ABSHERON REHABILITATION PROGRAM CONTAMINATED SITES … · 2016. 7. 11. · Brief Description of the...

ABSHERON REHABILITATION PROGRAM

CONTAMINATED SITES REHABILITATION PROJECT

ENVIRONMENTAL IMPACT ASSESSMENT

FOR

CLEANING OF AREAS POLLUTED WITH RADIOACTIVE WASTES AND OIL IN TERRITORY OF SABUNCHU AND SURAKHANI DISTRICTS OF BAKU

EXECUTIVE SUMMARY

MINISTRY OF EMERGENCY SITUATIONS BAKU

February 12, 2008

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Table of ContentsINTRODUCTION............................................................................................................... 1

Background ..................................................................................................................... 1 Overall Project Description and Environmental Assessment Category.......................... 2 Brief Description of the Investments Proposed for the Clean-up and Rehabilitation of Two Former Iodine Sites and the Construction of a Dedicated NORM Storage Facility......................................................................................................................................... 3

ENVIROMENTAL BASELINE CONDITIONS ............................................................... 4 ALTERNATIVES CONSIDERED..................................................................................... 6 POSSIBLE IMPACTS OF THE CHOSEN ALTERNATIVE ........................................... 6 SUMMARY OF THE ENVIRONMENTAL MANAGEMENT PLAN ............................ 7 PUBLIC CONSULTATION............................................................................................... 8 SOCIAL ASPECTS ............................................................................................................ 8 COMPLIANCE WITH APPLICABLE WORLD BANK SAFEGUARD POLICES........ 9

List of Abbreviations ARP Absheron Rehabilitation Project EA Environmental Assessment EIA Environmental Impact Assessment EMF Environmental Management Framework EMP Environmental Management Plan ESP Environmental State Program IAEA International Atomic Energy Agency IDP Internal Displaced People MES Ministry of Emergency Situations NGO Non-Governmental Organization NORM Naturally Occurring Radioactive Materials OP/BP Operational Policies / Bank Procedures RAP Resettlement Action Plan RPF Resettlement Action Plan TOR Terms of Reference WB World Bank

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INTRODUCTION

Background

The Government of Azerbaijan has requested the assistance of the World Bank in financing activities under the proposed Contamination Sites Rehabilitation Project (the Project) that will help the country towards achieving the Environmental State Program (ESP) goals targeting decontamination operations as well as advanced environmental management. The ESP intends to address both the legacy as well as the on-going environmental pollution from the oil production activities that generated irreversible environmental degradation both land based and off shore. The Project aims at declining the health risks and improving living standards of the families in the project area by reducing their exposure to air, land and water-pollution generated by potential radiation hazard from the low-level radioactive charcoal waste materials and other oil production pollution sources. Therefore, the Project intends through its five components to build capabilities and operations in high priority site clean-ups such as two former iodine production contaminated sites and 1000-ha oil polluted land in the Absheron peninsula through (i) full-scale site remediation including repackaging and transport of contaminated low-level radioactive waste and the disposal of this material at a newly built disposal facility; and (ii) removal of old oil production infrastructure and other types of waste, decontamination from oil spills, and oil processing equipment from the highest priority polluted sites. The Project will be implemented by the Ministry of Emergency Situations (MES) through an established Project Working Group and will collaborate with the International Atomic Energy Agency’s (IAEA) who will offer advice and project oversight. The Project is part of the broader World Bank supported Absheron Rehabilitation Program (ARP) for cleaning up the environment in Azerbaijan. The program consists of multiple investment interventions selected from priority activities listed in the ESP and agreed with the concerned government agencies. The first stage of projects ready for implementation within this long-term collaboration program (ARP) focuses on (i) critical investments that will quickly tackle some of the worst environmental issues in Absheron and drastically improve living conditions for some of its residents, including informal settlers, and (ii) the development of environmental cleaning capacity. These first phase projects with a proposed implementation schedule during 2008-2013 are: (1) the Contaminated Sites Rehabilitation Project (the Project); (2) the Integrated Solid Waste Management Project; (3) the Large Scale Oil Polluted Land Clean-up Project, and (4) the Strengthening Environmental Policy and Enforcement for Environment State Program.

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Overall Project Description and Environmental AssessmentCategory

The Contamination Sites Rehabilitation Project will finance activities under the following five components: Component A: Clean-up and rehabilitation of two former Iodine Sites (US$11.5 million); Component B: Construction of a dedicated NORM storage facility (US$7.0 million); Component C: National Mapping and Remediation Program for NORM Contaminated Sites (US$11.0 million); Component D: Remediation Program for the 1,000ha Site (US$22.0 million); and Component E: Technical Assistance and Project Management (US$3.5 million). The decontamination of two former iodine production sites (Component A) involves removal, repackaging and transport of contaminated low-level radioactive waste at two sites as well as the disposal of this material at a newly built dedicated NORM waste storage facility (financed under Component B). Component C will enable MES to execute at the national level an extension survey program to map the NORM contaminated sites and subsequently investigate these sites to determine contamination levels, priorities and remediation or containment actions. The component C also includes abudget (US$ 5.0 million) for high priority NORM contamination clean-up operations, that have not been identified yet but that will be determined during the national mapping. Component D will develop approaches to cleaning up 1,000 hectares of oil polluted land situated between the Buzovni and Mashtagi settlements. Finally, component E will provide financial support for the management and performance monitoring of the Project as well as for technical assistance towards institutional development, strategy development and planning. In accordance with the Bank’s safeguard policies and procedures (OP/BP 4.01 Environmental Assessment and OP/BP 4.12 Involuntary Resettlement) the proposed project has been classified as environmental assessment Category “A”. Main investments are targeting remediation, clean-up works and proper disposal of highly radioactive and non-radioactive contaminated land in the Absheron Peninsula including about 32 ha land polluted by low-level radioactive waste, oily compounds and other hazardous materials derived from over 60 years of iodine production operations in Baku area (Surakhani and Ramani settlements) as well as 1,000 ha of oil polluted land covered with more than 300 un-operated wells and other old oil exploitation equipment and infrastructure. Other high priority NORM contamination cleanup operations are envisaged under the project at selected sites identified later during project implementation once the national mitigation program for NORM contaminated sites and affiliated national mapping strategy (project component C) are developed. Given the multiple components included in the project, complemented by the fact that MES still needs to finalize several specific investments (e.g., decontamination of the highest priority oil production sites and specific cleanup interventions at the 1,000 ha)

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proposed to be financed under this project, the Bank and MES have agreed that the following documents1 will be prepared prior to appraisal in order to meet the Bank’s Category A requirements and the national EA legislation: (i) a full Environmental Impact Assessment (EIA) report2 including a proper EMP for the decontamination works of the 32-ha land at two former iodine production sites and the safe disposal of 85, 000 m3 of charcoal waste in a special NORM storage facility; (ii) an Environmental Management Framework (EMF) for the cleanup works envisaged at the high priority NORM contaminated sites and the 1,000 ha of oil polluted land; (iii) a Resettlement Policy Framework (RPF) and (iv) a Resettlement Action Plan (RAP) for the relocation of the 13 IDP families from the Surakhani site. The Environmental Management Framework3 (EMF) prepared for investments at additional sites that require further decontamination (unknown at this point, Component C) and for the cleanup works proposed at the 1.000 ha site (Component D), provides a general option impact analysis with environmental and social criteria and an overall assessment on how to mitigate and monitor possible environmental effects affiliated with these investments. The EMF is attached in the Annex. The goal of the current document is to reflect the Executive Summary of the EIA report prepared by MES in connection with the investments financed under Components A and B of the proposed Project. Therefore, the following chapters refer only to the content and conclusions of the environmental assessment developed for the proposed decontamination works at the Surakhani and Ramani former iodine plant production sites and for the affiliated NORM disposal facility constructed under the project.

Brief Description of the Investments Proposed for the Clean up andRehabilitation of Two Former Iodine Sites and the Construction of aDedicated NORM Storage Facility

Two former iodine production sites in Greater Baku are contaminated with waste that remained from the extraction of iodine from oil production water. Consequently, the sites are partially covered with heaps of charcoal that contains NORM and other heavy metals, polluted soil, and old production facilities that contain oily products. Also, existing structures are contaminated and materials such as radioactive scaling and asbestos can be found on site as well. Contamination levels and the most efficient methods to remediate the sites preferably for future development as residential areas were determined in a feasibility study. Implementation of the cleanup works at the two iodine sites include: (i) development of a Temporary Safety Plan to minimize exposure of the public to hazardous materials on the sites through fencing, supervision etc. for the period between the start of the project and the commencement of the decontamination works, (ii)

1 These draft documents are disclosed 120 days before the proposed Board date of June 12, 2008 2 The current document represents the Executive Summary of this EIA. 3 The EMF is disclosed separately and does not represent the subject of the current document.

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preparation of detailed site investigations, detailed design of works and works supervision requirements, (iii) the removal, packaging and transport of the radiological waste, (iv) the removal and disposal of other hazardous materials to the existing hazardous waste sanitary landfill, (v) the clean-up of oil contamination and contaminated water reservoirs on the sites and (vi) the demolition of buildings and the preparation of the site for re-development. It is envisaged that, following remediation, the two sites will be declared safe for “unrestricted use” by the national regulatory body so that options for land use and redevelopment can be explored.

Adjacent to the existing Izotop storage facility for radioactive sources, MES has planned the construction of a special sanitary above ground (or partially in-ground) storage facility for NORM. This facility will have sufficient capacity to contain the NORM from the two iodine plant sites and spare capacity and extension possibilities to store additional NORM from future clean-up operations. The project will finance detailed site investigations, the detailed design, construction works and operations to receive the NORM from the former iodine sites. Future (post-project) operations and monitoring will be managed by Izotop under supervision of MES and in collaboration with the International Atomic Energy Agency (IAEA).

