, losses that cannot be recovered or can be recovered in the long run with natural processes will be regenerated in shorter time and will contribute to improvements in landscape integrity

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Impact Significance Environmental and social Significance Impact Mitigation Measures of Residual Factor Before Impacts Mitigation  The project owner (EPCG) is responsible with regard to workers health and safety. This would include both management measures and reporting and investigating any incidents  A Health and Safety Management Plan would be developed and safe working procedures would be implemented, as well as

undertaking training programmes, inspections and reward/penalty schemes to enforce safe working practices Workers Potential injuries (Occupational)  HS measures will include: and traffic Low Low Health and . Shield guards or guard railings installation and inspection of all moving parts accidents Safety . Electrical equipment grounding, insulation and compliance with applicable codes . Procedures to work on elevated platforms and walkways, and stairways and ramps (handrails, toe boards and non-slip surfaces etc.) . Personal protection measures (employees should be provided with hard hats, safety boots, eye and ear protection, and snug fitting gloves as appropriate; inspection programmes etc.) Natural hazards (bad weather conditions,  The project owner (EPCG) should develop and implement the Emergency Action Plan for all potential accidents situations earthquake) Emergency  Regular maintenance of the pump system will be done for keeping them in orderly and operating condition

situations (e.g. Low In case of flooding, earthquake or other natural disaster Emergency Action Plan will be implemented Low Malfunction of  accidents) the hydro  To avoid overflow through the crest of embankment and instability of the slopes technical requirements in line with the Main Design mixture and Emergency Action Plan will be implemented transportation system

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6. PROJECT ALTERNATIVES

This section discusses the remediation and further operation alternatives for the Maljevac Landfill first, where the Project assessed in this ESIA is a part of the preferred alternative. Following this discussion, the alternatives in the Project are evaluated; including alternative routes for the Paleski Stream relocation, alternative methods for construction, and alternative methods of reclamation for Cassette II. In this context the reasons for selecting the preferred/proposed alternative are also provided. Before the discussion on how to proceed with the proposed activities, the “no action” alternative, which represents the continuation of the current status without any intervention, is presented as well.

6.1. No Action/ Project Alternative

This scenario implies the situation in which the current activities continue as usual, without any action to minimize the current or future negative impacts or risks. In this case, the current negative impacts from the site and the risk of dam collapsing will continuously represent a risk for the environment and for humans. Therefore, considering the aspects of environmental quality and public health, the “no action” alternative cannot be regarded as an appropriate option for the ash disposal site.

6.2. Alternative Projects for Remediation and further Operation of the Maljevac Landfill

During development of the project framework for remediation and further operation alternatives for the Maljevac Landfill, the following alternatives were evaluated:

1. Stabilization of the embankment and monitoring the status of the dam; 2. Stabilization of the dam and construction of series of drainage wells; 3. Construction of Cassette III and continued ash deposition, relocation of Paleški stream, and phased reclamation of the landfill

All of the above alternatives included closing and remediation of Cassette II once its capacity is full. Thus, the Project (being assessed in this ESIA report) has been covered in alternative 3, which is the preferred option. As the option chosen for remediation, alternative 3 provides the solution for minimization of surface water contamination by collecting of the effluents of the ash dump and recycling them to the system and by relocating the Paleski stream. In this context, infiltration of water into the ash body will be minimized and particle transport by wind erosion will be prevented as well. Table 6.1 summarizes main environmental and social impacts of these three alternatives.

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Table 6.1. Environmental and Social Impacts of Alternative Projects

Alternative Phases Impact Limited negative impact on local population Construction phase due the construction works and heavy traffic 1. Stabilization of the Limited positive impacts on stability of the embankment and monitoring dam the status of the dam Operation phase Further negative impacts from the already contaminated site including pollution of the Paleski stream Limited negative impact on local population Construction phase due the construction works and heavy traffic 2. Stabilization of the dam and Significant positive impact as the risk of dam construction of drainage wells collapse is eliminated Operation phase Further negative impact from the contaminated site including pollution of the Paleski stream Limited negative impact on local population due the construction works and heavy traffic Construction phase Negative social impact on landowners due to expropriation 3. Construction of Cassette III Significant positive impact as risk of dam and continued ash deposition, collapse is eliminated relocation of Paleški stream, Significant positive effect on water quality and phased reclamation of the after relocation of Paleski stream Significant positive effect on landscape and landfill Operation phase air quality after rehabilitation and greening of the landfill Negative impact from the continued use of the site since dumping will continue for next 7 years

6.3. Method/Technology Variants/Options for the Selected Project Alternative

The conceptual design was developed based on the selected alternative project (Alternative 3 in the previous section). In the framework of Conceptual Design for the continued operation of ash and slag dump Maljevac, the following variants for surpass of the entire landfill were evaluated, according to the order of construction and exploitation of each Cassette:

VARIANT 1 Cassette II – Cassette III m1 – Cassette I VARIANT 2 Cassette II – Cassette III v – Cassette I VARIANT 3 Cassette II – Cassette III v2 – Cassette IV – Cassette I VARIANT 4 Cassette II – Cassette (III v + IV) – Cassette I

1 Cassette III m - Cassette III next to the road 2 Cassette III v - Cassette III till to the elevation K+832m Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 6 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 2 / 8 First Draft of ESIA Date: December 2018

In the evaluation of variants the current capacity of the landfill and construction of new cassettes were considered. All these variants imply implementation of the project in phases, in such way that each of the phases provides space for disposal of the annual production of ash and slag, increased for a certain reserve, as well as that it ensures continuous operation of the thermal power plant. While considering the variants, all cassettes except Cassette III and Cassette IV were within their limits. The goal of considering these four variants was to get as much space for dumping as possible on the already devastated land with achieving the maximum lifetime of the landfill.

VARIANT 1

Variant 1 would cover Cassette II, construction of the Cassette III next to the road and Cassette I (Figure 6.1).

Figure 6.1. Final Shape of the Landfill in the Variant 1

VARIANT 2

Variant 2 would cover Cassette II in its final shape, construction of the Cassette III, where the dumping will be done up to the level K + 832 m asl and with maximum volume for ash disposal of 2,532,031 m³ and Cassette I (Figure 6.2).

VARIANT 3

Variant 3 would cover Cassette II in its final shape, construction of the Cassette III where the dumping will be done up to the level K + 832 m asl, construction of the Cassette IV which is physically separated from the Cassette III by a dam and Cassette I (Figure 6.3).

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Figure 6.2. Final Shape of the Landfill in the Variant 2

Figure 6.3. Final Shape of the Landfill in the Variant 3

VARIANT 4

Variant 4 would cover Cassette II in its final shape, Cassette III where the dumping will be done up to the level K + 832 m asl and with maximum volume for ash disposal of 3,391,537m³ and Cassette I (Figure 6.4).

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Figure 6.4. Final Shape of the Landfill in the Variant 4

6.3.1. Comparison and Assessment of Alternatives

Comparative overview of the volume and duration of exploitation of the landfill Maljevac in all 4 alternative solutions are shown in Table 6.2.

