E4082 v4 Public Disclosure Authorized I. Environmental Management Plan- MOSTAR The Environmental Management Plan (EMP) for Mostar landfill Uborak, which is an integral part of the Environmental Framework (EF) is presented on the following pages. The EMP identifies the proposed mitigation measures to address the potential negative environmental impacts of the proposed Project activities. The content of the EMP is described in Annex 3 of the EF. Since EMP as such does not exist in national legislation it has to be prepared by WB standards. Public Disclosure Authorized The screening of the potential subproject sites will be done according to procedures described in chapter V of EF. Mostar landfill Uborak will serve as a sample case for the EF, and for this mitigation and monitoring measures will be presented. Background data The Mostar region encompasses two Cantons in FBiH, Herzegovina-Neretva Canton and West-Herzegovina Canton. Within these two cantons 12 municipalities are included. The largest city in this region is the city of Mostar, with more than 100.000 inhabitants. Mostar is now the administrative center for the Herzegovina-Neretva Canton. It also has a university, and before the war it had a well-developed industry. The major companies were Aluminij- Public Disclosure Authorized Aluminum electrolysis industry, Soko army aircraft industry, and Hepok agricultural complex. The major environmental issue in this region is protection of the Neretva River, which is a landmark, tourist attraction, hydro-power source, and an important water resource. Neretva is very important in agricultural irrigation. Neretva is also used as a drinking water supply, both in Bosnia-Herzegovina and neighboring Croatia. The Neretva flows almost through the entire Canton, through Croatia and discharges into the Adriatic Sea. Within the Mostar region there are a number of unsanitary landfills (legal) and illegal dumpsites. None of these sites have pollution-prevention measures that would safeguard the environment or the health and welfare of the local population and animals. Mostar itself is divided into 6 city municipalities, West, Public Disclosure Authorized South West, South, North, South East and Stari Grad. Within these 6 city municipalities two public works organizations are functioning. Those are: Parkovi which is in charge of waste collection for West, Southwest and South with no sanitary landfill as a final disposal site and Komos, the proprietor of the Uborak landfill that operates in the municipalities of North, South East and Stari Grad. The landfill The Uborak landfill is a fully sanitary landfill (donors have supported several millions of dollars of investments in Uborak). The pit is lined with impermeable foils, the gas release pipes are installed and so is a leachate collection- circulation system. The landfill encompasses an area of 7 hectares, with an additional 4.2 hectares designated for recycling and another 8 hectares for 1 future expansion of the landfill. Uborak also has an incinerator on site, which is not equipped with exhaust fumes treatment. The capacity of the existing pit is 440,000 m3, while the daily amount deposited amounts to 30 tons. Uborak is located some 10 km from Mostar, off the main road – M 17. It is fairly distant from the road. The nearby villages, for the most part, have been abandoned during the war, and there are no public institutions or designated public areas in the vicinity. The landfill is also free of any old war materials, explosives, mines and weapons. The illegal landfills, or wild dumps, to be closed are those within the regions to be serviced by the landfill sites supported by the project. This supports the strategy that with a well-functioning, sanitary landfill, transfer and collection system in place, illegal landfills will not be necessary. Approximately 30-40 transfer stations will be funded by the project. Transfer stations will be sited on existing illegal dump sites closed under the project. The investments financed will not affect any known archeological or historical site or any natural habitat, nor affect indigenous people. The social assessment has determined that there are no scavengers active in the landfills included in the project; and there are no people living on the existing landfills or illegal dumps. Doing nothing and consequence environmental impacts If a “do nothing� alternative was followed, the outcome can be reasonably foreseen. Uncollected waste will become more evident for longer in the residential areas and eventually public health impacts will be significant. The time scale for this scenario cannot be predicted with accuracy. Currently, the situation of SWM in BiH is serious. The large number of illegal dumpsites, and the poor quality of collection and operation of landfills affects the aesthetic look, environment and health of the entire country as well as neighboring countries, as well as the attitude of general local population. As an example, illegal dump sites allow for scavenging and animals roaming through a large collection of assorted waste. This means that all the health care wastes, food industry waste (carcasses etc.), hazardous waste is openly accessible to disease vectors and human contact. The potential for contamination of water supplies is great in the “do nothing� alternative. In the Mostar region which is predominantly karst, it is evident that the leachate from piles of waste will eventually find their way into the water. Being open, this waste can often be propelled by the wind. The effects of unregulated wild dumpsites are very broad. As an example an abandoned mine in Mostar has been used as a dumpsite. This dumpsite allows leaching of waste materials directly into a lake connected to the Neretva river, which is not only a tourist attraction and recreational area but most importantly a drinking water and irrigation source for a large portion of the Southern