ENVIROMENTAL BASELINE CONDITIONS The Baku iodine plant, which operated during the period of 1930–1990, consisted of two production sites situated next to Ramani and Surakhani settlements. The total area occupied by the former plant is about 32.5 ha of land, of which 4.3 ha represent the Ramani production site and 28.2 ha the Surakhani site. According to the practiced technology, iodine and bromine were extracted by activated carbon (charcoal) absorption from the oil production water formed from the layer water, including also natural radio-nuclides (e.g., uranium-238 and radium-226/228 and potassium-40), which surfaced together with the oil extracted from the respective oilfields. The used charcoal waste accumulated and stored at the two production sites without proper utilization or disposal during the 60-year plant operation is classified as radioactive waste given the presence of the radium isotopes. When the iodine plants stopped operation and were abandoned in 1996, no measures were taken to remove the waste materials or to contain the waste on site. Since then, site structures and scrap metal (used pipes, valves, collectors, etc.) have deteriorated releasing waste materials that were originally contained inside buildings and the charcoal waste heaps have been subject to weather influences and use as a source of fuel by local population. Adjacent residential areas are encroaching upon both the Romani and Surakhani sites. No people live at the Romani site, but 13 families (55 people, refugees from Nagorno-Karabakh) live in the former office buildings at the entrance of the Surakhani site since 1993. Several technical and engineering background studies (e.g., Feasibility study, EIA, site characterization analysis) have been developed by MES during the project preparation to

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characterize and define the site current baseline environmental conditions including historical site contamination description and spatial distribution of contaminants, groundwater pollution assessment, existing potential radiological dose to the public, and evaluation of radioactive and non-radioactive waste management at the project sites. From available information recently collected in October 2007, the estimated volume of radioactive waste at the two former iodine sites totals 85,310 m3 (18,993 m3 at Ramani, and 66,377 m3 at Surakhani site). The gamma-radiation dozes on both sites have been found to exceed the region’s normal indicators. Considerable contamination by abovementioned isotopes was also observed in the chemical sediments deposited in the inner walls of the asbestos pipelines used for the drainage of processed oil water. Pipelines transported the used water together with other liquid wastes back into the reservoirs or into the neighboring industrial waste collectors. Artificial lakes containing high petroleum acids’ concentration were created in natural hollows on both former production sites as a result of the oil water discharge during the plant operation. Groundwater on both iodine sites present at depths varying between 0.34 and 2.9 m is likely to be contaminated with radio nuclides, heavy metals, and other oil compounds as a result of the lack of proper waste management at these sites. From the analyses performed during the EIA process, the following characterization describes the baseline situation at the two production sites:

• the radiological contamination analysis revealed that the charcoal waste identified at the two sites correspond to the II and III radiation hazard categories4 while the asbestos pipes, the charcoal mixed with bricks or soils, and different other mixed solid wastes correspond to the I and II radiation hazard categories according to the IAEA classification. According to the testing results, buildings and construction materials located on sites may not be considered as radioactive materials. Solid samples collected from the sites were found to be exposed to considerable radioactive contamination, which requires total removal of topsoil up to a 1 m depth;

• Large volumes of active charcoal (of category II) were discovered in samples collected from the bottom sediments of adjoining artificial reservoir (lake);

• Specific activity level of radium isotopes contained in surface and groundwater was found to be of concern (e.g., 0.2 Bq/l);

• Air measurements collected at both sites identified radon at a specific activity level of about 110Bq/Kg; this is considered low mainly due to the open-air storage of radioactive charcoal waste and prevailing winds;

• Furthermore, oil contamination in soils was detected on both Ramani and Surakhani sites with concentrations varying between 5-60 times more than the allowable concentration level at the Ramani site and between 2 - 65 times more at the Surakhani site. The oil contamination in ground water at both sites is about 3-55 times more than the allowable concentration level. Main heavy metals analysis

4 In accordance with the IAEA classifications these waste categories must be totally removed from the site

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performed at both sites revealed concentrations lower than the acceptable concentration level.

Based on the analysis conducted and the results obtained, the EIA report indicates the rehabilitation criteria of the polluted area and proposes rehabilitation methods viable for the defined contamination level. The site proposed for the construction of the new NORM disposal facility is located at the current disposal area for high radioactive wastes (sources) owned by the Special Industrial Complex “Izotop”. This storage facility is located at approximately 37 km from Baku in a relatively isolated area where there is no groundwater (up to a depth of 600 m) and 10 km away from the nearest water and gas pipelines. Also, there are no settlements or industry within 3 km from the site. For these features, the site has been determined as most suitable for management and storage of radioactive waste. The existing facility has been constructed and is operated in line with international good practices and includes also a mobile laboratory to monitor and analyse radioactivity levels. After being sorted out by activity and life-time, the high and medium radioactive waste is stocked in 200-litre barrels and stored in 4m deep concrete bunkers that are continuously monitored. The construction of the new NORM facility foresees works including building an in-situ reinforced concrete shelter, steel fence, and a separate 700m long road from the Baku-Shamakhy highway to the facility.

ALTERNATIVES CONSIDERED The EIA and the feasibility study identified and evaluated several alternatives to the proposed investments, including the no action alternative; alternative ways of decreasing the environmental pollution at both sites through neutralization of the radioactive and oil waste on site; other cleanup alternatives including partial offsite disposal and management of hazardous waste. In particular, distinguishable alternatives exist for the disposal of NORM waste: (i) burning, (ii) covering, (iii) dumping in wells, and (iv) transportation and disposal of the waste in a special landfill for radioactive waste. MES, in consultation with IAEA, and based on international best practice, short and long term safety issues, and cost effectiveness considerations, has concluded that the preferred approach is to remove the waste from the contaminated sites and dispose of it in a newly constructed dedicated sanitary landfill for radioactive waste, adjacent to the existing Izotop facility for disposal of radioactive sources. This solution also serves the need for special long-term monitoring requirements that come with the disposal of radioactive waste. For this reason, existing hazardous waste disposal sites were not considered.

POSSIBLE IMPACTS OF THE CHOSEN ALTERNATIVE The proposed cleanup investments are expected to have important and positive environmental impacts on the Absheron Peninsula, that will lead to: (i) reducing public health risks and environmental damage caused by inappropriate management of the site’s

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legacy waste from years of oil production activities in the project area; and (ii) possible new land utilization following cleanup and remediation of two former iodine production sites in Surakhani and Ramani. The activities which raise short-term environmental concerns are those related to the execution of specific proposed civil works that involve: (i) full-scale remediation of two former iodine production sites, including treatment, packaging, transport and disposal of affiliated plants’ buildings and of about 85,000 m3 of mixed low-level waste (charcoal) piled and buried at these sites; and (ii) construction and operation of long-term radioactive waste storage facility receiving waste from the two former iodine production sites and from other oil production site clean-ups. Predicted environmental impacts of the chosen activities are related mostly to construction works performed during the proposed cleanup and disposal of the charcoal waste. Temporary effects may appear during the construction of the new NORM facility but these are manageable if the selected contractor performs the works in according with the international and local construction standards. Effects could appear on air quality and noise (e.g., associated with excavating waste sites and transporting waste to the disposal facility, vehicle emissions), soil or surface and groundwater (e.g., cumulative radionuclide concentrations). The EMP including mitigation of possible environmental impacts and a monitoring program during the construction phase as well as after completion of proposed civil works will ensure that negative impact could be managed appropriately. The long-term monitoring program (including radioactive measurements) proposed during as well as after project implementation for the different areas of the environment at the iodine plant sites will allow constant verification of physicochemical and biological changes associated with the cleanup remediation on the site and will provide guarantees to the health of the population and contractors performing the works. A summary of the EMP is presented below.

SUMMARY OF THE ENVIRONMENTAL MANAGEMENT PLAN The EMP provides a rigorous environmental monitoring program consisting of sampling and analyzing various media (water, groundwater, air, soil and sediments) on and around the project sites to detect potential radioactive or other hazardous contaminants such as heavy metals and inorganic chemicals. Such monitoring data will be evaluated to determine the degree of regulatory compliance and for pollution-management practices. Furthermore, the EMP provides a thorough presentation on mitigation measures applicable to the cleanup and construction works including: (i) site management and institutional controls; (ii) health and safety protection for cleanup workers and nearby residents; (iii) contingency planning and emergency responses (including spills); (iv) mitigation measures for collecting and discarding radioactive waste; and (v) radioactive waste transport mitigation measures.

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Institutional arrangements and costs for implementing the mitigation and monitoring are also provided. Implementation will be accomplished primarily through a project implementation team within the MES, and supported staff of relevant environmental agencies. Monitoring of project performance and implementation of EMP requirements will --as noted—be the responsibility of the MES implementation team, but the team will relay heavily for this task on the support of: (i) the day-by-day responsibility to monitor work progress and environmental performance by the independent supervising engineer; (ii) the oversight of an independent project steering committee for which regulatory institutions will be invited; and (iii) the panel of national and international experts for which also IAEA specialists will be invited.

PUBLIC CONSULTATION A public consultation process has been implemented for the project in accordance with the Bank OP 4.01. An initial public meeting was held by MES on December 19, 2007. The meeting was attended by representatives of the Academy of Sciences, NGOs, local governments and community representatives (municipalities) of the districts of, or adjacent to, the project areas. The project team (implementing agency and consultants) briefed the audience on the proposed project and on the preparatory work carried out, answered questions raised by participants. The second round of public consultations on the EIA and related safeguard documents was held on February 7, 2008 when draft documents were presented and discussed to a various public. Comments received during both meetings were incorporated in the final safeguard documents and publicly disclosed in Azerbaijan and at the Bank’s Infoshop.

