<p> Disaster Hazard Mitigation Project, Kyrgyzstan Relocation of tailings from TP3 and 18 to TP 6</p><p>Panel of Experts (PoE) Design Review Mission: Bishkek, May 2008 Summary conclusion: The PoE considers that the present design is not yet proved as fit for purpose and therefore it would be unwise to go to tender for the project on the basis of the documentation available at this time. The PoE considered the review in the form of a series of questions: Question 1: Is the feasibility of the preferred option well established? The PoE still do not consider that the case for the preference of TP6 over TP15 as the disposal site for TP3/18 tailings has been unequivocally proven. However, it seems that only the TP6 option is to be developed and the documentation reflects this. Thus with the option of relocation to TP15 apparently no longer in the brief, the questions for the PoE then become: A number of concerns raised in 2007 have still not been addressed in a manner that the PoE considers adequate e.g. quality of English language in documentation, provision of further technical data and so on, </p><p>Question2: Is the design technically sound? A number of potential and actual technical shortcomings were found in the design and these have been raised in the individual experts’ reports.</p><p>Question 3: Is the project design appropriate in the context of the project’s situation? Since a number of potential and actual technical shortcomings were found in the design this question cannot be fully answered at this time. Therea are elements in the desing and documentation which the PoE considers may not be best international practice not appropopriate to the conditoins aunder whhc this project is being undertaken. The details may be found in the individual PoE members’ reports Question 4: Is the project design competently presented in the documentation provided to PoE and destined to go to bidding contractors? The simple answer is “no” and the full explanation of this response is justified through the following comments and those in the other individual reports from PoE members</p><p>Report of the Waste Safety Expert: Peter Waggitt There are still concerns about the quality and consistency of presentation in the English language versions of the documentation which would make it hard for contactors to be sure they were understanding requirements correctly. The meaning of bidding requirements should be unambiguous so that there is no confusion as to what is required and what is offered. If the tender is to go to a full international bidding process then the quality of explanation in all language versions should be of the highest order, especially as the English language version is understood to be the definitive copy. This last point raised more concerns in relation to the accuracy and currency of the documents given to the PoE. During discussions with the JV some of the PoE queries were answered with the information that the point had been corrected or in some cases re-written, expanded or otherwise changed in the Russian language version of the document concerned. This suggest that the English language documentation supplied was not necessarily the most up-to date version. This obviously is not acceptable if the PoE members are to perform their duties effectively. Further it is also disturbing when the English language version is supposed to be the definitive documentation. Accurate document control should have made this point apparent sooner. The absence of any document control system apparent. Some headers and footers, which is where version control data often appears, do not match the document title which is confusing. What document control system is proposed? The hierarchy of the documentation is not clear. Also there is inconsistency of information on items between documents and some statements are apparently contradictory between documents. There are many documents and there seems to have been much cutting and pasting between them (and documentation from other WISUTEC projects), but are they all necessary? Are all the design documents proposed now produced, at least in preliminary form? The EIA was received on 28 May but the PoE has not yet seen the EMMP promised after last year’s meeting. The JV stated that they no longer intend to produce such a document. Such an EMMP would be expected to contain all the information on surveillance and montoring and environmental management in one document, this would assist regulators and contractors alike. The JV response that all the information is interspersed through the whols documentations “at appropraiate places” has proved inefficient for use by others, including the PoE. The use of some terms is inconsistent between documents, e.g. Client and Customer, and not all abbreviations are immediately explained or clear in meaning. There should be a consistency check and all terms clearly defined in one location, such as a glossary. It appears that the contractor will be required to produce some of the documentation and procedures for a number of activities such as QA/QC monitoring, safety, water treatment etc. which makes it hard for PoE to assess the suitability