region as well as neighboring Croatia. Whatever monitoring program that may have existed before the war, if any, it no longer exists. Currently, no monitoring activities are carried out at any of 2 the locations, except for weighing of waste at the Uborak landfill in Mostar, where preliminary ground water sampling has been done in 1990 and 1991. There is no baseline data for any other environmental parameter. The SWMP II will significantly contribute to improve environmental quality monitoring. The project will finance monitoring programs, equipment and services. It will also finance training in monitoring on the national and regional level. The common monitoring program to be used for the project landfills is described bellow. Monitoring and Enforcement The Environmental Assessments of each site includes analysis of the site's location and environmental quality, before the works commence. Currently, there is no indication that the groundwater is contaminated by the leachate at any of the landfills intended for rehabilitation. However, throughout the period of the operation of the landfill, there will be an increase in the leachate discharge. It is important to monitor the quantity and quality of the leachate to prevent potential groundwater contamination. Upon organizing the multi- municipal SWM program the Cantonal Ministries in the regions of interest shall organize an overseeing board. This board shall be composed of representatives of each involved municipality, and as such, will have the power to influence, if not bring about the major decisions regarding the management of this concept. This board will oversee most of the activities dealing with SWM. Monitoring will most likely be included in their scope or the scope of the Utility Comany, and will be controlled by periodically scheduled on-site inspections and/or reports. Some of the visual/observatory monitoring activities may be conducted by the trained staff at the site. However, when dealing with monitoring that requires laboratory analyses, it is not cost efficient to have one lab per region conducting these analyses. The project intends that all the tests be conducted in one or two central laboratories for the entire country. The capacity of the laboratories to conduct these analyses would lead to the possibility of involving the well-equipped Institute of Hydro-engineering at the Faculty of Civil Engineering in Sarajevo, and the Institute for Public Health in Sarajevo. Air quality can be analyzed at the Ex- Jugoinspekt laboratory in Kakanj. The parameters to be monitored are based on national waste strategy are as follows: - Leachate quality on site - Groundwater quality in surrounding and downstream areas - Surface water quality in surrounding and downstream areas - Soil quality in surrounding areas - Gas emissions from the site - Incinerator emissions - Weight of the waste - Composition of the waste - Disposal suitability of the waste (Hazardous waste) - Construction activities - After decommissioning monitoring 3 In Bosnia-Herzegovina there is no central agency that might provide baseline environmental quality information, nor is there any available written evidence. The data that is not available contains surface water, groundwater monitoring, and air quality, leachate and gas measurements. These should be assessed through the EIA procedure. The number of trucks, equipment and waste composition at each site has been given in detail within the Feasibility Studies for each site as well as waste composition, volume, and weight, GWCC and IHTM studies. Environmental Impacts and Environmental Management Plan (EMP) By improved collection, transfer, and disposal of solid waste, and the reduction of illegal dumping in environmentally sensitive areas, the project is expected to have positive benefits to human health and to reduce adverse environmental impacts of waste disposal. Additional positive impacts include: (i) improved waste collection would lessen the quantity of uncollected waste; (ii) improved collection methods, landfill design and management practices will separate municipal wastes from medical wastes and provide for the separate and proper disposal of each; and (iii) closure of illegal dumps will eliminate future contamination and health hazards. While resource recovery and recycling are desirable in the long term, there is currently just a formation of a market that will provide adequate payment for recyclables to fund the additional costs associated with waste separation. Recycling, including composting of solid waste, will only be considered for inclusion in the project scope if there is solid evidence of a long-term market potential and customer willingness to pay. Potential negative environmental impacts associated with solid waste management include contamination of soil, groundwater, surface water and air quality. These impacts would be associated with construction; collection, transfer and storage; operation of the landfill; leachate and gas emissions from landfills and transfer stations; and decommissioning of the landfills. Improper landfill siting is not a consideration as no new construction is planned. Of the three components of the SWMP II, only “Component A. Waste Management� includes activities which may have potential for negative environmental impact. The sub-components of rehabilitation of landfills, closing of landfills, and transfer stations may have potential negative environmental impacts. Rehabilitation activities will vary from site to site. Uborak landfill requires minimal rehabilitation. The following tables provide the specifics for each region/site and mitigation measures. Institutional capacity to implement project and environmental safeguards Institutional arrangements for the implementation of the Solid Waste Management Project I and II (and subprojects) have been defined, consisting of a Project Management Unit (PMU) formed in the Ministry