Table 6.2. Comparative Overview of the Options for Maximum Volume and Duration of Exploitation of the Landfill Maljevac

Cassette Variant 1 Variant 2 Variant 3 Variant 4 II (m3 of ash) 188.877 188.877 188.877 188.877 III (m3 of ash) 1.367.823 2.532.031 2.532.031 3.391.537 IV (m3 of ash) 2.463.357 I (m3 of ash) 879.013 879.013 879.013 879.013 Total of ash (m3) 2.427.713 3.591.921 6.055.279 4.451.427 Duration of Exploitation (year) 4.0 5.9 10.0 7.3

From the alternative solutions, Variant 4 has been chosen in the Preliminary Design phase. This variant is distinctive, whereby the basic criterion of evaluation was maintained (i.e., providing the highest possible storage volume for the ash with reaching the longest possible period of exploitation of the landfill) and this procedure was performed in accordance with the given Urbanistic-technical requirements. The selected variant uses the maximum available space on the already devastated land, whereby the new volume of accumulation space that would be provided would amount to 4.451.427 m3, which ensures that the lifetime of the landfill would be 7.3 years in total. The advantages and disadvantages of selected alternative – variant 4 are given in Table 6.3.

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Table 6.3. Advantages and Disadvantages of Selected Alternative

Advantages Disadvantages Extended period of exploitation of the landfill Negative impact from the continued use of the site for dumping for the next 7 years Usage of maximum available space of already Negative impact on the landowners due the devastated land expropriation (for Cassette III) Reclamation of the Cassette II in parallel with Risk of unsynchronized works or delayed works exploitation during phase reclamation

6.3.2. Risk of Delays and Associated Recontamination of the Remediated Sites

Bearing in mind that the reclamation of the landfill is planned to be executed in phases, it is necessary to consider the possible risk of unsynchronized works or delayed works during reclamation, which can induce the recontamination of already remediated sites. Table 6.4 provides an overview of all three remediation phases during the period of remediation (2018-2025).

Table 6.4. Overview of Remediation Phases

Remediation Year: Phase 2018 2019 2020 2021 2022-2025

1 Recultivation works on End of Beginning of Cassette II and operation of recultivation rehabilitation and re- Cassette II of Cassette II cultivation of 4th and 5th steps with precipitation 2 Recultivation works on End of Beginning of Cassette I and II operation of recultivation Cassette I of Cassette I

3 Recultivation of the slope Beginning of End of operation to the K + 821 m asl operation of and beginning Recultivation of the slope Cassette III of recultivation to the K + 828 m asl of Cassette III

Recultivation on Cassette III - slopes of Cassette and plateau of Cassette (K + 832 m asl)

Any possible recontamination could endanger the achievement of the objectives of the entire project framework. Therefore, relevant institutional and operational measures will be considered besides all technical measures that are provided in technical documentation.

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6.4. Variant Solutions for Relocation of Paleški Stream

In order to prevent further pollution of the Paleški Stream and downstream waters with the landfill leachate, it is planned to relocate the Paleski Stream from the collector it is running at the moment to a new riverbed. This new riverbed would receive the waters from the associated basins as well as the atmospheric waters from the basins and this uncontaminated water is to be channeled to Borovičko Lake.

The following variants have been considered during preparation of the Project:

Variant 1 proposed relocation of the Paleški stream to the right side of the landfill. The route is about 2000 m long and extends from the south side of the landfill, along the asphalt road Bobovo - Pljevlja. The route is defined by the topographical conditions of the terrain, which is characterized by moderate to steep slopes in a narrow corridor between the road and the body of the landfill. Relocation of the stream would be done in several parts. The bed of upstream part of the displaced Paleški stream has the length of about 940 m, and it is predicted for it to have earthen bed with 2 mm thick HDPE foil and a transverse profile in the form of a trapeze.

The downstream and steep part of the route will be solved by construction of an excavated reinforced concrete bed with trapezoidal shape that would be narrowed at the steepest part of the section and have rectangular shape. At the downstream part of the stream, a concrete waterfall would be built for the destruction of energy and creation of natural flow conditions.

Variant 2 proposed the relocation of the stream to the north side of the landfill with the same length of the route which is defined by Urbanistic-technical conditions of the Project. The bed of upstream part of the stream is predicted as earthen bed with HDPE foil thickness of 2.5 mm and with the trapezoidal transverse profile. The downstream and steep part of the route will be solved by the construction of an excavated reinforced concrete bed with rectangular shape. The connection of the trapezoidal earthen bed with concrete bed would be solved through the construction of a concrete transition section. At the downstream and out-flow points, water-blocking walls of 1.7 m high would be built, for the purpose of destroying energy and creating natural conditions of flowing.

Variant 3 proposed relocation of Paleški stream to Borovičko Lake. Relocation of the stream is necessary to prevent pollution of the water with leachate waters from the landfill. The existing collector would stay in function while leachate would be pumped out to the recirculation system of technical waters. The relocation route would be on the north side of landfill, from upstream part toward asphalt road and further to the downstream part of the landfill where it would be connected with natural bed.

The third variant has been adopted as optimal. That variant is in accordance with prescribed Urbanistic-technical conditions and will provide the solution most similar to natural flowing conditions of the stream.

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6.5. Rehabilitation Technology/Method Variants for Cassette II

Phase 1 of reclamation of the Maljevac landfill includes works on drainage for cover of Cassette II, technical and biological reclamation on Cassette II and rehabilitation and reclamation of the 4th and 5th step, along with construction of the sedimentation tank.

The main goal of reclamation of physical, chemical and biologically damaged soils is establishment of land management functions, as a resource that is disturbed by anthropogenic activities. The goal of the reclamation is to get through a series of activities that are foreseen by the reclamation project. In some way this would involve “returning” what was previously borrowed from nature by exploitation. Priority targets for reclamation of waste materials (ash and slag) are administration of certain plant crops and establishment of a certain ecological balance. Certain plant species with rapid development of the root system and over-ground vegetative mass contribute to the stability of loose deposited waste materials and the success of growing plants in such areas primarily depends on the applied category of reclamation.

The following methods can be used for reclamation of the degraded surfaces:

 Self-reclamation;  Semi-reclamation; and  Optimal reclamation.

Due to the state of the surface after completion of ash dumping on Cassette II of the landfill Maljevac, and specific pedological, microclimate and climate conditions, optimal reclamation with grass planting and forestation was selected.

The dynamics of execution of works is foreseen for a period of three years. Reclamation works will take place in the following phases of reclamation:

1. Technical reclamation phase 2. Biological reclamation phase

The technical reclamation phase involves formation of the final layer of landfill at a height of 2 m, with all the accompanying works. The biological phase of optimum reclamation involves a complex of biotechnical and phytomeliorative measures for restoring the landfill cassette as well as cultivation of forest cultures in order to revitalize the soil and restore the damaged ecosystem.

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7. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

The purpose of the Environmental and Social Management Plan (ESMP) is to implement principles that are required to prevent, control and minimize potential impacts of the Project identified in the ESIA. The idea is to apply environmentally sound management strategies in line with the related national regulations and international standards to carry out project activities conserving the integrity of natural systems and keeping the adverse impacts at acceptable levels. Thus, the ESMP sets out to ensure that all aspects of the work comply with relevant legislation, permit conditions and good practices, and that measures for mitigation of the identified negative impacts are implemented at all phases of the Project.