SOCIAL ASPECTS During the preparation of the project, the Social Impact Assessment (SIA) was carried out with the main focus on the following issues: a) impact on IDP families living on the Surakhani iodine plant site; b) possible impacts on population living in the close neighborhood to iodine plant sites; and c) assessment of potential impact on population living along the radioactive wastes transportation route. The SIA has identified 56 IDPs in 13 families in Surakhani and approximately 55 individuals in the entire contaminated land that spans over 1,000ha. Other findings of the SIA include: (i) More than 50% of population living around the iodine plant site are not aware about radioactive pollution and potential danger to their health; (ii) one new IDP family moved into and settled in Surakhani lately; and (iii) no settlement is found close to the new polygon for radioactive waste disposal In order to increase the public awareness of the project, the MES will organize live TV dialogue on project impacts with the participation of representatives of civil society and directly address questions raised by viewers of the program.

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For the implementation of the project, the IDP/ refugee families in Surakhani will need to be relocated. The MES, together with the State Refugee Committee (SRC), has developed a Resettlement Action Plan (RAP) that lays out the relocation plan. The SRC is planning to build apartment buildings in and around Baku to accommodate IDPs in the Absheron areas, and the IDPs from Surakhani are expected to be housed in the new apartment buildings. However, it is expected that the construction of the apartment buildings will not complete before the beginning of the project. The IDPs will therefore be relocated to temporary residence, before they move to the new apartment buildings. The Resettlement Policy Framework5 (RPF) has also been developed to set out policies and procedures for the relocation of households in Surakhani and in other contaminated areas to be cleaned up in the subsequent phases of the project.

COMPLIANCE WITH APPLICABLE WORLD BANK SAFEGUARD POLICES A detailed Environmental Impact Assessment (EIA) including a proper Environmental Management Plan (EMP) was prepared for the investments financed under the project Component A and B, and discussed with the local public on two occasions. The EIA and EMP ensure that these investments will comply with the existing environmental laws and regulation in Azerbaijan as well as with the Bank’s Operation Policy on Environmental Assessment. The Resettlement Policy Framework has been developed together with a Resettlement Action Plan (RAP) for the relocation of the 13 IDP families in Surakhani. The RPF and RAP have been reviewed and found that they adequately meet the OP 4.12.

5 The RPF is disclosed separately and does not represent the subject of the current document

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ANNEX

ENVIRONMENTAL MANAGEMENT FRAMEWORK

FOR

REMEDIATION PROGRAM FOR NORM CONTAMINATED SITES AND THE 1000-HA SITE (PROJECT COMPONENTS C and D)

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MINISTRY OF EMERGENCY SITUATIONS

57 Tbilisi Avenue AZ1000, Baku

Republic of Azerbaijan

ABSHERON REHABILITATION PROGRAM

CONTAMINATED SITES REHABILITATION PROJECT

ENVIRONMENTAL MANAGEMENT FRAMEWORK

BAKU February 2008

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TABLE OF CONTENT

List of Abbreviations 3 List of Annexes 15 Chapter 1 INTRODUCTION 16

1.1. Background .................................................................................... 16 1.2. Project Environmental Assessment Category ................................ 17

Chapter 2 PROJECT DESCRIPTION 18

2.1. Project Components ....................................................................... 18 2.2. Brief Project Environmental Situation...........................................23

Chapter 3 Applicable Environmental Legislation and Policies 24 3.1. Overall relevant Azerbaijan legislation.......................................... 24 3.2. National Environmental Impact (EIA) policy and legislation ....... 26 3.3. Relevant World Bank Safeguard policies ...................................... 27

Chapter 4 Proposed Framework for EA guidelines and procedures related to remediation works under the Project (for the 1000 ha Site and future NORM cleanup sites) 30 Chapter 5 Institutional Arrangements for the EA process 31 Chapter 6 Public consultation and information disclosure 33

6.1. Procedures for public consultation on the sub-projects ................. 34 6.2. Procedures for public disclosure .................................................... 34

Annex 1 Background on environmental pollution at the “1000-ha Site” 35 Annex 2 Assessment of Azerbaijan’s EA/EIA Legislation and Practice 36 Annex 3 World Bank OP 4.01, Annex B - Content of an Environmental Assessment Report for a Category “A” Project 41 Annex 4 Environmental Management Plan (EMP) 42

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List of Abbreviations ARP Absheron Rehabilitation Project EA Environmental Assessment EIA Environmental Impact Assessment EMF Environmental Management Framework EMP Environmental Management Plan EREG Environmental Review Expert Group ESP Environmental State Program IAEA International Atomic Energy Agency IDP Internal Displaced People MENR Ministry of Ecology and Natural Resources MES Ministry of Emergency Situations NGO Non-Governmental Organization NORM Naturally Occurring Radioactive Materials OP/BP Operational Policies / Bank Procedures PIU Project Implementation Unit PMT Project Management Team RAP Resettlement Action Plan RPF Resettlement Action Plan SEE State Ecological Expertise TOR Terms of Reference WB World Bank

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List of Annexes Annex 1 Background on environmental pollution at the “1000-ha Site”

Annex 2 Assessment of Azerbaijan’s EA/EIA Legislation and Practice

Annex 3 World Bank OP4.01, Annex B – Content of and Environmental Assessment Report for a category “A” Project

Annex 4 Environmental Management Plan (EMP)

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Chapter 1 INTRODUCTION

1.1. Background Azerbaijan has a long history of oil exploration and production that has left the country with a massive legacy of oil and other chemical related pollution generating environmental degradation both land based and off shore. The Government of the Republic of Azerbaijan launched in 2006 a proactive approach to cleaning up the oil contaminated environment and reclaiming polluted land for development in the country, specially in the Absheron Peninsula, by establishing a comprehensive Environmental State Program (ESP) involving decontamination operations as well as advanced environmental management. The ESP intends to address both the legacy as well as the on-going environmental pollution from the oil production activities and its implementation involves key ministries and agencies in the country. The Government of Azerbaijan has requested the assistance of the World Bank in financing activities under the proposed Contamination Sites Rehabilitation Project (the Project) that will help rapidly the country towards achieving the ESP goals. The Project aims at declining the health risks and improving living standards of the families in the project area by reducing their exposure to air, land and water-pollution generated by potential radiation hazard from the low-level radioactive charcoal waste materials and other oil production pollution sources. Therefore, the Project intends to build capabilities and operations in high priority site clean-ups such as two former iodine production contaminated sites and 1000-ha oil polluted land in the Absheron peninsula through (i) full-scale site remediation including repackaging and transport of contaminated low-level radioactive waste and the disposal of this material at a newly built disposal facility; and (ii) removal of old oil production infrastructure and other types of waste, decontamination from oil spills, and oil processing equipment from the highest priority polluted sites. The Project will be wholly implemented by the Ministry of Emergency Situations (MES) through an established Project Working Group and will collaborate with the International Atomic Energy Agency’s (IAEA) who will offer advice and project oversight. The Project is part of the broader World Bank supported Absheron Rehabilitation Program (ARP) for cleaning up the environment in Azerbaijan. The program aims to steer implementation of the ESP towards a regional development approach to the rehabilitation of the Absheron Peninsula. It consists of multiple investment interventions selected from priority activities listed in the ESP and agreed with the concerned government agencies. The first stage of projects ready for implementation within this long-term collaboration program (ARP) focuses on (i) critical investments that will quickly tackle some of the worst environmental issues in Absheron and drastically improve living conditions for some of its residents, including informal settlers, and (ii) the development of environmental cleaning capacity. These first phase projects with a proposed implementation schedule during 2008-2013 are: (1) the Contaminated Sites Rehabilitation Project (the Project); (2) the Integrated Solid Waste Management Project;

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(3) the Large Scale Oil Polluted Land Clean-up Project, and (4) the Strengthening Environmental Policy and Enforcement for Environment State Program.

1.2. Project Environmental Assessment Category The proposed Contamination Sites Rehabilitation Project has been classified as environmental category “A” in accordance with the World Bank policy OP/BP 4.01 on Environmental Assessment given the envisaged NORM cleanup activities including safe disposal and storage as well as partial clean up of oil contaminated soils at high priority sites. The proposed project investments also trigger the Bank policy OP/BP4.12 on Involuntary Resettlement and the OP 17.50 on Disclosure Policy. In order to satisfactory complete the project preparation required for environmental category “A” Bank financed investments, MES agreed to prepare in due time6 the following documents: (i) full Environmental Impact Assessment (EIA) for the decontamination of the two former iodine production sites at Surakhani and Ramani including construction of proper NORM disposal facility; (ii) an Environmental Management Framework (EMF) for the naturally occurring radioactive materials (NORM) decontamination works of the highest priority oil production sites as identified in the National Remediation Mitigation Program and for the cleanup works proposed at the 1000ha oil polluted site7 ; (iii) a Resettlement Policy Framework (RPF) that sets out policies and procedures to be followed for any displacement of people as a result of project implementation; and (iv) a draft Resettlement Action Plan (RAP) for the IDP families living on the Surakhany site of the former iodine plant. The EA, EMF, RPF and RAP are designed to facilitate Project implementation and to ensure compliance with Azerbaijan's legislation, procedures and policies, international Conventions and WB safeguard policies, in particular in terms of environment and resettlement. The EA for the iodine sites decontamination includes a broad overview of the policy, environment and socio-economic implication of the cleanup operations, possible long-term environmental impacts (e.g., on land-use and land resources) that may arise during the operation of a proposed waste disposal facility to receive the charcoal waste, and recommends the implementation of a mitigation plan to avoid possible impacts during constructions and of a comprehensive environmental monitoring program during the proposed cleanup operations. The EMF, RPF and RAP documents outline the procedures for the management of environmental and social issues of the project to be followed during the project implementation. When the situation exists that details of sub-projects to be financed are unclear at the time of project appraisal, Frameworks are developed to ensure compliance with national laws and bank policies. The final safeguards documents will be disclosed in country in the local language and at the InfoShop in Washington, DC in English prior to project appraisal. Appropriate and specific EIAs, EMPs and RAPs will be prepared during project implementation for the cleanup of 1000ha site and the highest priority NORM sites in line with the requirements of the project EMF and RPF and with adequate public participation and disclosure.

6 120 days before the project Board date planned on June 12, 2008. 7 Specific investments for these cleanup sites will be known during project implementation once the requested technical studies are developed.