of Environment and 4 Tourism. In addition the same, a board appointed will supervise individual subprojects project as in SWMP I. This board consists of a representative from each municipality which is using the same landfill, and will protect the interest of each municipality in terms of the system running smoothly and fairly. As the SWM system is going to be based on a regional basis the existing Utility companys will have to be merged into one. Each of the municipalities would have to have an engineered transfer station at the location of their existing disposal site. The overseeing “institution� would, in accordance with the Ministries at the Cantonal/Regional or Entity level, coordinate inspections and monitoring. The PMU is responsible for the overall environmental management and decision making in accordance with the EF during the preparation and implementation of subprojects. A separate environmental unit for the project is not required, since the PMU will be staffed by qualified personnel and specialists which will be able to carry out environmental management along with technical assistance from the World Bank and independent experts/specialists. The Utility Company /boards in charge for the landfill are responsible for obtaining an Environmental Permit for subprojects that impact the environment. For the purpose of screening, the utility company/board, with the guidance of PMU, should prepare the initial project concept/minimum required information about the project which will enable adequate categorization. The PMU will play a key role during the screening, and will participate in categorization of subprojects in accordance with requirements of national legislation and Bank’s procedures, based on the screening presented in chapter V. The results of the screening and categorization should be reviewed and approved by the Bank. The Bank should provide assistance during the screening process, especially with respect to safeguards. Furthermore, the PMU will advise the Utility Company /board on the World Bank EA requirements (contents of an EA report and/or EMP format), the EF chapter requirements and other necessary information. The PMU will also be responsible for contacts and consultations with entity ministries, related to requirements, procedures and EIA contents for projects requiring environmental permits from the entity level (Cat I, Cat II and Cat III subprojects). Where an Environmental Permit or any other necessary permit (e.g. location or construction permit) is issued by cantonal or municipal authorities, the Utility Company should send the official permit request and attached documents to the PMU for review prior to submission to authorities. The PMU with the Utility/board is responsible for selection and contracting of Consultants to be engaged in the preparation of the EIA report or EMP as well as for supervision during preparation. EIA reports or other separate reports (such as EMP) will be submitted by the PMU to the Bank for review and approval. For Cat A projects the Utility Company /board retains independent EA experts not affiliated with the project to carry out the EA. Consultations with project affected groups and NGO’s will be arranged by the Entity Ministry. In case the Entity Ministry is not responsible for the consultation by national 5 policies, the Utility Company /board will be responsible for carrying out the consultation, in agreement with the PMU and by informing the competent ministry/authority. The Utility Company /board will send a copy of the consultation record to the PMU. In case significant issues have been identified during the consultations, the PMU will inform the Bank accordingly. The Utility Company will as well be responsible for selection and contracting of licensed company / laboratory (e.g. central BiH laboratory) for monitoring of EIA requirements. The data collected during these monitoring activities would need to be readily accessible for all interested parties. Due to the cost of local and external work force, monitoring should be carried out by the staff of the landfill, once properly educated and trained. During both the construction and operating phases of each subproject the Utility Company /board will carry out the monitoring defined in the EIA and EMP to ensure that mitigation requirements specified in the EMP and any other environmental requirements specified in the Environmental Permit are complied with. The environmental protection law requires that the Utility Company /board reports to the competent authority (that issued the permit) on emission monitoring results, accidents, and other information requested by the permit(s), during the initial and last phases of construction, operation and decommissioning. When required by national policies, and if the PMU finds it necessary (due to lack of equipment or capacity), specialized institutions/companies will perform the required monitoring and data collection. Implementation of mitigation measures specified in the EMP and Environmental Permit must be supervised by the PMU on biannual basis. Reports on mitigation measures and monitoring results are submitted by the Utility Company /board to the PMU for the project progress report. The PMU is responsible for reviewing and analyzing the reports received from the Utility Company /board and can request additional monitoring in order to ensure that all environmental guidelines and permit requirements are satisfied. The environmental compliance reports will be attached to the annual progress reports submitted by the PMU to the Bank. In addition the responsible Ministries will be in charge for the monitoring of the EIA requirements. Allocation of responsibilities The Entity (FBiH and RS) Ministry of Environment will be assigned the following tasks: conducting inspections, mandating monitoring activities, collecting and forming a database of monitoring results and analyses. Each Canton/region within which the landfill is located, can take over the activities of the Entity body that can not be conducted at that level. The Canton will enforce and penalize improper disposal activities, form the overseeing institution, conduct an educational campaign for the general public and try to motivate the population to accept the SWM system. 