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

The EMP and Monitoring plans are the basis for fulfilling the requirements under Montenegrin legislation. In a later phase, the Environmental Protection Agency will require all construction contractors to develop a detailed Construction Environmental Management Plan (CEMP) for their respective activities. The detailed CEMP should include detailed method statements, environmental control procedures and environmental compliance monitoring to be carried out during the construction works. The Contractor will cover the cost of implementing the relevant monitoring program in areas of his or her responsibility.

The following tables (Table 7.1 and Table 7.2) present the Environmental Mitigation Plan measures and the Environmental Monitoring Plan. Further information regarding the institutional arrangements for implementation of the ESMP and emergency action planning framework are provided in Appendix 11.

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Table 7.1. Mitigation Plan

Significance of Installation Operation Installation Operation Issue Mitigation Measures Residual cost cost responsibility responsibility Impacts Land Preparation and Construction Phase  Slopes of embankments would be landscaped and planted to reduce potential for surface erosion. To be To be Contractor, Contractor, Land use, Erosion  Erosion control measures will be taken in all areas of work (such as slopes) against erosion included in included in supervised by supervised by and Landslide risk risks the the NEPA and NEPA and Low  Suitable warning signs (landslide risk, slippery conditions, etc.) and reflective markings Contractor’s Contractor’s supervision supervision indicating steep slopes would be located in line with good engineering practice or as agreed bid bid engineer engineer with the local authorities  Driving of machinery within surface water, streams or on their banks will be prevented.  Maintaining, refueling and cleaning of construction machinery will be carried out at dedicated locations (defined before the works commence) with proper containment and drainage and related waste material would be stored at a controlled area  Training will be provided to machine operators regarding sensitivities and working procedures in works near water Surface and  Checking all machines and equipment for leaks prior to use. Groundwater  Oil and fuel will be stored in places with secondary containment. No drums will be placed As above As above As above As above Low Resources – Water directly on the ground. Quality  Storage and handling of fuels, oils and other hydrocarbons will be controlled, involving measures to prevent soil and water contamination. Designs will include storage on sealed surfaces and within secondary containment and refueling of all plant, vehicles and machinery will not be allowed within 50 m of any watercourse.  Precautions such as planting against erosion.  Preparing site specific emergency plans to respond to any incidents or spillages of hazardous material to water environment  Limiting the construction area to the minimum amount of space needed  Removal, storage and handling of topsoil (especially for the route of Paleski stream relocation) in such a manner that it would be used during finishing works for recultivation, Soil Quality reinstatement, bio-restoration and stabilization of slopes As above As above As above As above Low  Parking, washing, maintenance and fueling of the construction machinery would be done at designated sites with concrete ground and in the event that soil is contaminated by spillage, affected layer would be removed in line with the relevant regulation

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Significance of Installation Operation Installation Operation Issue Mitigation Measures Residual cost cost responsibility responsibility Impacts  All packaging waste material for oil and other petroleum derivatives would be stored at a controlled area.  Storage and handling of fuels, oils and other hydrocarbons would be done at designated areas with solid grounds (not soil) and located at least 50 m away from any watercourse.  Opening of non-controlled and unplanned access roads to any part of the Project site (on the Soil Quality course of the relocation route of Paleski Stream) will be forbidden As above As above As above As above Low  Systematic collection of solid waste during construction (including food and material packaging, and other types of waste) would be undertaken and wastes would be disposed at licensed facilities specified by national authorities  Drainage channels will be constructed in accordance with the topographical conditions of the Project Area.  Frequent watering of work grounds will be done during dry periods and water intended for this purpose must be used in quantities that will not result in generation of run-off  Speed limits will be enforced on the Project area and public roads to limit the levels of dust generation.  Vehicles delivering material will be covered. Air Quality  All vehicles, equipment and machinery used for construction will be regularly maintained and (Exhaust gasses and inspected/certificate to ensure that the exhaust emission levels conform to the standards As above As above As above As above Low dust) prescribed.  No works causing dust formation are allowed when strong wind is blowing in the direction of the settlement Gradac.  Loading and unloading will be carried out without scattering  Temporary spoil storage areas will be positioned in such way that they are not vulnerable to wind erosion  Raising workers awareness that noisy activities would be minimized  Construction time will be limited to day-hours (07.00 to 19.00)  Use of modern equipment and machines with noise suppressors  Regular maintenance of construction vehicles and equipment  Avoiding the simultaneous operation of several noisy machines, when possible. Noise As above As above As above As above Low  Using natural acoustic barriers or screens around the machines, such as trees and topographical factors.  Regular maintenance of access and temporary roads and limiting the speed of vehicles on unpaved roads for transportation of materials  Leaving engines idling at the site will be avoided unless absolutely necessary.

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Significance of Installation Operation Installation Operation Issue Mitigation Measures Residual cost cost responsibility responsibility Impacts  Systematic collection of solid waste during construction (including food and material packaging, and other types of waste) would be undertaken and wastes would be disposed at licensed facilities specified by national authorities or handed over to a company authorized to collect the subject waste  All packaging waste material for oil and other petroleum derivatives would be stored at a Waste Generation As above As above As above As above Low controlled area  Scattering of wastes with the wind within and out of the project area will be prevented by collecting and temporary storage of waste at designated areas  Incineration or burying of wastes by any means at site and/or dumping of wastes to nearby roads or water resources will absolutely prohibited  Preparation of a landscape restoration plan in line with the remediation design for Cassette II including the realistic requirements to minimize short term visual intrusion from the site operations and to maximize the long term recovery potential of the landscape  The landscape plan should be closely related with the planned works concerning the Paleski stream diversion and the creation of new flow Landscape  Autochthonous species would be selected for the re-cultivation and preference be given to As above As above As above As above Low the creation of habitats that reflect the natural appearance of the site prior to the construction operations  After completion of the construction operations and restoration of the land the impacts to the landscape will be reversed and, depending on the quality of the restoration work, the area could gain significant amenity value.  Clearing up and removal of vegetation will be minimized to the extent necessary for the execution of works  Topsoil will be scraped off, where there would be excavation or leveling of ground and stored to protect vegetative capacity  Scattering of wastes with the wind within and out of the project area will be prevented by collecting and temporary storage of waste at designated areas.  Fauna species will survive in the adjacent areas where no physical disruption occurs. There Ecosystem / are no endemic or rare species in the landfill Maljevac area, so there is no risk on the Flora and Fauna As above As above As above As above Low population of those species.