and safety of the approach being taken. Also the proposal that the contractor is responsible for all the QA?QC appears to be an unacceptable conflict of interest. The consulting engineer should cary out at elast check monitoring and QA/QC throughout the project. The proposed use of a third party company for on-site construction monitoring is also discouraged to avoid misinterpretation of the designer’s intentions through an extra communication stage. The on site representative should be from the joint venture team. Many parameters used in the design, such as measurable objectives and the level of safety and acceptable level of risk are not clearly stated or justified. There were concerns in 2007 about the level and availability of basic characterisation being adequate for the preparation of a suitable safe design-some of these concerns remain. Examples include: Some background studies/project costs/hydrology Design analysis – question of if all the required parts are present both analytical elements and in the material design supplied to the contractor e.g. the inclusion of a field test on excavation. In some cases the PoE has been obliged to make subjective comment on issues where insufficient base data have been found in the documentation to support assertions made. </p><p>Tender Documentation There are some apparent errors in the Bills of Quantities in respect of some items wrongly labelled. Again a thorough consistency check should be made to avoid later problems over claims arising over use of misleading information. Summary BOQ and Summary Cost Estimate have differing numbers of items – BOQ has addition of General Items and Contingency. Some quantities in the Summary Cost Estimate and BOQ are seen to be different. This may affect PIU estimates. A thorough check should be made before the documents are finalised. Some apparent errors noted in the summary costs documentation. It appears more detailed instruction is provided in relation to concrete works than earthmoving in the conditions; is this normal in what is essentially an earthmoving project? Is there a warranty period for the works and how will performance be measured to allow release of any retention money?</p><p>Truck decontamination sites: The truck cleaning bays desings suggest the structures are possibly too narrow if trucks other than the assumed 2.5 m wide local vehicles are used. The bed of the bay is 3.5 m wide and this leaves only 50cm clearance at each side to the outside edge of the kerbs. Other trucks could well be wider and so run even closer to the edges of the bays. When a high pressure (HP) washer is used with such low sides there is obvious potential for an overspray problem. It is suggested that the design be re-assessed and consideration given to fitting metal side panels 1.2 – 1.5 m high (as at Wismut sites) to contain splash and over spray. It is noted there are no minimum specifications given for the for HP washing equipment to be used, nor for the need to have back-up equipment. It should be clearly stated in the tender instructions that no truck shall be allowed to leave a working site until it has been washed down in accordance with the requirements. This means “no wash down – no truck movement”. Cost estimate 1 in BOQ mentions cost of truck cleaning only once per day. What does this mean? If it is a requirement to wash down at the end of the shift as well as before leaving each site then this should be clearly stated. The cleaning specification for trucks needs clarification; cleaning is not just about tyres alone e.g. a requirement for “no visible contamination on the tyres exterior and underside ” needs to be clearly stated. The need to wash the bed of the trucks leaving TP6 should be emphasised.</p><p>Water treatment system (WTS): Capacity for surge storage could be too small at 500m3 and not sufficient to meet requirements for 10 day storage of T15 rainfall and operational procedure set out in explanatory notes 4.3.4 and EIA p 67 depending on return period of T15 event and volumes of other contaminated water to be treated. What is full explanation of T15 design event, e.g. the return frequency of this 15 minute rainfall? EIA p 67 a water storage pond is mentioned but no description or location explanation is provided here or reference back to where such a description is given. Will WTS also be treating contaminated water from showers and laundry? Has this been allowed for in the operational design and costings? Explanatory notes p. 26 4.3.4 states that the contractor will choose the technology for water treatment but BOQ cost estimate 6 is very specific about a technology to be applied. What are the competence requirements for operating such a plant and how will they be assessed or will contractors have to show evidence of experience? Water quality discharge standard is stated to be 0.5 mgU/L but how will this be checked and by whom? What contingency is there for retaining “clean” water to ensure quality has been checked before batch discharge? Will this WTS also be managing seepage or any pumped ground water from excavations at TP3 (section 4.3.3 explanatory notes)? If so, has this been included in