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The present Environmental Management Framework document has been prepared by MES to ensure that the proposed cleanup works at the 1000 ha site and other NORM identified sites meet the national environmental requirements in addition to the WB safeguard policy on environmental assessment. The EMF provides guidanceon the process of proper project implementation including preventing, minimizing or mitigating site-specific environmental impacts possible during the cleanup works. The objectives and content of the EMF is described in general below and in detail in the attached annexes.

Chapter 2 PROJECT DESCRIPTION The goal of the Project is to assist the MES to efficiently identify and implement cleanup and remediation operations in high priority sites that are contaminated as a consequence of oil production processes and related activities in the Absheron peninsula. Specifically, the project will target as top priority the cleanup of the two former iodine production site in Greater Baku (Suraxani and Ramani sites) that are contaminated with NORM and the remediation of the “1000ha site” located north of Baku’s international airport as well as other “hot-spots” contaminated with NORM as identified in the National Remediation Mitigation Program. The Project also intends to build local capacity in proper cleanup operations of high priority sites and preparation for site re-development, including tools such as national mapping of NORM contaminating sites and technical assistance for proper project monitoring.

Project Components The project will finance activities under the following components.

Component A - Clean-up and rehabilitation of two former Iodine Sites This component will develop immediate cleanup activities for the decontamination of the two former iodine production sites in Surakhani and Ramani (Figure 1a and 1b). The contamination of the site includes radioactive materials and other heavy metals, polluted soil, and old production facilities that contain oily products, which present serious health exposure to the increasingly dense housing development surrounding the sites. Specific activities implemented under this component include: (i) development of a Temporary Safety Plan to minimize exposure of the public to hazardous materials on the site through fencing, supervision etc. for the period between the start of the project and the commencement of the decontamination works, (ii) the preparation of detailed site investigations, detailed design of works and project supervision requirements, (iii) the removal, packaging and safe transport of radiological waste to a dedicated NORM disposal facility to be constructed under Component B of the Project, (iv) the removal and disposal of other hazardous materials present at the site to the existing hazardous waste sanitary landfill, (v) the clean-up of oil contamination and contaminated water reservoirs on the sites; and (vi) the demolition of contaminated buildings and the preparation of the site for re-development. The activities under this component are considered to have high risk impact on the environment and fall under environmental

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categories A as per Bank policies. A detailed EIA has been prepared by MES to address the possible environmental impacts related to the project cleanup works that follow best international practices, the Bank’s standards and the local environmental, health and safety guidelines. Activities under Component A are not further discussed in the present EMF. Figure 1a. Situation map of Ramani site.

Figure 1b. Situation map of Surakhani site

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Component B - Construction of a dedicated NORM storage facility This component will finance the development and construction of a dedicated facility for the storage of radioactive waste from the two former iodine sites to be decontaminated under Component A and of NORM from other site clean-ups such as former oil production sites. Activities include detailed site investigations, the detailed design of the facility, construction works and operations to receive the NORM from the former iodine sites. Future (post-project) operations and monitoring will be managed by Izotop under supervision of MES. This component involves category “A” type activities which are also captured in the detailed EIA prepared by MES for component A and therefore are not further discussed in the present EMF.

Component C - National Mapping and Remediation Program for NORM Contaminated Sites The following activities are foreseen under this component: (i) development of a comprehensive radiological monitoring program to assess the current radioactive contamination situation in the country, including Baku and the Absheron Peninsula and specific areas in the Caspian Sea; (ii) development of a national map, showing the distribution of surface radioactivity, as well as radionuclide inventory, activity levels, and potential radiation hazard; (iii) development of a national remediation program, with prioritization and budgets for the various contaminated areas; (iv) the remediation of the first highest priority oil production sites with NORM contamination totaling US$ 5.0 million as identified in the National Remediation Mitigation Program for NORM Contaminated Sites; (v) establishment of an integrated program to perform continuous national radiological monitoring of the existing NORM contaminated areas including a radiation emergency and response plan for these areas. The envisaged remediation works at the first hot-spots sites identified during the Project implementation are considered environmental assessment category “A” and are further captured in this EMF. Site-specific EIAs with EMPs will be developed in accordance with the EMF once the site location and specific cleanup works are known. Component D - Remediation Program for the 1,000ha Site This component will finance the first-stage approach (e.g., priority cleanup activities) of the remediation and rehabilitation program for about 1,000 hectares of oil polluted land resulted from intensive and long-lasting oil exploitation activities and located between the Buzovni and Mashtagi settlements (Figure 2). Specific activities will include: (i) development of a comprehensive site investigation (including environmental investigations and radiological scan) as the basis for a detailed clean-up and rehabilitation program for the area; (ii) removal of old oil production structures and infrastructure; (iii) adequate closure of non-functional oil production wells; (iv) clean-up of oil contaminated spots; (v) removal of other types of hazardous waste, and (vi) re-development plan for future land-use purposes. The remediation and rehabilitation program will also have to deal with the few wells that could remain in production for the coming years and the

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encroachments of residential areas onto the site that are already visible and they affect the remediation works. The specific activities financed by this component will be finalized during the project implementation. They are classified as category “A” based on OP/BP 4.01 and the overall process for assessing and managing environmental impacts during the cleanup works are presented in this EMF. A Resettlement Policy Framework (RPF) has been prepared by MES to set out policies and procedures for the displacement of households from the 1000-ha site in case remediation works would require so.

Figure 2. Situation map of 1000 ha site

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Component E - Technical Assistance and Project Management

This component will provide financial support for the management and performance monitoring of the Project as well as for technical assistance towards institutional development, strategy development and planning. The implementation of technical assistance activities will be closely coordinate with IAEA’s technical cooperation program (Monitoring and Rehabilitation Programs for Contaminated Areas of the Absheron Peninsula). The activities under this component are not expected to have negative impact on the environment and will not fall under environmental category “A” as per Bank policies. The location of the overall project site is presented in Figure 3. Figure 3. Location of the overall project site

The project is expected to have important and positive environmental impacts on the Absheron Peninsula that will lead to reducing public health risks and environmental damage caused by inappropriate management of the site’s legacy waste from years of oil production activities in the project area. The environmental impacts of the investments are mainly related to the execution of specific cleanup works and possibly during the transport of hazardous waste and may include: short-term effects on air quality, surface waters and soil such as dust, noise, air emissions, wastewater disposal on the construction site, accidental spillage of equipment oil. One potential long-term impact of the project could be the redevelopment of the land for purposes that are not compatible with the level of cleanup achieved during the project implementation, potentially triggering a health hazard. This risk will be mitigated through the development and implementation under the Project of cleanup standards suitable for commercial land or housing development.

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Other long-term impacts such as effects on groundwater and soil could be envisaged in relation with the NORM disposal facility during its operation once the facility starts to receive the waste. To avoid such impacts, the operator will be instructed to perform regular monitoring of the facility in accordance with a comprehensive monitoring system for supervision and control of groundwater and soil quality. Occupational health and safety issues for the workers and near site community during the remediation works will be followed according to international standards to prevent exposure to spills, gas emissions and fires or explosions that could be directly associated with these works. The above risks can be addressed by direct mitigation activities in the design, planning and supervision of the cleanup works intended to prevent and avoid further soil and groundwater contamination. An EMP that covers typical mitigation approaches to cleanup civil works contracts with localized impacts and related monitoring actions that are compatible to the Bank safeguard requirements will be developed before works commencement and incorporated in bidding documents as an integral part of contract documents for the respective remediation works. For the remediation of the hot spots NORM sites specific attention will be given to the technical requirements and restrictions imposed through logistical challenges of working in an oil-polluted radioactively contaminated environment while ensuring effective remediation within the applicable regulatory framework.

2.2. Brief Project Environmental Situation The Absheron peninsula is heavily polluted due to nearly 150 years of oil production that has left some 20,000 hectares of oil-contaminated land. Much of the peninsula looks like a wasteland, covered with standing oil ponds, high concentration of sulfurous reside, and a shoreline painted by the oily tides. Much of this is also attributed to old and outdated drilling equipment. The Caspian Sea has also been affected due to poor oil extraction practices that result in significant quantities of contaminated water being discharged into the sea. Along with the rusty platforms and pools of oil crust, one can see well fires burning for years releasing toxins into the air. Oil production on the peninsula has also generated radioactive waste (from natural radio-nuclides). Cleaning up already polluted land, as well as reducing on-going pollution from oil-production and other human activities by conforming to good international environmental and safety practice, are key priorities of the Government of Azerbaijan through initiation of the Environmental State Program (ESP). Land contaminated with radioactive nuclides of a natural origin, creating in a number of places a high level of ionizing radiation represents the greatest danger on the territory of Absheron peninsula. There are plots on the territories of fields and old derelict lands with radiation parameter from 120 to 2000 and more micro-Roentgen/hour while normal average level is from 6 to 10 micro-Roentgen/hours. Large accumulation of radioactive nuclides is concentrated in old pipelines for water production, in which salts formed on the pipe wall may radiate up to 2000 micro-Roentgen/hour and more, as well as in oil-gathering stations; in other parts radiation is 10-50 micro-Roentgen/hour. Preliminary evaluation of the contaminated soils and ground waters in the 1000 ha site area demonstrates that up to 30% of the area is contaminated with oil and oil products up

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to the average depth of 1.0 m, and in the other areas (sludge tanks, former oil warehouses) up to 1.5-3.0 meters. It is therefore expected a total volume of contaminated soils reaches 3.0-3.5 million m3 or 5.25-6.1 million tons, and contamination level varies from 1-2% up to 20-30%, far going beyond last indicator in the sludge tanks and warehouses. More information on the level of pollution currently known at the “1000-ha site” is presented in Annex 1.