 Recultivation would create alternative habitats to the fauna as operations progress  Construction activities will be taking place gradually in order to leave enough time for fauna species to leave the construction sites  In order to allow fauna elements to continue their natural inhabitancies in the surrounding area noise levels will be kept at minimum.  Measures would be taken to prevent animal deaths in the project area and on the access roads and new roads would not be opened to the extent possible Ecosystem /  Incineration or burying of wastes by any means at site and/or dumping of wastes to nearby As above As above As above As above Low Flora and Fauna roads or water resources will absolutely prohibited

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Significance of Installation Operation Installation Operation Issue Mitigation Measures Residual cost cost responsibility responsibility Impacts  Land acquisition will be done in a manner which ensures transparency and accountability, and which ensures that compensation is paid in accordance to the law in force  Appropriate disclosure of information, consultation, and the informed participation of affected persons and community will be implemented Project Project  Temporary and permanent business and employment opportunities will be provided during Budget for Budget for construction and operation phases of the Project EPCG EPCG land land Socioeconomy  Procurement of the land has been started on 'willing buyer/willing seller' basis supervised by supervised by Low acquisition acquisition NEPA NEPA  The project owner (EPCG) developed a RAP complying with national and international and and requirements (including effective consultation measures with PAPs and a grievance resettlement resettlement procedure)  Local suppliers and contractors would be given priority in procurement of materials and services for the Project  Locals will be given priority for temporary employment during construction  Contractor will follow the national requirements with respect to "chance finds" which may emerge during construction. To be To be Contractor, Contractor,  Contractor is not allowed to perform excavation, demolition, alteration or any works that may included in included in supervised by supervised by harm the properties of any cultural monument. Cultural heritage the the NEPA and NEPA and Low  In case of chance finds, the Contractor shall mark and secure new identified sites (with a Contractor’s Contractor’s supervision supervision protective railing or other means of protection) to avoid damage in the course of construction bid bid engineer engineer of the Cassette III and relocation of the Paleski stream and immediately notify the relevant authority.  The project owner (EPCG) and the contractor of works are jointly responsible with regard to workers health and safety. This would include both management measures and reporting and investigating any incidents, i.e. Implement international HSE standards in all contracts  With regard to workers health and safety, contractor will identify potential risks before commencement of works. The emergency response provisions will include a Site Safety Occupational/ Plan, which will also indicate a contact person available in the event of an accident. Site Workers Health and As above As above As above As above Low Safety Plan is submitted to the Project Owner (or Supervision Consultant) for approval. Safety Contractor will ensure the following in terms of workers/occupational health and safety:  Drugs and alcohol are not used on site.  Contractor is to include a provision for safe working environment and safety measures and personal protective equipment (PPE) for all workers in his/her Site Safety Plan, including gloves, hard hats, goggles, ear protection and safety footwear.

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Significance of Installation Operation Installation Operation Issue Mitigation Measures Residual cost cost responsibility responsibility Impacts  Site Safety Plan is to include a provision for first aid to be administered on site and a trained person must be engaged in line with the Law on Occupational Health and Safety (‘’Official Gazette of MNE’’, No. 034/14).  Contractor shall provide to his workers potable water supply, toilets and water supply Occupational/ for washing. Workers Health and  Safety Labour Management Plan (SLMP) is required to ensure health and safety As above As above As above As above Low Safety provisions  Contractor shall perform all project activities following the SLMP and all Montenegrin laws and by-laws regarding health and safety  All necessary precautions will be taken regarding traffic safety in cooperation with relevant authority/administration in order to minimize impact on traffic resulting from the vehicles to be used for construction activities Emergency  An Emergency Action Plan will be developed in line with the emergency plan and procedures situations (e.g. of the EPCG As above As above As above As above Low accidents)  The Emergency Action Plan will be implemented in any emergency case Operation Phase  Slopes of embankments would be landscaped and planted to reduce potential for surface erosion. To be To be Contractor, Contractor, Land use, Erosion  Permanent erosion control measures will be taken in all landfill Maljevac (such as included in included in supervised by supervised by and Landslide risk embankments) against erosion risks the the NEPA and NEPA and Low  Suitable warning signs (landslide risk, slippery conditions, etc.) and reflective markings Contractor’s Contractor’s supervision supervision indicating steep slopes would be located in line with good engineering practice or as agreed bid bid engineer engineer with the local authorities Surface and  Apply the best engineering practice to maintain the recultivated Cassette II Maintenance Maintenance Groundwater  Cleaning of necessary components for functioning of the water drainage system Maintenance Maintenance Contractor, Contractor, Low Resources – Water  Appropriate operational measures will be taken such as regular control of drainage system in Contractor Contractor supervised by supervised by Quality order to avoid leakage EPCG EPCG  Operational plans for winter maintenance would be developed  Slopes of embankments would be landscaped and planted both to improve the visual effect Maintenance Maintenance and to reduce potential for surface erosion. Maintenance Maintenance Contractor, Contractor, Soil Quality  Permanent erosion control measures will be taken in all landfill areas Maljevac against Low Contractor Contractor supervised by supervised by erosion risks. EPCG EPCG  Soil quality will be monitored during operation stage including control of the top soil in the village Gradac Donji

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Significance of Installation Operation Installation Operation Issue Mitigation Measures Residual cost cost responsibility responsibility Impacts  With the aim of protecting the air from potential scattering of during extremely windy and dry weather conditions, the existing system for sprinkling the landfill with water will be used  All trucks/vehicles to be used will be provided with suitable and adequate coverings and obey the speed limits Maintenance Maintenance  The operational activities will be carried out in accordance with the local regulation and Maintenance Maintenance Contractor, Contractor, Air Quality Low Rulebook on the manner and conditions for monitoring the quality of air Contractor Contractor supervised by supervised by  The Project Owner (EPCG) will also designate a liaison staff, in case of complaints related EPCG EPCG with air quality that could be received from the neighborhood settlements, for the evaluation of the complaints and where necessary, for the planning and implementation of corrective actions.  Equipment which will be installed will be used in line with the regulations, standards and norms for that type of equipment, so that noise and vibration will exceed the defined values  The maintenance of the project units and equipment will be carried out regularly Maintenance Maintenance  The Project Owner (EPCG) will take into account the sound power levels of the equipment Maintenance Maintenance Contractor, Contractor, Noise given in the technical specifications/data sheet, in the selection of inverter, transformer and Low Contractor Contractor supervised by supervised by other electrical equipment EPCG EPCG  Engines and other noisy parts of the equipment should be equipped with mufflers  Finally, site personnel should be informed about the need to minimize noise and about the health hazards of exposure to excessive noise  Systematic collection of solid waste during operation (including food and material packaging, Maintenance Maintenance and other types of waste) would be undertaken and wastes would be disposed at licensed Maintenance Maintenance Contractor, Contractor, Wastes facilities specified by national authorities Low Contractor Contractor supervised by supervised by All packaging waste material for oil and other petroleum derivatives would be stored at a  EPCG EPCG controlled area.  Checks and photographic recording for germination success of planted areas and for natural regeneration/vegetation will identify locations and areas of disturbance, successes and failures.  Technical measures, such as fencing and intermediate cover, will be taken to prevent the Maintenance Maintenance entrance of fauna to the landfill site, while access of fauna to the new Paleski stream Maintenance Maintenance Contractor, Contractor, Flora and fauna riverbed will be enhanced due to creation of a new habitat. Low Contractor Contractor supervised by supervised by  Passages over the new Paleski Stream bed would be formed/allowed as appropriate for the EPCG EPCG fauna species.  Areas identified as critical with regard to fire risk (such as re-vegetated areas, wildlife habitats and infrastructure) must also be examined at appropriate intervals to enable assessment of fire risk and application of preventive measures.