6 Please note, under the column of institutional responsibility when the listed institution is Utility Company this means the authority on the landfill or the authority for transport, which shall be determined once the overseeing body has been formed. When governmental authorities are mentioned this means the entity or regional authorities which would govern SWM legislation. It has also been deemed necessary to set up some sort of public education campaign for the general local population. This campaign shall entail billboard advertisements, TV advertisements and flyers. This is listed as education done by the government authorities. Table 1Environmental Mitigation Measures Institutional LOCATION: MOSTAR UBORAK LANDFILL Cost responsibility Phase Issue Mitigating measure Install Operate Install Operate Comments The Utility company in Sanitation of existing Varies by charge of a given Clandestine dumping wild dumps, or the region Operation causes widespread collection of such location For serious cases the environmental pollution waste, Penalizing for and government illegal dumping conditions intervention should be included 7 Institutional LOCATION: MOSTAR UBORAK LANDFILL Cost responsibility Phase Issue Mitigating measure Install Operate Install Operate Comments The government The waste is scattered Education and raising authorities ( FBiH or around the collection environmental Cantonal) should containers causing awareness of local Education: Operation conduct the aesthetic degradation population US$ 18,000 educational campaign and increase in disease Efficient waste Utility company should vectors collection intervals improve collection rate Meshing: Waste collection in The vehicles are Use of closed vehicles US$3-5,000 open-container vehicles already equipped Operation or protective cover on New truck: Utility company causes littering along with a mesh net the container US$ 90,000 the collection route cover. per truck Residual waste on the The vehicles are Utility Utility collection trucks poses Cleaning of vehicles already cleaned on Operation US$ 10,000 company / company / a threat to health and after dumping of waste site, after each Landfill Landfill aesthetics disposal. Poorly maintained The vehicles are Utilize newer vehicles US$ 4,000 Utility Utility vehicles pose an regularly maintained Operation and ensure proper / truck- company / company / additional air pollution on site at the Komos maintenance year Landfill Landfill threat headquarters. 8 Institutional LOCATION: MOSTAR UBORAK LANDFILL Cost responsibility Phase Issue Mitigating measure Install Operate Install Operate Comments US$ 250- Mandate use of one 600 /bin Non-uniform waste bins standard waste Utility Utility according Operation and containers cause container type suited company / company / to bin size inefficient collection to the collection Landfill Landfill US$ 4,000 vehicles. per vehicle Mandate use of a standard waste Large, non-uniform bins container type suited US$ 250- are a health hazard to Utility Utility to the automatic lifting 600 /bin Operation workers while manually company / company / onto the vehicle. If not, according loading them on the Landfill Landfill mandate use of smaller to bin size vehicles waste bins adequate for manual loading. Government Improvement of environmental collection services to authorities should Open burning of waste include the majority of Education: conduct educative Operation causes air pollution the local population US$ 18,000 campaign Education of local Utility company / population Landfill should improve services 9 Institutional LOCATION: MOSTAR UBORAK LANDFILL Cost responsibility Phase Issue Mitigating measure Install Operate Install Operate Comments Utility company / Potentially hazardous Placing special Landfill should conduct US$ 250- solid and liquid ( containers on services 600 /bin Operation contained) waste collection sites Government according poses a bigger threat to designated for such environmental to bin size groundwater waste. authorities should legally regulate There is definitely Utility US$ will at Uborak company- Not recycling materials Training and equipment 100,000 Utility landfill but no with decreases the capacity for recycling. for basic company means. Some governmen Operation of the landfill and Governmental recycling through recycling attempts t further depletes natural awareness of such including funds or of cardboard and environme resources revenue possibilities. cardboard donations aluminum have been ntal legal and metal made. backing The landfill site is a Placing a fence around The only issue in health threat through the premises, and Uborak is a large US$ 15 / m Utility Utility Operation its accessibility to having security at the number of ravens of fence company company animals and scavengers site and seagulls. Increasing the Covering the waste US$ 100- Large number of birds Utility Utility Operation frequency of waste is mechanically 200 per act as disease vectors company company cover up done. day 10 Institutional LOCATION: MOSTAR UBORAK LANDFILL Cost responsibility Phase Issue Mitigating measure Install Operate Install Operate Comments Utility Lack of a methane company collection system Using a gas torch to Gases are freely US$ 12,000 Utility with Operation causes a threat to the burn off the generated emitted into the / ha of company governmen atmosphere through gas atmosphere landfill tal legal release of GHG backing The landfill is equipped with fire Lack of a methane Using a gas torch to US$ 12,000 hydrants around the Utility Utility Operation