The territories polluted with oil in the project area may include: (i) open oil warehouses – locations where oil extracted from oil-wells used to be delivered in areas that had 100-10,000 m2 covered with ground walls from where oil was transported for refining; (ii) oil residues-soil mixture transported and collected in temporary territories; (iii) buried drilling mud and buried oil contaminated lands (the 1000 ha site); (iv) pollution emerged as a result of accident occurred during oil transfer pipes in oil-field areas; (v) existing lakes emerged during water flows as a result of leakage from injection wells; and (vi) pollution of neighboring areas by oil combinations brought by ground waters and atmosphere. Sources of pollution include not only field waters, but also technological waters flown from processing plants.

The project area will be subject to an intensive site characterization based on which extension and depth of pollution will be developed together with appropriate remediation methodologies that will allow ultimate cleanup and land reclamation.

Chapter 3 Applicable Environmental Legislation and Policies

3.1. Overall relevant Azerbaijan legislation The most relevant Azerbaijan environmental sector and health safety related regulations applicable to the proposed Project are the following: 1) The Law on Environment Protection (1999) establishes the main environmental protection principles, and the rights and obligations of the State, public associations and citizens regarding environmental protection. It also establishes the principles and requirements for the preparation of the State Ecological Expertise (SEE) which is the official EIA procedure in Azerbaijan. The Law states the basics of SEE in Azerbaijan as a process of “identification of the environment’s correspondence with the quality norms and ecological requirements aimed at revelation, prevention, and prediction of possible negative impacts of economic activities on the environment and related consequences” (Article 50). Such definition presents a technocratic approach to environmental issues, whereby the legislation provides the economic activities with certain limits for using natural resources rather than mechanisms to achieve minimal environmental impacts through preventive and mitigation measures. The other key document forming the legal basis for EIA is the Handbook on the Process of Environmental Impact Assessment in Azerbaijan (1996) on which more detailed information are presented in the following sub-chapter. 2) The Environmental Safety Law (1999) indicates that land users are responsible for rehabilitation of damaged soil and other natural resources for their subsequent use.

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Specifically, the law prohibits import of radioactive wastes, processed re-usable nuclear fuel, other radioactive substances and nuclear materials. 3) The Law on Radiological Safety of Population (1997) calls for ensuring radiation safety in industrial entities during operation. The Law also establishes main principles of government policy on meeting radiation safety requirements, as well as environmental norms providing safety of employees and population in areas affected by use of radioactive sources. The Law provides for compensation which can be claimed by population for damage to their health, property and life during accidents. 4) The Law on Sanitary and Epidemiological Safety (1992) establishes rights and obligation of citizens and national monitoring institutions in provision of sanitary and epidemiological safety; basic principles of establishing sanitary-hygienic norms and standards; sanitary and epidemiological requirements for industrial entities, to be met at design, construction and operation stage, and for other economic activities. According to Article 39 of this Law, and Criminal Code of Azerbaijan Republic, violating sanitary-hygienic norms and rules causes criminal responsibility. 5) The Law on Protection of Atmospheric Air (2001) establishes norms for mitigating physical and chemical impacts to atmosphere, as well as provides for legal basis for state registration of negative impacts on atmosphere, for control over air protection, solving disputes emerging due to pollution of atmosphere. 6) The Land Code (1999) sets mandatory requirements for remediation of all soils after their use, including soils where mining works have been conducted. 7) The Soil Fertility Law (2000) sets up requirements for land owners, leasers and land users to protect fertile top layer of soils during any construction activities. The Law fixes specific time frame for restoration soil fertility as 3, 3.5 and 5 years based on specific soil characteristics. 8) The Law on Industrial and Domestic Wastes (1998) determines main principles of the state policy in solid waste management; obligations of the state authorities responsible for solid waste management, including allocation of plots for waste processing and disposal, coordination of waste recycling activities, setting rules for trans-boundary transportation of wastes, licensing of waste generating activities etc.; and also describes property rights. The Law specifies requirements for design, construction and reconstruction activities, for waste collection, transportation and disposal (prohibited within residential city areas and other residential settlements, in resorts, forest and recreational zones, in the areas where underground and potable water is available and in the zones of mining activities), for waste processing sites (shall be properly equipped with waste processing tanks, signage and control access points shall be available). The Law also encourages introduction of technologies for minimization of waste generation by industrial enterprises. The Law envisages both state and community (public) control over the waste generating activities and waste management, and imposes payments for collection, disposal, use and processing of wastes.

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9) The Law on Public Health (1999) sets out basic principles for public health protection and the health care system. The Law also assigns liability for harmful impact on public health, stipulating that damage to health resulting from polluted environment shall be compensated by the entity or person that caused the damage.

In addition, a large number (some 75+) of Decisions of the Cabinet of Ministers have been issued to help interpret the body of environmental legislation and related Presidential Degrees and Orders. Furthermore, Azerbaijan is a party to several international conventions regulating the EIA process and waste management issues including: (i) the Aarhus Convention on Access to Information, Public Participation in Decision-Making, and Access to Justice in Environmental Matters; (ii) the Espoo Convention on EIA in Trans-boundary context; and (iii) the Basel Convention on Hazardous Wastes Transportation.

3.2. National Environmental Impact (EIA) policy and legislation The current EIA system in Azerbaijan is rooted in the old Soviet central planning system and largely follows the procedure of State Ecological Expertise (SEE) adopted by the former Soviet Union in the late 1980s. Unlike EIA, and in line with the definitions of SEE in the Law on Environmental Protection (EP), the core purpose of the SEE system lies in the formal verification by state authorities of all submitted developments for their possible environmental impacts, regardless of their scale, sector type or nature. The Law on EP states that SEE is the official EIA procedure in Azerbaijan, but it is not a specific EIA related legislative document. According to Article 54.2 of the Law, EIAs are subject to SEE which means that the environmental authority - Ministry of Ecology and Natural Resources (MENR) - is responsible for the review and approval of EIA reports submitted by developers. The Law on EP establishes the basis for the SEE procedure, which can be seen as a stand-alone check of compliance of the proposed activity with the relevant environmental standards (e.g. for pollution levels and discharges, noise). In addition, the Law on EP determines that projects cannot be approved without a positive SEE resolution. The basic procedures for the conduct of EIA are laid down in the 1996 Handbook on the EIA Process in Azerbaijan. Although these provisions are not technically legally binding, compliance with them is to all intents and purposes regarded as mandatory. The EIA Handbook introduces the main principles of the ‘western’-type EIA process to the country, and details (i) the EIA process, i.e., the sequence of events, roles and responsibilities of applicants and Government institutions, charges; (ii) the purpose and scope of the EIA document; (iii) public participation in the process; (environmental impact review); and (v) environmental review decision. It defines EIA as a process aimed at identification of, evaluation of, mitigation of, or avoiding, possible negative impacts of development proposals, but also mentions principles of integrated approach of such assessment. It is acknowledged to introduce transparency in the process of decision-making through involving the interested public in the discussion of the proposed activities and taking the public opinion into account (Paragraph 1.1.) The EIA definition also suggests that not only should the developer design their proposals in a way least

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harmful for the environment, but they also should consider certain activities under each proposal to eliminate or minimize its possible negative impacts. The EIA Handbook also outlines the main parties to the EIA process, which are the Developer, the Environmental Authority (MENR), the Experts and the Public. The Developer is responsible for preparation of all EA related documentation, and for further implementation of proposed mitigation measures. The MENR has to review the documentation submitted by the Developer, and make a decision on issuing environmental Permission. The Experts are involved in analyzing all applications and drawing their conclusions on the proposed activities. The Public is expected to provide its feedback to the proposed activities through various types of public involvement techniques. The EIA principles outlined by the Azerbaijan’s legislation is in general consistent with international principles, calling for transparency, integration of environmental, social, engineering, economic and other assessments. In terms of timeframes, the EIA Handbook provides for one month for the Environmental Authority to make a decision on EIA scope, and for 12 months for the Developer to submit EIA after the Environmental Permission is issued by the Environmental Authority. Not all EIA stages are adequately covered by the local legislation. A distinctive screening list with activities that are likely to cause significant environmental impact is not established either by the Law on EP nor by the EIA Handbook. Consideration of alternatives is not explicitly required by any of the two basic legal EA documents. However, in practice most of the developers, in an effort to meet requirements of international donors and achieve higher environmental performance do cover alternatives and their impacts in their EIAs. On the other hand, the reporting requirements are specified in detail in the EIA Handbook. In relation to public participation, the Law on EP and the EIA Handbook do not contain clear regulations/procedures on public participation and the access for the public to the relevant information and thus do not meet international requirements for public participation at the present time. Public participation is mainly understood as public access to EIA documentation, but has no role in the decision-making process. Public consultation requirements for this Project are outlined in Chapter 6. Monitoring and post-project analysis are among the weak aspects of Azerbaijani EIA system, covered only by rather vague requirements of the Law and Handbook for monitoring and audit of economic activities. This can partially be explained by the lack of adequate mechanisms of monitoring and up-to-date system of internationally applied indicators. Annex 2 provides the description of Azerbaijan’s EIA procedure in more details, including the identification of the investor’s and relevant authorities’ obligation. This procedure will be mandatory for the cleanup investments under the proposed Project.

3.3. Relevant World Bank Safeguard policies

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The World Bank undertakes environmental screening of each proposed project to determine the appropriate extent and type of EA. The Environmental Assessment is defined through Operational policies OP 4.01. The Bank classifies all proposed projects into one of four categories8, depending on the type, location, sensitivity, and scale of the project and the nature and magnitude of its potential environmental impacts. In accordance with the OP/BP 4.01, the proposed Project has been classified as environmental category “A”. A proposed project is classified as Category A in accordance with the OP 4.01 if it is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. The EA for a Category A project examines the project’s potential negative and positive environmental impacts, compares them with those of feasible alternatives (including the “without project” situation), and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance (Annex 3). Furthermore, for the Category “A” projects, an Environmental Management Plan (EMP) needs to be prepared in accordance with the Bank's OP 4.01. The specific requirements relating to EMPs are set out in Annex C to WB's procedure 4.01 (BP 4.01) - which is mandatory (Annex 4). Furthermore, for Category “A” projects, the borrower should consult with project affected groups at least twice during the project preparation: (i) the first consultation takes place shortly after screening and before the TOR for the EIA are finalized, involving discussion on issues to be addressed in the EIA; (ii) the second consultation takes place once a draft EIA is prepared, involving discussion of issues raised in the EIA. In addition, the borrower consults with such groups throughout project implementation as necessary to address EIA related issues that affect them. For the proposed Contaminated Sites Rehabilitation Project, the relevant safeguard policies to be considered at all stages of project preparation and implementation are: (i) the OP/BP 4.01 on Environmental Assessment; the OP/BP 4.12 on Involuntary Resettlement, and (iii) the OP 17.5 on Public Disclosure.