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Significance of Installation Operation Installation Operation Issue Mitigation Measures Residual cost cost responsibility responsibility Impacts  The Project includes remediation of Cassette II and in this context cultivation works after Maintenance Maintenance closure will provide stabilization of topsoil layer in the landfill area. Subsequently, regional Maintenance Maintenance Contractor, Contractor, Flora and fauna vegetation will cover the area with natural processes in time. Therefore, losses that cannot Low Contractor Contractor supervised by supervised by be recovered or can be recovered in the long run with natural processes will be regenerated EPCG EPCG in shorter time and will contribute to improvements in landscape integrity  The project owner (EPCG) is responsible with regard to workers health and safety. This would include both management measures and reporting and investigating any incidents  A Health and Safety Management Plan would be developed and safe working procedures would be implemented, as well as undertaking training programs, inspections and reward/penalty schemes to enforce safe working practices  HS measures will include: . Shield guards or guard railings installation and inspection of all moving parts Workers/ . Electrical equipment grounding, insulation and compliance with applicable codes Occupational Health EPCG EPCG EPCG EPCG Low . Procedures to work on elevated platforms and walkways, and stairways and ramps and Safety (handrails, toe boards and non-slip surfaces etc.) . Personal protection measures (employees should be provided with hard hats, safety boots, eye and ear protection, and snug fitting gloves as appropriate; inspection programs etc.)  All necessary precautions will be taken regarding traffic safety in cooperation with relevant authority/administration in order to minimize impact on traffic resulting from the vehicles to be used for maintenance activities  The project owner (EPCG) should develop and implement the Emergency Action Plan for all potential accidents situations  Regular maintenance of the pump system will be done for keeping them in orderly and Emergency operating condition situations EPCG EPCG EPCG EPCG Low In case of flooding, earthquake or other natural disaster Emergency Action Plan will be (e.g. accidents)  implemented  To avoid overflow through the crest of embankment and instability of the slopes technical requirements in line with the Main Design and Emergency Action Plan will be implemented•

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Table 7.2. Environmental and Social Monitoring Plan

When is the How is the parameter to Where is parameter to Why is the Installation be What parameter the be parameter Installatio and Phase, monitored? Operation is to be parameter monitored? / to be n Operation item (frequency of cost monitored? to be type of monitored? cost responsibili measurement monitored? monitoring (optional) ty or equipment continuous) Land Preparation and Construction Phase Erosion Ensure Included in Contractor and Slopes and Construction Visual Random safety of the bid - supervised Landslide relevant signs sites observation checks works and from the by NEPA risk environment Contractor According to the Decree on classification and At two categorization of reference water (“Official points; Ensuring Gazette of the Paleski Physicochemic compliance Republic of stream Once at the al analysis with national Included in Surface Montenegro” No. upstream beginning of Contractor performed by a legislation the bid Water 14/96 and 2/07) – from the the project, - supervised certified and and from the Quality Parameters such landfill, and then by NEPA competent international Contractor as; suspended Paleski monthly laboratory requirement solids, COD, stream s BOD5, total downstream mineral oils, pH, from the electrical landfill conductivity, heavy metals...) According to the Rulebook on the characteristics of the site, conditions of construction, sanitary and technological conditions, manner of operation and Measuring the closure of landfills levels once a Ensuring (“Official Gazette Physicochemic week, while compliance of the Republic of al analysis physicochemic with national Included in Montenegro”, No. Existing and performed by a al analysis Contractor Groundwat legislation the bid 31/13). new certified would be - supervised er Quality and from the Sampling and piezometers laboratory with carried out at by NEPA international Contractor analysis of the necessary the beginning requirement groundwater for equipments of the project, s at least the and then following quarterly parameters: TBT (tributyltin), arsenic, barium, copper, zinc, fluoride, chrome, tin, cobalt, nickel, lead, total hydrocarbons, phenols and mercury.

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When is the How is the parameter to Where is parameter to Why is the Installation be What parameter the be parameter Installatio and Phase, monitored? Operation is to be parameter monitored? / to be n Operation item (frequency of cost monitored? to be type of monitored? cost responsibili measurement monitored? monitoring (optional) ty or equipment continuous) Number of spill/leakage incidents and Checking corrective Included in Contaminat efficiency of Contractor measures taken Quarterly or the bid Soil Quality ed Site Audit impact - supervised in accordance upon incident from the lands/sites minimization by NEPA with national Contractor measures legislation and international standards In accordance with national legislation at least the following parameters should be Ensuring analysed: TBT Soil Physicochemic compliance (tributyltin), samples in a al analysis Once at the with national Included in arsenic, barium, raster of performed by a beginning of Contractor legislation the bid Soil Quality copper, zinc, 20x20 m certified works and - supervised and from the fluoride, chrome, within the laboratory with upon incident, by NEPA international Contractor tin, cobalt, nickel, remediation the necessary as necessary requirement and lead, total area. equipments s polyaromatic hydrocarbons (PAH), total hydrocarbons, PCB (total) and mercury. Twice prior to the start of the works; Once during periods of Construction winds >4 Bft areas, route Installation of (daily average) Ensuring of trucks dustviewer for after a period compliance Included in Contractor and optical check of 7 days with national the bid Air Quality Dust - supervised settlements of coarse dust without rain; and from the by NEPA in the (> PM10) Once during international Contractor vicinity of periods of standards project site wind below 4 Bft (daily average) after a period of 7 days without rain

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When is the How is the parameter to Where is parameter to Why is the Installation be What parameter the be parameter Installatio and Phase, monitored? Operation is to be parameter monitored? / to be n Operation item (frequency of cost monitored? to be type of monitored? cost responsibili measurement monitored? monitoring (optional) ty or equipment continuous) Ensure that the works cause the least Having Access to Visual possible alternative Random parcels observation disturbance Socio- access to the checks close to the of the economy parcels close to construction Supervision activities at the construction As reported site Inspection the parcels site close to the Included in Contractor construction the bid - supervised site as from the by NEPA possible Contractor Inproximate Visual During Destruction of vicinity to Ensure observation material crops, trees, the compliance Supervision delivery and meadows construction to ESMP Socio- inspection construction site economy Statistics on the Document Ensure grievances Project review Monthly compliance received and Office Local media to ESMP replied to - Employment agreements Project Document Monthly - Number of office Review work accidents - Use of PPEs Regular - Health and inspections Site audit safety signs during the Project Area Visual - Fire safety process of observation equipment/syst performing ems works - Number of health and safety and Project Document Monthly environmental office Review Ensure that trainings the works Contractor provided are in line supervised Workers/ Included in - Emergency with the by NEPA, Occupation the bid Preparedness requirement - supervision al Health and Action from the Project Document s in terms of engineer and and Safety Plan Monthly Contractor office Review occupational EPCG - Number of health and drills safety conducted - Employment data on the security personnel - trainings provided to Project Document security Monthly office Review personnel - Grievances received and replied on the acts of security personnel