collection system burn off the generated / ha of perimeter and an company company causes a fire hazard gas landfill additional water storage pool. Lack of a leachate Already present at collection system poses Installing a leachate the site, involves Utility Utility Operation N/A a threat to the collection system circulation of the company company groundwater leachate Utility The proximity of the Sealing off leachate in The landfill already company/ landfill to a drinking the landfill, collection contains PEHD foils Utility Operation N/A ind. water source poses a of leachate and proper on the bottom and company laboratorie health threat monitoring sides of the pit. s 11 Institutional LOCATION: MOSTAR UBORAK LANDFILL Cost responsibility Phase Issue Mitigating measure Install Operate Install Operate Comments The surrounding houses around the site are mostly abandoned. Operation of the Utility There are no known landfill causes a noise, company endemic species in US$ 30 per aesthetic and health Placing a buffer zone Utility with Operation the vicinity. meter of threat to the nearby around the site company governmen There are no length local population and tal legal schools, hospitals or environment backing other institutions in the area except for the army barracks next to the site. Burning of wastes in an Installation of filters Utility incinerator without and appropriate Some burning has company exhaust treatment and equipment Training of occurred of expired Utility with Operation monitoring causes air staff to know what food cans and SFOR company governmen pollution wastes can be burned medical wastes. tal legal and how backing 12 Institutional LOCATION: MOSTAR UBORAK LANDFILL Cost responsibility Phase Issue Mitigating measure Install Operate Install Operate Comments The site is fairly withdrawn from the The landfill and its major road and local US$ 30 per operational facility may Placing a buffer zone Utility Utility Operation population center meter of be aesthetically around the site company company and can not be seen length unpleasing except from close by. Seasonal variations US$ 100- Increasing the number This method is Utility Utility Operation cause an increase in 200 per of cover up layers already in effect company company odor in summer time day The landfill poses a US$ 30 per Utility Placing a buffer zone, threat to nearby small meter of Utility company Operation Carrying out proper farmlands length of company with monitoring buffer indep. labs Dirt roads around the Access roads are landfill generate dust- paved in a narrow Paving the access roads US$ 25- Utility Utility Operation particulate air pollution strip, while the and landfill roads 30,000 company company roads on site are not. 13 Institutional LOCATION: MOSTAR UBORAK LANDFILL Cost responsibility Phase Issue Mitigating measure Install Operate Install Operate Comments The workers have Utility the proper, US$ 200 Proper protection, company mandated per worker The workers are proper education and Utility with Operation equipment and are + methane exposed to health risks training, regular health company governmen also subject to detectors checks tal legal semiannual health US$ 500 backing checks. Cover layer materials The landfill uses the obtained from other on site excavated Utilizing materials Cost is sites place a stress on materials as well as whose procurement included in Utility Utility Operation the environment of additional soil does not directly harm the cover company company material's origin whose procurement the environment up. does not harm the environment Expansion of the Utility The BiH authorities landfill site might take Thorough survey of the company Future designate the use of up land otherwise site Utility with Expansion / the land as was the useful. Accordance of the company governmen Construction case with the authorities tal legal current site. backing 14 Institutional LOCATION: MOSTAR UBORAK LANDFILL Cost responsibility Phase Issue Mitigating measure Install Operate Install Operate Comments Most surrounding Construction work settlements are Utility Utility Future might endanger the Limit construction to abandoned and the company company Expansion / surrounding the standard level environment is with with Construction environment and (time-wise) mostly rocky, hilly constructio constructio inhabitants and has scarce n workers n workers vegetation. Expansion site Fencing off the site Utility Utility Future construction and Requiring proper safety company company US$ 15 / m Expansion / operation causes gear Future project with with of fence Construction potential health and Limiting access to constructio constructio welfare risks workers only n workers n workers Thorough site investigation and Future Site might cause monitoring US$ 400- Utility Utility Expansion / pollution of ground Future project Installation of a clay 500,000 company company Construction water bottom layer followed with PEHD foils Utility Utility company company A small flood brook may Future with with be polluted from the Expansion / Rerouting this brook Future project constructio constructio expansion of the Construction n and n and landfill design design workers workers 15 Institutional LOCATION: MOSTAR UBORAK LANDFILL Cost responsibility Phase Issue Mitigating measure Install Operate Install Operate Comments Any decommissioning of Careful monitoring that the leachate system Utility Utility Decommission would be less frequent might cause a spill into company company than during operation the environment. Pit might be accessible to disease vectors such Placing a final layer on Utility Utility Decommission as animals, rodents and the pit company company pests. US$ 20 / Collection of rain water m2 Utility Utility Decommission Surface drainage on top of the site company company Placing final cover and Utility Utility Decommission Possible landslides vegetating the area company company 16 17 18