The WB OB/BP on Involuntary Resettlement requires WB-assisted projects to avoid or minimize involuntary land taking. If such cannot be avoided, displaced persons need to be meaningfully consulted, compensated for lost/damaged assets and assisted in restoring or improving their living standards and livelihood. The policy requires that if involuntary land taking and resettlement become necessary, a clear plan for compensating and assisting displaced persons be prepared by the borrower by appraisal for WB review. Such a plan must be substantially completed prior to the commencement of civil works. An Involuntary Resettlement Policy Framework and a draft Resettlement Action Plan have been prepared for the proposed Project and are the subject of discussion in separate documents.

8 The four environmental categories are: category A; B; C or FI, on which detailed explanations can be found in the OP/BP 4.01.

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The WB policy on Public Disclosure follows specific procedures according to which the Borrower (i.e. the MES) will have to make the draft EIA Report, EMF, RPF and RAP documents available in Azerbaijan at a public place accessible to project-affected groups, different stakeholders and local NGOs. The Borrower must also officially transmit these documents to WB. Once the reports have been locally disclosed and officially received and approved by WB, the WB will also make them available to the public through its Infoshop.

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Chapter 4 Proposed Framework for EA guidelines and procedures related to remediation works under the Project (for the 1000 ha Site and future NORM cleanup sites) The sub-projects including investments related to the decontamination of 1000 ha site and the future NORM priority hot-spots identified by the National Remediation Mitigation Program and financed under the proposed Project will have to conform to current Azeri environmental laws and comply with international requirements and the regulations and the procedures of the WB’s safeguard policies, including Environmental Assessment (EA) policy outlined in Operational Policy 4.01 and the Involuntary Resettlement (OP 4.12). Although the finalization of all technical details (e.g., proper site characterization, feasibility studies, EIA, detail design) related to these specific investments will be done during the project implementation, the environmental risks associated with the proposed cleanup works classify these investments as environmental assessment category “A” per Bank policies. Table 1 summarizes the approach to be completed by the Borrower (MES and PIU) to streamline the EA process applicable to the above investments, which meet both the Bank and the local environmental assessment requirements. Table 1 Management of the EIA process for proposed 1000ha site and other NORM cleanup site sub-projects Steps of EIA process Procedures to be followed by MES

based on the Azeri EIA legislation9 and on the WB OP 4.01 Sub-Project Preparation Stage Screening and scoping of sub-projects (approx. 1 month) (Category A based on OP 4.01)

• MES submits an application (e.g., project brief) including draft ToR for EIA report to MENR with copy to WB;

• Decision on EIA to be conducted and notification of MES on the scope and depth of the study by MENR;

• Public disclosure and consultation prior finalizing draft ToR on the scope of the subproject;

• Finalization of draft ToR by MES including any comments received from MENR and WB

Sub-project EIA Study Preparation, Review and Disclosure Stage EIA report preparation including EMP and its dissemination

• Prepare EIA study with EMP based on the ToR before sub-project appraisal as described in Annex 2 and Annex 3;

• Submit draft EIA report with EMP to WB for review and clearance to disclose it in country for 2nd public meeting;

• Submit draft EIA report with EMP to MENR review for SEE; • Carry out 2nd public consultation in country on the draft EIA

and EMP; disclose the draft documents in local language and to Infoshop;

• Prepare final draft EIA including MENR,WB and public comments;

• Prepare Executive Summary of the final draft EIA; • MENR issue the SEE (approval of the project); • Submit officially final EIA report to WB for “no objection”

Sub-project Implementation and Monitoring Stage Implementation of the EMP • MES/PIU supervise works in accordance with EMP and

submits progress reports to WB and MENR

9 EIA procedure according to “Handbook of the EIA process in Azerbaijan”, 1996

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Chapter 5 Institutional Arrangements for the EA process Overall, the proposed subprojects will be subject of national and WB environmental procedures including: (i) subproject screening and environmental classification (confirmed as Category “A”); (ii) application of good practice environmental and social guidelines; (iii) implementation of required environmental work; and (iv) monitoring and supervision of subprojects. The MES (the Working Group assigned for the Project) via PMT will be responsible to prepare and implement the proposed sub-projects while ensuring that the required environmental procedures outlined in Table 1 are followed. In the event of any work deviations or unreasonable delays the MES will seek the advice of the relevant parties and provide any necessary support and advice to overcome the problems. The PMT will be in charge of overall project management and to ensure proper preparation and implementation of the project-specific EIAs and the related EMPs. At the national level, the key environmental institution in Azerbaijan is the MENR which divides his activities in several areas such as environmental policy development; environmental protection; water monitoring and management; protection of marine (Caspian Sea) bio-resources; and bio-resources and protected areas management. At the level of MENR, the State Ecological Expertise (SEE) Department is the body responsible for carrying out SEE and making decisions on environmental soundness of development activities through issuing environmental permits. The SEE will also be responsible for liaison with the relevant ministries and agencies regarding environmental approvals. During construction and operation, the MES via PMT and the Regional Monitoring Departments of the MENR will be responsible for the supervision and enforcement of environmental management plans (EMP) and carrying out routine monitoring during the operational phase of the projects. Construction contractors will be responsible for implementing the EMPs that are developed for subprojects during the construction phase. The EMP should be part of the bidding documents for the cleanup works and costs of EMP implementation should be envisaged in technical specifications. A brief overview of the main institutional arrangements in the EA process in Azerbaijan including supervision and enforcement of EMPs is presented in Annex 2.

The EA process for the proposed sub-projects outlined in Table 1 and the institutions responsible for its implementation are described in detail below: Sub-project screening – before the ToR for the EIA consultancy services on sub-projects is established, for each sub-project, the MES will prepare a sub-project brief (official application) in accordance to the EIA Handbook to the MENR for their review and assessment (including scoping). For this purpose, the MES will carry-out the preliminary screening of the subproject and identify the environmental classification (in this case, confirmation of Category A as per OP 4.01). Based on the completed

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information, the MENR (SEE) has one month to examine the application, screen the proposed subproject for its potential environmental and social impacts in compliance with national laws and norms, consult with experts and the public, provide comments to final ToR and inform the MES of the scope and depth of the EIA study. During this time, prior finalization of the ToR, the MES will organize a first public meeting on the draft ToR in accordance with OP 4.01. Any comments received during the public meeting will be incorporated in the final draft ToR. Once the decision is given by MENR, the borrower (MES) will finalize the ToR, receive clearance on ToR from WB and engage the consultants to prepare the draft EIA and EMP. Subproject EIA Study preparation: According to the MENR screening decision on the type of EIA, the MES will proceed as indicated in Table 1 (developing an EIA with EMP as in Annexes 2 and 3 and organizing a 2nd public consultation on the draft EIA). For preparation of category “A” project EIA studies, MES will hire registered EIA specialists in accordance with the requirements of the Azerbaijan legislation who are not affiliated with the Project. Once the draft EIA is prepared, the MES will send it for review before the 2nd public consultation to the WB and MENR. MENR has 3 months to complete the review before providing its decision. The MES will notify in the mass media the affected parties for the public consultation of the EIA report in due time before the hearing. Furthermore, the MES will submit to the MENR a review of the draft EIA report including the outcomes of the public hearing. The environmental review expert group will meet to decide on the results of the EIA report and will prepare the draft decision of approval or refusal of the sub-project. Finally, the MENR will decide on the approval or rejection of the sub-project based on a written explanation. MES will perform an overall quality assurance that the documents prepared meet the World Bank and Azerbaijan environmental legal requirements. The WB will provide no objection to the consultation result and final EIA as well as to the final EMP. Overall Project Implementation and Monitoring: The MENR is responsible for the management of environment and the state control of ecological safety. MENR through its department of Environmental Policy and Environment Protection will perform inspection visits during the cleanup works in parallel or in coordination with those performed by the State Control Inspectorate for Environment and Natural Resources (centralized) to ensure compliance with local environmental standards and regulation. The MES in cooperation with PMT will have overall responsibility for ensuring implementation and monitoring of the EMP for each subproject. However, the various parties identified in the EMP (contractors, construction supervisors, supervisor engineers) are immediately responsible for implementing and monitoring their own activities in accordance with the current local construction standards. MES will designate within the PMT a specialist responsible for the environmental compliance with related EA and EMP requirements of the cleanup investments proposed at the 1000 ha site and the other NORM sites. MES, through its designated specialist, will monitor the implementation of the EMPs based on unannounced supervision visits at the sub-project sites during the cleanup works. During such visits, MES will be responsible

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for observing the compliance with all environmental aspects at the site as stipulated in the Contractor’s ToR and as highlighted in the EMP mitigation and monitoring plans (including verification of all environmental permits requested for the Contractor on the site). The MES and local authorities where the sub-projects will be carried out will ensure that the following are carried out in a proper manner: (i) supervision on the potential environmental impacts during works including construction noise, air quality, water quality, etc.; (ii) supervision on the compliance with contractor’s performance of works without disruption of regular traffic; (iii) ensuring that the contractor understands and follows its obligations on overall maintenance of the construction site related to environmental protection measures; (iv) ensuring that a work and occupational health safety plan is on the site (during work performance) along with valid environmental permits and related documents for proper implementation of works; (v) supervision of proper removal of construction waste to the dump site according to local regulations; (vi) monitoring of mitigation measures of environmental pollution impacts at the construction site (e.g., construction noise; brief assessment of short-term impacts during constructions on surface waters, etc.). At present, practical experience in the implementation and management of EMPs in the country appears to be weak and skilled technical staff is not available at either central or the local level, where EMP implementation will have to be monitored. Institutional strengthening for EMP supervision and enforcement will be provided under the Project through regular training focusing on practical aspects of environmental monitoring and mitigation during the project preparation and implementation stages. In addition, an Expert Panel Group will be established through the project to guide and oversee implementation of the sub-project’s radioactive cleanup activities in accordance with the International Atomic Energy Agency’s (IAEA) safety standards. The World Bank will supervise the project preparation, implementation, and safeguard compliance on regular basis and conduct site visits, and review the subprojects EMPs and EIAs. Regular supervision will as well include continuous monitoring of environmental compliance with EA and EMP. Reports will be prepared on each of the environmental supervisions, specifying mitigation measures and assigning responsibilities for implementation. The findings and recommendations of the reports will be discussed, as appropriate, with organizations and neighbors concerned. In the semi-annual reports that MES will submit to the Bank, it would provide information on the environmental compliance of the Project, taking into account Bank and local procedures, highlighting environmental issues arising from the project supported activities, the status of mitigation measures and next steps.