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When is the How is the parameter to Where is parameter to Why is the Installation be What parameter the be parameter Installatio and Phase, monitored? Operation is to be parameter monitored? / to be n Operation item (frequency of cost monitored? to be type of monitored? cost responsibili measurement monitored? monitoring (optional) ty or equipment continuous) - Grievance mechanisms for Project personnel Project Document Monthly - Grievances office Review received from Project personnel Ensure that works are in line with Roads in the safety and Contractor Having a traffic zone of environment supervised management smaller Included in - Random al protection by NEPA plan, selected settlements Supervision the bid Traffic checks requirement - and route and time for and close to inspection from the - As reported s, and supervision transport of the Contractor smallest engineer material construction degree of site traffic disturbance as possible Operation Phase Erosion Ensure EPCG and Slopes and Construction Visual Regular safety of - - supervised Landslide relevant signs sites observation checks works and by NEPA risk environment The results are compared to the requirement s in terms of the defined MAC values. Sampling and Four times a Comparative performing At two year analysis with laboratory reference (2x during the the results analysis to points, summer from the Unanounced determine the Paleški period) (2x previous sampling, parameters stream during the period, with analysis on the stipulated by the upstream winter period), the aim of MaintenancMaintenancEPCG Surface site and in a legislation from the and it is monitoring e e supervised Water certified (suspended solid landfill; possible to the pollution Contractor Contractor by NEPA laboratory with particles, COD, Paleški have more trends, the necessary BOD , pH value, stream frequent effects of 5 equipment electrical downstream measurements the conductivity, from the depending on protective content of heavy landfill the obtained measures metals etc.) results which have already been implemente d and establishing new protective measures

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When is the How is the parameter to Where is parameter to Why is the Installation be What parameter the be parameter Installatio and Phase, monitored? Operation is to be parameter monitored? / to be n Operation item (frequency of cost monitored? to be type of monitored? cost responsibili measurement monitored? monitoring (optional) ty or equipment continuous) The results are compared to the requirement s in terms of Sampling and the defined chemical MAC values. Sampling and analysis of the Comparative performing taken samples analysis with laboratory should be the results analysis to performed from the determine the twice a year Unanounced previous parameters (1x during the sampling and period, with stipulated by the summer Existing and analysis in a the aim of MaintenancMaintenancEPCG Ground legislation period) (1x new certified monitoring e e supervised water (suspended solid during the piezometers laboratory with the pollution Contractor Contractor by NEPA particles, COD, winter period), the necessary trends, BOD , pH value, and it is 5 equipment effects of sulphate content, possible to the electrical have more protective conductivity, frequent measures content of heavy measurements which have metals etc.) depending on already the obtained been results implemente d and establishing new protective measures In accordance with national legislation at least the following parameters would Ensuring be analysed: TBT Soil Physicochemic compliance (tributyltin), samples in a al analysis Once at the with national arsenic, barium, raster of performed by a beginning of MaintenancMaintenancEPCG legislation Soil Quality copper, Zn, F, 20x20 m in certified works and e e supervised and chrome, tin, the village laboratory with upon incident, Contractor Contractor by NEPA international cobalt, Ni, lead, Gradac the necessary as necessary requirement total polyaromatic Donji equipments s hydrocarbons (PAH), total hydrocarbons, PCB (total) and Hg. Construction Ensuring areas, route Installation of compliance of trucks dustviewer for MaintenancMaintenancEPCG Upon with national Air Quality Dust and optical check e e supervised complaint and settlements of coarse dust Contractor Contractor by NEPA international in the (> PM10) standards vicinity Ensuring Construction Phonometer compliance sites measuring MaintenancMaintenancEPCG Upon with national Noise Noise level (dB) Nearest system with e e supervised complaint and sensitive the appropriate Contractor Contractor by NEPA international receptors software standards

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8. PUBLIC PARTICIPATION AND INFORMATION DISCLOSURE

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

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

In this context, available information has been evaluated and secondary data secondary data have been collected from the following sources:

 Available strategic planning documents and main project documentation  Socioeconomic data from public institutions  Existing socio-economic databases such as; regional and local population indicators, migration patterns; social development indicators, unemployment, economy structure, labour market, income levels, land use, social organizations; economic activities, education, health, social policy, development priorities

In public consultation context project leaflets would be prepared and distributed for achieving informed consultation of the Project Affected People (PAPs) and public consultation meeting would be held. In the scope of the ESIA studies for the Project following meetings and visits took place between 10 September 2018 and 12 September 2018:

 Inception meeting with the Ministry of Sustainable Development, Nature and Environmental Protection Agency (Implementing Agency-IA) and Project Management Unit (PMU) on 10 September 2018;  Meeting with the EPCG at the Pljevlja TPP on 11 September 2018;  Site visit to the Project area on 11 September 2018;  Meeting with the representative of the local people/residents;  Meeting with the PMU on 12 September 2018.

8.1. Previous Public Consultation Activities

The Project as a part of a larger project framework (as described in Chapter 1) was subject to previous public consultations during development of the ESIA for Remediation of Five Contaminated Sites, as well as within the national EIA procedure and the public consultation during the RAP process. A meeting was also held with the representative of village Zbljevo in the initial phase of ESIA development. Thus, these consultations are considered as first round of discussions related to scope of this ESIA. The information

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related to these consultations and the meeting minutes are presented in Appendix 12 of this ESIA Report. A public consultation/participation meeting would be conducted within the scope of the ESIA studies following the completion of the draft report.

8.1.1. Public Consultation for ESIA of Remediation of Five Contaminated Sites

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

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

In the scope of IWMCP activities and following activities on Thermal Power Plant Pljevlja various studies and associated public consultation activities were conducted. These activities are listed chronologically and summarized in Table 8.1.

Table 8.1. Chronological Overview of Development of Previous Documentation

Public Discussion Venue / Mode of No. Date Conclusions Informing ESIA of Remediation of Five Contaminated Sites “Military club” hall, Municipality 1 10 April 2011 First Public consultation Pljevlja Hall at the Municipality Pljevlja 2 12 July 2011 Second Public consultation Assembly Draft Detailed Spatial Plan (DSP) for TPP Pljevlja and Draft Strategic Assessment of Environmental Impacts Draft of the detailed spatial plan for TPP Pljevlja and draft of the report on 1 strategic assessment of environmental impacts adopted Notifying the public about holding public consultations regarding the Draft On the MSDT website 2 29 April 2015 Detailed Spatial Plan for TPP Pljevlja www.mrt.gov.me and Draft Strategic Environmental Assessment MSDT, Podgorica, IV Proleterske brigade No. 19, III floor, office No.309. Public review and submission of 29 April 2015 - complaints and opinion about the 3 Spatial Development Directorate of 29 May 2015 Environmental Impact Assessment Municipality Pljevlja Report in written form. On the MSDT website www.mrt.gov.me

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Table 8.1. Chronological Overview of Development of Previous Documentation

Public Discussion Venue / Mode of No. Date Conclusions Informing Hall of the Pljevlja Municipal 4 29 May 2015 Public consultation Assembly First EIA Elaborate Environmental Protection Agency Decision on rejecting the request for 1 26 Sep 2016 website www.epa.org.me issuing environmental consent. Second EIA Elaborate Environmental Protection Agency Request for deciding on the need for 1 11 Oct 2016 website www.epa.org.me assessment of environmental impacts Notifying the public about submission of the request for providing consent to the 2 14 Oct 2016 Daily newspaper POBJEDA Environmental Impact Assessment report, by the Project Leader EPCG JSC Premises of the Environmental Protection Agency, IV Proleterske street, No. 19, II floor, office number 211 Invitation for public review and providing complaints and opinion about the Environmental Protection Agency 14 Oct 2016 - 09 Environmental Impact Assessment 3 website www.epa.org.me Nov 2016 Report in written form, in the period from Premises of the Spatial 14 October 2016 until 09 November Development Directorate – 2016. Department of Environmental Protection of the Municipality Pljevlja, office 31A (second floor) Decision for forming a Committee for 4 03 Nov 2016 Environmental Protection Agency review of the Environmental Impact Assessment Report 5 09 Nov 2016 Public consultation Environmental consent to the Environmental Protection Agency 6 Environmental Impact Assessment website www.epa.org.me report was issued. RAP RTV Pljevlja Daily newspaper POBJEDA Print copies of the Public invitation Notice about holding the public 1 were placed on notice boards of Pljevlja municipality and the Local discussions concerning the RAP community, as well as on visited and visible locations at the project implementation area itself. 2 29 May 2018 The premises of TPP Pljevlja Public consultation