the planning, and where can the reference be seen? There seems to be some confusion in respect of winter break operating plan for the WTS. In 6.3.6 of the EIA under “Winter break” it states that the drainage runoff from the temporary cover at TP6 will be tested for contamination and then taken to the WTS “in tank cars to temporary water treatment station along TP3”. Is this the regular WTS? It was stated by the JV staff that the WTS would be shut down for the winter break which is also confirmed in Section 28 of the Technical Specifications “.for two seasons and removal in wintertime” - so which is the correct procedure and if poor quality water is found at TP6 how will it be managed if the WTS has been removed or shut down? What is the management plan for sewage treatment arising from site toilets? Will it involve this WTS? We have found no obvious reference to standards and procedures for environmental protection in relation to transport, use and storage of fuels, oils, chemicals etc. other than general conditions in the tender documents p.45. These seem rather sparse and implementation may not provide a high enough level of protection. No reference has been seen to the project or the contractor being required to have an approved Environmental Management Plan (EMP) which would be expected to cover much of what seems to be missing or is not clearly stated in the areas of general environment protection. Working hours are very long with talk of shifts of 12 hours or more, without including breaks. Is this a safe working practice and would it contravene any local labour laws? Is working 12 hour or longer shifts without breaks really “best practice?” Would the imposition of more “normal” hours have a significant impact on cost/timing of works overall? If so, to what extent? Does such long working time allow sufficient time for servicing and safety checking of machinery, etc? Has sufficient allowance been made for the reliability of machinery in productivity and work-rate calculations? Is it realistic to assume 100% productivity every working hour? What is the long term stewardship plan for the project sites, if any? Equally post construction and long term surveillance and monitoring of the sites? How are these issues to be funded? Is this being addressed elsewhere? On page 34 of the EIA in section 4.8.3 the text mentions “enrichment of uranium”; this is clearly a translation error for (probably) “concentration of uranium “. There is a very significant difference in the use of these two terms and only the correct one should be used. There is no history of uranium enrichment activity at Mailuu Suu. EIA page 81 s. 7.1.2 the stated assumption for calculating worker doses is quoted as 1000 working hours per season. If the staff work 6 months for 6 days per week [26 days per month] for 12 hours per day (as suggested elsewhere in the documentation) this would represent 1872 hours, which would almost double doses; even if one allows some time for breaks in the 12 hours shift the working time would still be around 1600 hours, which would increase the dose estimates made in Table 7.4. It is important that it is made clear in the documentation that worker dose limits must be strictly observed by the contrcator throughout the project, which may mean using more staff in two shifts per day to achieve the required work rates. EIA Table 7.4 Page 82 requires correction of the additions in column 1. Presumably the reference immediately below should be to Table 7.4 not Table 7.1 as written. Also in the part of s.7.1.2 immediately below the table it states “nobody stays unprotected 200 hours per year at the tailings” This would seem to be in conflict with the anticipated periods of work and the likelihood that the foreman would be on the sites of excavation and placement for much of his time. In EIA page 106 s 11.1 the presence of a reference in Russian has not enabled the PoE to make any clear interpretation of what is being said . What is the meaning of a risk of <106 and who made the assessment? The “Guidelines for EIA” document does not apparently appear in the reference list who was repsonsible for its production? In Table 11.3 there appears to be no reference under positive consequnces to the benefits of th possible future use of the two sites, the removal of the hazards at WD5 and the residual infrastructure e.g. the roads upgraded or built for the project. Radiation Protection:</p><p>Monitoring and Radiation Protection Plan 1st Edition Chemnitz April 2008</p><p>Ref Comment General Poor English language use throughout. Again it is observed that an edit by a native English speaker would have ensured the document was more easily readable. Radiation Protection details mentioned in the Tender documents (P57-(13)) are not found in the Radiation Protection Plan which is a concern. Does this document represent a real Radiation Protection Plan? It seems to be very short and light on detail that provide guidance to the contractor. Nowhere have we found a reference that the radiation safety and monitoring programmes should be approved by the competent authority. In number of places in this document and others there is