Chapter 6 Public consultation and information disclosure The current EMF, presenting a guidance tool to ensure that the proposed sub-projects funding the decontamination of the1000ha site and future NORM cleanup sites comply with the existing environmental regulations and standards in Azerbaijan as well as with the World Bank’s Safeguards Policies, was publicly disclosed on February 7, 2008 during a second public meeting organized by MES for the overall proposed Project. Several

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other project relevant safeguard documents were disclosed and discussed during this meeting including the draft EIA for the decontamination of two iodine sites, the RPF and RAF for the 1000ha site and future NORM cleanup sites. Minutes of the meeting and comments received from the public were incorporated in the final draft EIA and disclosed further in country and at the WB Infoshop.

6.1. Procedures for public consultation on the sub-projects For projects falling into WB Category A projects, MES will consult the project affected groups and local NGOs about the project’s environmental aspects and take their views into account at least twice during the sub-project preparation: (i) during preparation of the project brief, before the ToR for the EIA are finalized; and b) after the draft EIA with EMP is prepared. For meaningful consultations, MES will provide relevant information to the public in an appropriate form and language, and in timely manner. The minutes of public meetings will be recorded and included in the final EIAs with EMPs.

6.2. Procedures for public disclosure For Category “A” sub-projects, MES will ensure that the findings of the EIAs and EMPs are accessible to the public affected by sub-project and NGOs in local language. Also, MES will ensure that the EIAs and EMPs are officially submitted to WB in English for review and clearance. WB will disclose the drafts and final EIAs (with respective EMPs) and the affiliated Executive Summaries in the Infoshop for overall public review.

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Annex 1

Background on environmental pollution at the “1000-ha Site” Intensive contamination of equipment, pipelines, reservoirs and the surrounding environment occurs during the production, processing, transportation and preservation of oil and oil products. A large amount of contaminated equipment (pipes, pumps, oil reservoirs, etc.) with long term radioactive background “crusts” was discovered in the area of the oil fields all over across the Absheron peninsula. One of such areas is situated in the peninsula’s northeast between the densely populated villages of Mashtaga and Buzovna totaling about 1000 ha. The site (proposed for remediation under World Bank financed investments) stretches along the main road that connects the two villages. The oil production activities have ceased almost completely in this area and most of the equipment used has been dissembled and left at the site exposing the surroundings to hazardous impacts due to long term oil leakages. This represents a high risk also because sometimes this equipment is recycled or simply used by local inhabitants especially for the construction of buildings. Soil contamination in the area is defined by long term presence of oily hydrocarbons, radioactive materials and oil slimes, bitumen formed at the surface due to exposure of fuels under the climatic conditions, contamination by debris, metallic materials and different municipal waste. Such contamination derived mainly from: (i) former oil swamps created to contain extracted oil before its further transportation to the refineries currently transformed in pits full of bitumen or covered with soil; (ii) uncovered disposal of oil-contaminated soil collected from over contaminated areas or abandoned oil swamps; (iii) drill cuttings; (iv) oil leakages from oil transported through pipes, and (v) artificial lakes formed by the oil water production, some of which dried out while considerate contamination of radio-nuclides (e.g., radium and uranium) remained accumulated in nearby sediments. A preliminary site characterization of soils and groundwater demonstrated that 30% of the proposed project area is contaminated by oil and oil products, with a soil contamination depth ranging between 1.0 - 3.0 m below the ground level. The volume of contaminated soil is estimated at about 3.0-3.5 million m3 (5.25-6.1 million tons) with the pollution level ranging from 1-2% to 20-30%. According to drilling data performed in 2006, the ground water level at the 1000-ha site varies between 1.5 and 2.0 m. It is important to note that earlier data from 1970 showed that the ground water level used to be at a 5 m depth. The increase of the groundwater level is believed to be attributed mainly to the flooding of North-Eastern Absheron as a result of water leakage from the Samur-Absheron canal and of the infiltrations from the irrigation water practices and sewage from neighboring settlements. Data confirmed that the chemical composition of the area’s ground waters include hydrocarbons.

The site is characterized by soils of sandy to silt texture with semi-desert vegetation growing randomly. The geological structure of the site reveals sandy loams layers bedded by rocks and limestone in the first 2 meters followed by sub-layers composed of

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limestone, sands, sandstones and clays. The oil exploration depth in the area reached 1300 m.

Annex 2

Assessment of Azerbaijan’s EA/EIA Legislation and Practice10

1. The parties to the EIA process The Azeri EA system is based mainly on two documents: the Law on Environmental Protection (EP) (1999) and the non-binding EIA Handbook (1996). The main parties to the EIA in Azerbaijan, outlines in the EIA Handbook, are the Developer, the Environmental Authorities, the Experts and the Public. Of these, the Developer is responsible for the completion and submission of the Application for the Environmental Permission (hereinafter ‘Application’) and all; the related fees, for undertaking and EIA and public consultations and for the subsequent documenting of both processes; and for the compliance of the proposed activity to the conditions of approval during the whole project life-cycle The main responsibilities of the Environmental Authority include reviewing Applications; consultations with Experts; making initial public enquiries; informing the Developer of the required depth of the EIA process; appointment of the date for the Scoping Meeting; setting the Environmental Review Expert Group (EREG) for consideration of the EIA Document and announcing the results to the public; attaching any necessary environmental performance-related conditions to the Environmental Permission; and processing the relevant monitoring and audit information The Experts, comprising the EREG, are responsible for undertaking EIA process according to the field of their expertise, analyzing all Applications and comments received from the public, as well as for drawing its own conclusions on the proposed activities. The Public is generally “anyone who is in any way affected by the proposal o shows a genuine interest in it. After the information on the development proposal has been made available to the Public, the latter is expected to provide its written comments and suggestions on the proposed activity to the Developers through various types of public involvement techniques (such as public hearings, discussion forums, public and consultations). 2. EIA principles As provided in Article 53 of the Law on EP, SEE is carried out in accordance with: (i) Azerbaijan’s international legal commitments; (ii) Principles of legality, scientific validity, transparency, integration of environmental, social, engineering and

10 Extracted from the “Assessment of Effectiveness of EIA system in Azerbaijan”, CENN (2004).

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technological, technical, architectural and planning, economic and other assessments; (iii) The results of comprehensive socio-economic and ecological assessment of environmental impacts of economic activities; (iv) the people’s right to healthy environment the principles of sustainability, (v) the presumption of potential danger of the unregulated use of natural resources, the risk of disasters, and (vi) the necessity to preserve the nature as an integral part of the society. 3. EIA timeframes The EIA Handbook specifies that within one month after the submission of the Application the Developer should be informed of whether the proposed activity requires a full EIA or not (Paragraph 2.7). In case a full EIA process is needed, the Environmental Authority must make its decision on the proposed development within three months upon the submission of the EIA documentation. Thus, the timeframes of the EIA process for each particular project depend on the type of the activities under consideration. At the same time, the EIA Handbook states that the Developer is not limited, in terms of time, in undertaking investigations and producing an EIA report, but is obliged to submit the report within 12 months after the Environmental Permission is issued by the Environmental Authority. 4. EIA objects Article 54 of the Law on EP lists activities subject to SEE. According to the list, following economic activities should undergo SEE before they can be implemented: (i) drafts of state and local programs for development and allocation of labor forces according to sectors and regions, (ii) feasibility studies (the so-called technical-economic substantiation documentation), (iii) projects of construction (reconstruction, extension, technical upgrading) and demolishing of economic objects and complexes, (iv) OVOS documents, (v) documents related to development and import of new techniques, technologies, materials and substances, (vi) draft vocational and regulatory and technical documents on environmental protection, (vii) ecological conditions established as a result of economic activities or emergencies, (viii) ecological conditions of the region, isolated natural objects and ecosystems, (viii) ecology related sections of the draft agreements providing for use of natural resources based on the decision of the respective executive authority. As stated in the EIA Handbook, “the EIA Process is applied to all development proposals in principle” (Paragraph 2.1). The Environmental Authority further decides on the extent to which the EIA procedure should be applied to each particular activity based on the severity of the likely impacts which the activity under construction may have. 5. Contents of the EIA report The EIA Handbook defines the content of EIA reports as separate documents describing the proposal, the environmental baseline, potential environmental impacts of the

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proposal, and the measures to avoid, remedy or compensate for them, and containing of introduction and conclusion sections (Paragraph 3.2.2.). 6. EIA stages 6.1. Screening