IWMCP is funded by the World Bank and according to the WB Guidelines (OP 4.01), the remediation and the hazardous waste landfill projects require Environmental and Social Impact Assessment (ESIA), Environmental Management Plan (EMP) and two public consultations. With the aim of developing the document “ESIA for the purpose of Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 8 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 3 / 9 First Draft of ESIA Date: December 2018

remediation of 5 environmental black spots”, public consultations were held in line with the OP 4.01 including two public discussions which were related to the projects of the Maljevac Landfill remediation. The first public consultation was held at Military Club Hall in Pljevlja, on 10 April 2011, at 11 o’clock. This public discussion was attended by 55-60 people. TV Pljevlja recorded the entire public consultation session.

The second public discussion was held at the Municipality Pljevlja Assembly on 12 July 2012, at 12 o’clock. The consultations were attended by 22 people, apart from 3 representatives of the Environmental Protection Agency and 4 representatives of the Developers (COWI and CDM) who led the public discussion. Minutes were taken during both public discussions. Reports on the public consultations which were held represent one of the components of the final version of the document “ESIA for the purpose of remediation of 5 environmental black spots”.

During the second public discussion, the participants provided the Consultant with an analysis performed in 2008, which shows that ash was classified as a type of hazardous waste, thus should be treated in line with this classification during the remediation project. The Consultant representative said that the results presented in the Study were valid, and that there was no manipulation of any kind. Other participants stated that the laboratory CETI could not be trusted and that the process of independent verification of the results should be initiated. The participants raised the issue of expropriation, considering that this topic has been “open” in Pljevlja for 30 years already. The Consultant explained that the scope of the project was to solve the existing issues, in order to eliminate future pollution. During construction of remediation works, negative impacts may potentially occur, but there will be no negative impacts after remediation.

During both public discussions, the interested public mentioned several times that they would not allow construction of this type of facility on the territory of Municipality Pljevlja and they invited the Prime Minister to comment on this issue.

8.1.2. Public Consultations regarding the Draft Detailed Spatial Plan (DSP) for TPP Pljevlja and the Draft Strategic Environmental Impact Assessment Report (SEA)

Concept of spatial plan of the area was done based on the adopted development strategy and guidelines for construction of electro-energetic facilities defined in the Spatial Plan of Montenegro and the Spatial Urban Plan of the Municipality Pljevlja. Electro-energetic complex of the TPP Pljevlja is a part of the actual industrial zone in the city. In line with the planned project solution, the area in the scope of the plan is divided in 7 locations of urban sites, within which different activities and facilities will be realized:

− Thermal Power Plant Pljevlja, block I and II − Transport system for ash and slag to the new landfill, at the location of the existing mine pit Šumani − New ash and slag landfill at the location of the existing mine pit Šumani − Protection zone, with a width of 300 m from the landfill border − Buffer zone, with a width 300-600 m from the landfill border (in line with the suggested planning solution which defines the width of the protection zone as 300 m from the landfill borders). This solution has been suggested in line with the previous Rulebook on important characteristics of the site, conditions of

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construction, sanitary and technical conditions, manner of operation and closure of landfills − Sports-recreational zone Borovičko Lake − Recultivation of the Maljevac Landfill

These locations will be connected by the system of traffic and pedestrian roads, along with greening the area by planting plants/trees. The area covered by the DSP is 622 ha. The use of space is partially defined by the guidelines provided in the higher order plans and SUP of Pljevlja. Within the area covered by the plan, the following types of use are planned:

− Industry, includes Block I and II of the TPP, transportation system for ash and slag, ash and slag landfill − Low density of residence zone in the width of 300-600 m from the landfill, including agricultural areas, cemetery and other natural areas − Green areas – protective greenery around the TPP and the landfill − Sports and recreation – in the area of the recultivated Maljevac Landfill

Public consultations regarding the DSP for TPP Pljevlja and the Draft SEA were held during the period from 29 April 2015 until 29 May 2015, in the hall of the Municipality Pljevlja Assembly. Aim of the public discussion was to familiarize the expert and layman members of the society with the above mentioned documentation, in an organized, structured and accessible manner.

During the public discussion, a round table was organized in cooperation with Municipality Pljevlja, for presenting the reports. The round table was held in Pljevlja on 25 May 2015, from 12 to 14 o’clock, in the hall of the Municipality Pljevlja Assembly. DSP and SEA were available to the public during the entire public discussion period as presented in Table 8.1 and it was possible to submit all the complaints and suggestions via email ([email protected]) or they could have been filed directly in the Ministry of Sustainable Development’s archive service.

8.1.3. Public Consultation for EIA Elaborate

Within the “Conceptual Design for deposition of coal combustion by-products – landfill Maljevac”, technical-technological solutions for continuation of operation of the Maljevac Landfill have been designed. Impact of the current landfill, along with the appropriate measures for prevention of environmental of impacts of this project, has been elaborated on within the Elaborate on environmental impact assessment study. Also, the program of monitoring of the basic aspects of the environment of the subject Project, together with a graphical overview of the measuring locations, was included in the above mentioned Elaborate.

Elaborate has been aligned with the Rulebook on the content of the elaborate on environmental impact assessment study (“Official Gazette of the Republic of Montenegro, No. 14/2007). In line with the Law on Environmental Impact Assessment, the competent authority has arranged the public discussion regarding the above mentioned Elaborate.

Public consultation regarding the Report on environmental impact assessment for the Maljevac landfill – deposition of coal combustion by-products from TPP Pljevlja, was held

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in line with the Law on Environmental Impact Assessment. The public was notified through daily newspaper Pobjeda, on 12 October 2016, while the interested individuals could get an insight in the print version of the EIA Report in the premises of the Environmental Protection Agency, as well as in the Spatial Development Directorate – Environmental Protection Department of the Municipality Pljevlja, while an electronic version of the EIA Report was also available on the website of the Environmental Protection Agency www.epa.org.me. The public discussion was held in the premises of the TPP Pljevlja on 09 November 2016, at 12 o’clock. The public discussion was attended by: a representative of the Project leader, representatives of the EIA Report developers, representatives of the Environmental Protection Agency, representatives of the Spatial Development Directorate and Environmental Protection Department of the Municipality Pljevlja, representatives of the media and the interested members of community for the villages Zbljevo and Zabrđe. Minutes were taken at the public discussion. Information about the public consultations is also available on the website of the Environmental Protection Agency, as well as within the Public registry for 2017, which may be found on the following link: http://epa.org.me/images/eia/arhiva/2017/Dosije%20broj%2020.pdf.

After having held the public discussion, the competent authority issued environmental consent to the Elaborate on the environmental impact assessment study for deposition of coal combustion by-products generated by the TPP “Pljevlja” – landfill Maljevac.