mention of recording results and submitting them to the competent authority. It should be emphasised that results need to be “recorded, analysed and assessed before submission to the relevant authorities”. Also what arrangements will there be for archiving of data from the project? Is there an agreed format for data transmission from contractor to consultant e.g. software standardization etc Arrangements for record keeping, reporting schedules, incident reporting and lines of communication are not clearly defined and stated 1 Consider checking if TSR-1 is relevant to this situation. If not, what other regulations for transport of radioactive material apply in Kyrgyzstan? The IAEA documents quoted are all standards. P.6-2.2.2 Safeguard not the correct word, should probably be Security. Confusion in last para using stored instead of disposed. T6 may be used as a grazing site by nearby resident possibly, which could become an issue. 2.2.3 The unrestricted use of sites appears incompatible with the use of clearance level criteria that are inconsistent between documents. Text here implies there will be active management of the remediated site T6 to restrict types of vegetation growing in the future. Is there proposed to be a monitoring, surveillance and maintenance programme? If so, what is proposed for the programme, how would it be funded and which organization would be responsible for implementation? 2.3.1 Has the scenario for exposure of a site security guard been considered? Such people may be exposed at least as long as any other worker. Scenarios for foreman may be inappropriate. We feel the range of workers used in scenarios (worker types and activities) may not be the most conservative e.g. surveyors, labourers, etc. Calculations of doses not well explained. It is noted that there will be worker training about radiation although no detail of the type of programme envisaged has been provided; this could be reinforced by the issuing of a basic worker radiation safety manual at the end of the training session. This was discussed in 2007. The manual could even be supported by a simple safety card dealing with a range of OH&S and radiation protection rules. Worker classification is mentioned but not defined; no mention of area classification. 3.1 Will there be an indication of a set standard for the protocol of the measurements of gamma radiation etc to ensure results can be compared. Radiation measurements need to be made not only in working places but also offices, change rooms, boundaries of the site, living quarters, etc. 3.2 If there is a reference to support the assertion that sites below 0.2 Bq/g can be released for unrestricted use it would be good to cite it here. Mentions that 20m X 20 m grid is OK for initial work but not for clearance - without suggesting a suitable spacing for clearance measurement in gamma surveys. What protocols are to be used? Who will develop them, who will review and approve them? Methodology here should be reassessed to ensure that optimum results can be obtained. 3.3 Text implies work is completed without any staging points for interim approval from the competent authority; some form of staged approval process may be more prudent rather than just waiting for a simple final remediation report 3.4 Has use of personal air samplers been included as well as high volume area sampling? This might be more relevant for worker protection, especially if done over full shifts. Has consideration been given to gravimetric methods of sampling dust? 3.5 Shorter term (< 3 months) radon measurements might be better done over say a week with different instruments rather than spot measurements – this is due to the probable great variability in the values. Track etch devices could also be sited on workers’ helmets and in the cabs of machines. The value of the radon monitor weekly reading in an open air situation is not clearly understood. 3.6 A suitable dose rate meter may also be useful to augment the visual inspection along the public roads. A gamma meter is better to find “hot spots” initially then alpha and beta meters can be used to define details of spill and monitor effectiveness of clean up. A protocol is needed for this monitoring. The spill management plan should be developed and be covered in the radiation protection plan in respect of workers involved, cleaning of plant and machinery, clearance levels etc. 3.7 Not clear who is doing the reporting here – the monitoring supervisor or the contractor? Who will determine what a deviance is? A proper reporting schedule is required showing obligations and responsibilities of all parties. If there is a Radiation Protection Plan there should be a designated Radiation Protection Officer (RPO). The qualifications and duties of the RPO should be clearly spelled out; also if the person selected by the contractor has to be approved by the competent authority. The same applies to OH&S. 3.8 Records should also include details of calibration of instruments (when, how, procedures, results of daily instrument checks, validity of calibration etc); need to ensure that data are supplied to authorities in an agreed format. Records should also include details of all procedures to be used (protocols) so that there is continuity of process. Also there needs to be a clear indication of the reporting schedule for all the QA/QC, monitoring and safety reports including the frequency etc. 4 In the general worker protection section there should be reference to standard Personal Protective Equipment (PPE) to be supplied (Boots, safety helmets, reflective vests, overalls etc), general OH&S procedures to be used and any national requirements that will be observed. 