There is no distinctive screening procedure outlines by either the Law on EP or the EIA Handbook, in the country, despite the ratification of the Espoo Convention by Azerbaijan in 1999. According to the Law on EP, nearly all types of developments, regardless of their scale and sector, are subject to SEE, e.g. state and local development programs, feasibility studies, new developments as well as new construction, extension and upgrading of the existing objects, new technologies, regulatory and technical documents on environment protection, and environmental sections of draft contracts for the use of natural resources (Article 54). The EIA Handbook lays down a two-tiered EIA procedure, in which the Developer is required to submit an Application containing basic information on the proposal for any type of activities. Based on the experience of the past EIAs and sometimes on screening lists of various organizations (e.g. the World Bank), rather than on specifically developed lists of activities. The Environmental Authority further decides on the necessity of a full-scale EIA for each particular development 6.2. Scoping

There is no distinctive scoping process outlined in the Law on EP. The Law, however, mentions tasks of the SEE, which include identification of the degrees of ecological safety of the planned and implemented economic activities; assessment of the compliance of the developments with the environmental and health legislation and regulations; and verification of the proposed nature protection measures (article 52). According the EIA Handbook, the Environmental Authority holds a Scoping Meeting for the Developers, experts and representatives of the concerned public, aiming at reaching the consensus of the scope of the EIA (Paragraph 3.2.1.). In case the consensus has not been reached, the Environmental Authority decides on the contents of the EIA Documents which the Developer should then produce. 6.3. Assessment –environmental studies

The EIA Handbook requires a study of baseline environment as part of the EIA Document (Paragraph 3.2.2). A description of the environment should cover physical, ecological and social aspects of any development and should relate to all the sites affected by the proposed developments, but nevertheless, in the opinion of the majority, the baseline studies are one of the strongest features of the EIA process in Azerbaijan 6.4. Alternatives, mitigation and impact management

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The EIA Handbook, requires the Developer to include the description and assessment of all the potential adverse environmental impacts of the proposed activity, as well as the description of any measures to avoid, reduce, or compensate for, these impacts, in the EIA documentation (Paragraph 3.2.2.). The EIA Handbook does not require discussion of alternatives, including the so-called “do-nothing” alternative, and their potential impacts, in the EIA documentation except the description of alternative technologies. There is currently no methodology that would guide developers, EIA experts, the public involved, environmental authorities and the decision-makers through the process of dealing with such effects 6.5. Reporting

The purpose of the EIA Report, as stated in the EIA Handbook, is to describe the proposed development, the environment likely to be affected by this development, and to identify potential impacts and suggest ways to m minimize these impacts (Paragraph 3.2.2.). The EIA Documents are expected to provide the Environmental Authority and the affected public with the relevant information about the planned activity, and to convince the stakeholders that the negative impacts are going to be controlled and minimized to acceptable levels. The reporting should be done in a way acceptable to, and easily understood by, the public at large, which can be achieved through bringing all the technical details in annexes, and using maps, diagrams and photographs. During the public hearings, the relevant documentation is provided to all the interested parties to the process through the Environmental Authority (in hard copies and, most recently, through the Internet) which is responsible for making it available through central libraries and mass media. Reporting to the Environmental Authority should also reflect upon the most important comments received from the public as well as statistical data on all submissions from the public on justification of why some of these comments have not been included in the documentation on proposal 6.6. Reviewing

In accordance with the EIA Handbook, the EIA Document review for those developments, which are expected to have significant impacts and are thus required to undergo EIA, is undertaken by Expert Group chaired by the Environmental Authority, but comprised of experts hired from outside (Paragraph 5.1.). The outcomes of such reviews of the EIA documentation, statistical information on submissions received from the concerned public, comments on the proposal and the environment, analysis of the potential environmental impacts of the development, conclusions, and recommendations. 6.7. Decision-making and environmental clearance (permitting & licensing)

One of the distinguishing features of the SEE system is the obligation for any development activity to obtain a positive SEE resolution before receiving an approval for implementation (Article 51).

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The EIA Handbook unambiguously states that the Developer is obliged to obtain the Environmental Permission for any type of economic activities through submitting an Application to the Environmental Authority, carrying out EIA, and submitting the EIA Document to the Environmental Authority for approval (Paragraph 2.3.1). 6.8. Post-decision monitoring –monitoring, implementing and auditing

As stated in the EIA Handbook, the Developer is responsible for continuous compliance with the conditions of Environmental Permission through a monitoring program (Paragraph 2.3.1.). The Environmental Authority undertakes random inspections of the implementation of proposed activities in order to verify accuracy and reliability of the Developer’s monitoring data. It is the Developer who is responsible for notifying the Environmental Authority and taking the necessary measures in case the monitoring reveals inconsistencies with the conditions of the Environmental Permission. 7. Public participation in the EIA process The EIA Handbook’s public involvement procedure is rather unstructured and vague. It requires informing the affected public about the planned activities twice: when the Application is submitted to the Environmental Authorities for the preliminary assessment and during the EIA process per se. The Developer is expected to involve the affected public in the discussions of the proposal, but there are no clear mechanisms to ensure that the public’s comments are taken into account at the stage of project development. The Developer should inform the public of the planned activity once the application procedure has been launched. Surprisingly, it is not the Developer, but the Environmental Authority who is responsible for making the relevant EIA documentation available to the public through its offices, local government offices, schools and libraries, according to the EIA Handbook (Paragraph 4.1.). 8. Enforcement of the national legislation Enforcement of the national legislation has been one of the major issues for the country since Azerbaijan gained its independence in the early 1990s. The mechanisms of enforcement of the environmental legislation, particularly of the Law on EP, are underdeveloped, for example, with regard to setting liabilities for environmental damage, or to public participation in the EIA process. Azerbaijan’s environmental legislation performs the functions of a punishment tool to ensure economic activities are developed and implemented in accordance with the existing environmental standards. On the contrary, international environmental protection legislation is a tool to ensure environmentally conscious, transparent and accountable decision-making.

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Annex 3

World Bank OP 4.01, Annex B - Content of an Environmental Assessment Report for a Category “A” Project

An environmental assessment (EA) report for a Category A project focuses on the significant environmental issues of a project. The EA report should include the following items (not necessarily in the order shown): (a) Executive summary (b) Policy, legal, and administrative framework (c) Project description (d) Environmental and social baseline data (e) Environmental impacts (f) Analysis of project alternatives (g) Project implementation arrangements (h) Environmental Management Plan (EMP) (i) Public Consultation and disclosure (j) Appendixes (1) List of EA report preparers--individuals and organizations. (2) References - written materials both published and unpublished, used in study preparation (3) Record of consultation meetings (4) Tables presenting the relevant data referred to or summarized in the main text. (5) List of associated reports (e.g., resettlement plan or indigenous people development plan).

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Annex 4

Environmental Management Plan (EMP)

The objective of the EMP is to ensure the integration of the possible project environmental issues and proposed mitigation into the detail design and project implementation. To achieve satisfactory implementation of cleanup works, the EMP should ensure that: (i) implementation is monitored and meets the requirements of the environmental law in Azerbaijan; the clean-up and re-development standards for contaminated land; and the WB safeguard policies; and (ii) environmental impacts are mitigated The borrower (MES) and the selected EA Consultant will (a) identify the set of mitigation actions to potentially adverse environmental impacts; (b) determine requirements for ensuring that these mitigations are made effectively and in a timely manner; and (c) propose activities to monitor mitigation actions. The following content is developed based on WB OP 4.01 Annex C, and adapted to the proposed Project. It is suggested that the following information be included: (a) Mitigation Plan: This should include a description of the steps to be taken to identify all anticipated significant effects, to mitigate the major potential impacts on land, water, air and other media during the cleanup works. Potential impacts during the cleanup works are expected such as solid oily waste, noise, pollution caused by spills and leakages, waste water. Special attention should be paid for proper collection of asbestos structures/materials abandoned at the sites. Exampleof mitigation of short-term impact from noise, dust, and vibration during the execution of cleanup works: these could be minimized under the project by (i) specifying in all project contracts the responsibility of contractor to undertake appropriate work site mitigation actions as a part of their management of work sites, and (ii) the supervision of compliance of contractors by the Supervision Engineer. Mitigation measures may include the following actions: use of sprinklers to wash down roads and suppress dust emissions during soil transport; special covered vehicles to prevent spills and transport borrow materials; reduce noise by using noise absorbing/protecting building materials, provide workers with ear plugs and helmets and generally prevented from prolonged exposure to high noise levels, etc. (b) Monitoring Plan: Project monitoring plan includes conducting standard monitoring on environment (soil pollution, solid waste, noise) as well as continuous monitoring in emergency situations. This should include a description of the key parameters to be monitored (including monitoring locations, schedules and responsible entities) and reporting procedures to ensure that the construction and operation of the project is in conformance with local law and other relevant norms and standards. If such details are covered by permits or construction or monitoring contracts these can be referenced as attachments. Special attention should be given to general monitoring in oil polluted areas of former oil and gas production sites through regular soil, water and radio-ecological measurements.

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Example: Management of spills and leakages during transportation and accidental spills, management of waste waters and solid waste, noise, health and safety management, should be regularly monitored by local authorities. (c) Institutional Arrangements: There should be a narrative discussion that provide a brief presentation on how the monitoring data is going to be used for sound environmental performance - who collects the data, who analyzes it, who prepares reports, who are the reports sent to and how often, what is done by the responsible authorities after they receive the information; and how is non-compliance with the EMP managed. This should also include (a) technical assistance programs (training), (b) procurement of equipment and supplies, and (c) organizational changes. (d) Implementation Schedule and Cost Estimates: For all three aspects (mitigation, monitoring, and capacity development), the EMP should provide (a) an implementation schedule for measures that must be carried out as part of the project, showing phasing and coordination with overall project implementation plans; and (b) cost estimates and sources of funds for implementing the EMP. These figures are also integrated into the total project cost tables. In each Environmental Management Plan the following issues will be addressed: (i) Health and safety of workers and the public; (ii) noise, dust and odor control related to air quality, soil and water pollutions; (iii) emergency response plans in case of water or soil contaminations, surface runoffs, waste management plans, hazardous/radioactive substance management plan, fire safety measures, prevention of soil and water pollution, etc.

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