8.1.4. Public Consultation for RAP

The RAP has been developed for the purpose of land expropriation and relocation caused by implementation of the project framework, in compliance with the requirements of the World Bank OP 4.12 Involuntary Resettlement and with the national legislation. Within the extensive process of communication with the stakeholders and particularly with the affected individuals, the first public meeting was held on 29 May 2018 in the premises of TPP Pljevlja. Location at which the public hearing was held is in the near vicinity to the site where the real estate envisaged for expropriation for the needs of the Project is located. This location for public hearing was chosen for two reasons, the first one was that it provided the easiest conditions for organisation of the meeting, and the second was to enable the project affected people to access public hearing in the easiest possible way. The invitation for the Public hearing was published on RTV Pljevlja, which broadcasts the program on the territory of Municipality Pljevlja, in Pobjeda newspaper which is also distributed in Municipality Pljevlja, and print copies of the Public invitation were put on notice boards of Municipality Pljevlja Town Hall, as well as on visited and visible locations at the very area for the project implementation, 7 days prior to the Public hearing. The Minutes were taken during the public hearing. The subject of the public hearing was introducing the project affected persons (PAPs) with the Project, the Resettlement Action Plan and the upcoming land acquisition procedure. The PAPs were provided with reliable information on the project, its impacts and the proposed mitigation strategies and economic rehabilitation activities.

8.1.5. Meeting with the Representative of village Zbljevo

During preparation of ESIA for this Project, Consultant performed a site visit on 11 September 2018. During the site visit Consultant held a meeting with a representative of the local community, which started at 15:30 o’clock. Apart from the representative of the

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village Zbljevo, the meeting was attended by representatives of the Project leader (EPCG), Ministry of Sustainable Tourism and Development, Environmental Protection Agency/PMU as part of the project of Industrial Waste Management and Clean-up Project (IWMCP). Minutes from the meeting are available in Appendix 12.

8.2. Public Consultation after Completion of the Draft ESIA/ESMP

During the process of ESIA/ESMP preparation a public consultation meeting is planned in line with the WB OP/BP 4.01, following the completion of the draft ESIA/ESMP. Public consultation will be open to all interested parties/stakeholders and the population that is affected by the Project including local authorities, NGOs, affected population, EPCG and public institutions.

Stakeholders can be defined as those people and organizations who may affect, be affected by, or perceive themselves to be affected by, a decision or activity. For the Project, main stakeholder groups are identifies as provided in Table 8.2 below.

Table 8.2. Identified Stakeholders

Potential affected parties Employees of EPCG, EPA Montenegro and Contractors Representatives of companies operating in the area immediately adjacent to the Project Residents from settlements within the zone of influence of the Project Statutory regulatory authorities, on local or regional level, such as: Local landowners and leaseholders and potentially affected industries/businesses Interested parties General public Other companies operating on the National Grid Non-Governmental Organizations (NGO)

It is acknowledged that as the Project develops more stakeholders may be identified and engaged. In that case each stakeholder will be considered in terms of interests, concerns and requirements and will be included within this list. The contact information and communication methods for relevant stakeholders for the Project are given in Table 8.3.

The public consultation meeting–hearing is planned to be organized in January 2019 whereby the Project and draft ESIA/ESMP will be presented to the local community and the interested stakeholders. All the comments received during the public consultation will be documented and addressed in the ESIA report including minutes with questions and answers from the public hearing.

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Table 8.3. Stakeholder Groups and Methods of Communication

Stakeholders Contact Details Interest in the Project Contact Group Methods Agency for Nature IV Proleterske 19, 81000 Issuing ecological permits Official letter and Environment Podgorica, Montenegro Protection E-mail: [email protected] Ministry of IV Proleterske brigade 19, Responsible for regulation of Official letter Sustainable 81000 Podgorica, environmental impacts, reviewing Development and Montenegro, E-mail: design documents and issuing Tourism [email protected] permits (for fire protection t- Tel: +382 20 446 200; technical documents, construction, +382 20 446 339 etc.) and Project supervision and Fax: +382 20 446 215 control. Municipality of Kralja Petra 36, 84 210 Monitoring environmental Official letter Pljevlja, Pljevlja, Montenegro pollutants; implementation of the Secretariat for measures from Local Spatial Planning - E-mail: Environmental Action Plan; Environmental [email protected] preparation of data for the Service [email protected] planning and project documentation, proposing Tel: +382 (0) 52 321 305 protection measures and +382 (0) 52 323 010 assessment of certain economic and other activities on the environment, issuing water permits for relocation of the Paleški Stream Staff of EPCG Stakeholder who has the ability to Public influence and be affected by the announcement operation of the project. NGO Breznica E-mail: Stakeholder with an interest in the Official letter (Eko Breznica) [email protected] Project. NGO Green Dalmatinska 78, 81 000 Stakeholder with an interest in the Official letter Home Podgorica, Montenegro, E- Project. mail: [email protected] Tel: +382 20 609 375 Fax: +382 20 609 376 NGO Ozon Street Dr Vukašina Stakeholder with an interest in the Official letter Markovića, st 4,81 000 Project. Podgorica, Montenegro E-mail: [email protected] Tel: +382 20 331 419 NVO "Da zazivi Email: Stakeholder with an interest in the Official letter selo" Pljevlja [email protected] Project. Tel: +382(0)68 463 445 Representatives Stakeholder potentially affected by Public of the local and with an interest in the Project. announcement community; Zbljevo, Ljuce, Podrogatac

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Disclosure of relevant project information assists stakeholders to understand the project’s environmental and social risks, impacts and opportunities. To this end, EPCG will make available to the public the grievance procedure, in order to collect feedback and to take measures for correcting the causes that may lead to a negative opinion about the development.

Following the WB requirements, the ESIA/ESMP draft will be available for review to all interested parties and stakeholders in the premises of the NEPA and Municipality of Pljevlja, Department for Environmental Protection and on the website of the NEPA www.epa.org.me.

Public consultation will be announced by the means of public media. The notices will be sent to all the interested state and local authorities, agencies and organizations. In addition, public discussion will be announced with the leaflets which will be distributed to the local communities.

The presentation of the Project and the draft of ESIA/ESMP will be performed during public hearing on a way to gather further understanding of the different viewpoints regarding the Project.

Interested parties who may have an interest in the Project have been identified in Table 8.3 and may be consulted and informed on issues related to the project.

A report on the public consultation meeting (and process) on the draft ESIA will be presented in the appendices of final ESIA Report and will contain a list of the participants and relevant stakeholders, as well as minutes of the meeting.

Beneficiary consultations will be conducted during the construction phase, and records of environmental and social issues raised and complaints received during consultations, field visits, informal discussions, and formal letters will be followed up and the records will be kept in the project office at EPCG in Pljevlja.

In advance of the work commencement, EPCG and EPA Montenegro will provide information in:

 Newspaper articles in one national and in one local media;  Posters on main notice board at all community centers of potential affected communities;  Provide contacts of community liaison officers to work with local communities.

Doc. Name: Development of ESIA Report for Remediation Activities on Doc. Code: ENC - MNE - ESIA - 01 Chapter 8 Coal and Ash Disposal Facility Pljevlja, Montenegro Revision: B Pg. 9 / 9 First Draft of ESIA Date: December 2018