4.1 The training programme material should be approved by the competent authority; consider giving workers a manual or a safety card at the end of the course; to be signed for as a record of training received. 4.2 All workers to be issued with a device for radiation monitoring using a system which is approved by the competent authority. 4.4 Where will work clothes be laundered? Washing water should be treated to the required standard before discharge. Laundry and shower waste water should pass through a sediment trap which will need to be cleaned and residues sent to the site at TP6. The laundry office and other buildings on site and associted with the works should be included in the radiation area monitoring programme, checking for contamination in dsignated clean areas as well as other locations.. 4.5 If dust masks are to be used a specification should be provided so the contractor is clear as to what must be supplied 4.7 A complete list of record keeping requirements should be assembled in one document. 5 If security staff are to be employed would their duties be included here? 5.1 Function of a crib room in comparison to a lunch room is not clearly stated is this the changing room? Change rooms should have two doors - for clean and dirty ways in and out. These rooms and all living accommodation, offices, etc on site and associated with the site should be included in the routine monitoring for radiologically contaminated surfaces. Facilities need to be sized to suit work force; information in documents suggests about 20 staff per shift rather than the 10 stated here. 5.2.1 As well as workers’ laundry water, workers’ shower water should be passed through the water treatment plant. In addition, what regulations are in place regarding disposal of sewage from site toilets? 5.3 Competent authority should designate the medical officer(s) authorised to carry out the workers’ medical checks and maintain records as well as the contractor. 6 Security guards should be included in the radiological monitoring programme if they are present on sites guarding plant and machinery etc., especially if their shifts are to be for 12 hours per day Contractor should ensure that rules on safety and security will be in place for conducting official visitors around the site e.g. dress, safety briefing etc This process to be supervised by the contractor 6.1 Areas for radiation control to be clearly marked as controlled areas, uncontrolled or supervised as appropriate. 6.2.1 Vehicle cleaning standard should be clearly stated to workers and inspectors e.g. “no visible contamination on vehicle tyres or bodywork” Wash down should include tyres, underbody, chassis and sides of the truck. These rules should also apply to the cleaning of any vehicle or equipment leaving the sites. 6.2.2 Decontamination standards should clarify what clearance levels refer to e.g. alpha, beta radiation etc. A protocol needs to be developed which will need to be applied to all equipment and materials involved, as well as scrap and waste, the water treatment plant, buildings etc 6.3 Needs to be clarification of how water quality discharge standard will be measured and how discharge system will operate. e.g. where will water be stored before it is found to be meeting the discharge standard? How will water be checked? Clarification needed that the discharge standard will be 0.5mgu/L as opposed to the national standard of 1.8mgU/L Not clear what the disposal plan is for sewage. 6.4 A specific incident and emergency plan should be drawn up, which will include the mechanism for reporting to the competent authority 7.1 The environment and radiation protection manger should be qualified in accordance with any requirements of, approved by, the competent authority. This position will require a clear job description, e.g. will this person also manage OH&S issues?</p><p>General What other environmental monitoring e.g. water chemistry, is planned, if any? Where will this programme be recorded and who will be the approving authority? Will reference and/or investigation levels be set in relation to radiation doses? What plans are in place for disposal of other possibly contaminated items e.g. used air filters from machinery, broken parts, planks used under excavator on tailings, etc? Contractor should be given very clear instructions on all waste disposal requirements. There is no reference to a programme of audit or performance checking. Whilst such programmes are carried out by the supervising engineers and/or the competent authority the contractor may be obliged to show that similar internal performance and compliance checks have been made.</p>