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Joint Environment Programme 11

Environmental Assessment of theNatural Disaster Mitigation Project,Kyrgyz Republic

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I]JACOBS GIBBI.... ! HCG Environment

February 2004

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Contents

I Executive Summary 3

2 Introduction 6

2.1 Background 6

2.2 Project Objectives 6

2.3 Scope of EA and ToR 7

2.4 Structure of the Report 8

3 Policy, Legal and Administrative Framework 9

3.1 Introduction 9

3.2 National Environmental Institutional and Policy Framework 93.2.1 Institutional Framework 93.2.2 National Environmental Policy 133.2.3 National Disaster Management Policy 14

3.3 National Environmental Legislation 143.3.1 Constitution of Kyrgyzstan 153.3.2 Environmental Legislation 15

3.4 International Agreements and Conventions 20

3.5 Regional Cooperation 22

3.6 World Bank Screening and Safeguard Policies 233.6.1 World Bank Screening Categories 233.6.2 World Bank Safeguard Policies 23

4 Project Description 25

4.1 Need for the Project 25

4.2 Project Location 26

4.3 Priority Interventions 27

5 Baseline Environment 29

6 Scoping of Potential Impacts 61

6.1 Introduction 61

6.2 Do Nothing Option 62

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6.3 Scoping Environmental Impacts of Potential Interventions 63

7 Tailings Interventions 64

8 Landslide Interventions 78

9 Pipe Bypass for Mailuu-Suu River 94

10 Relocation of Tailings 96

11 Infrastructure Interventions 105

12 Generic Environmental Impacts and Mitigation Measures 107

13 Environmental Management and Monitoring 113

14 Public Consultation 113

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Executive Summary

The key aims of the Natural Hazards Mitigation Project in Mailuu-Suu, KyrgyzRepublic, are to:

* Reduce health risks from uranium mining wastes in the Mailuu-Suu area;* Reduce the risk of landslides in the Mailuu-Suu area;* Increase the preparedness of local people and authorities to natural disasters.

The Project will provide financial assistance to implement a set of interventions tomeet these objectives. Immediate engineering measures include:1. Unloading top of "Tectonic triangle" landslide to reduce risk of impact on Tailing

No 3;2. Improving the stability of Koi-Tash landslide by improved drainage;3. Rehabilitation of selected tailings and mine waste dumps to reduce radiological

and heavy metal pollution of river courses, and4. Riverbank strengthening to prevent tailings erosion.

A comprehensive monitoring system covering seismic, hydrogeological andenvironmental parameters will be put in place to determine the effectiveness ofimprovements. In parallel to the above, a feasibility study will be undertaken ofoptions to provide a long-term solution to the risks at Mailuu-Suu. The study willconsider options for stabilizing Tailing 3 in-situ or moving Tailing 3 to a new securedisposal location (to include site selection and environmental impact assessmentstudies. This will enable the preferred option to be determined based on technical,socio-economic and environmental considerations. The Project will also assist thegovernment to develop and implement a monitoring and warning program ofimportant potential disaster sites, and assist with institutional development toimprove the preparedness of relevant ministries in case of disasters.

A technical preparation team has prepared studies on various technical andeconomic issues to identify the needs and priorities. At the same time, environmentaland social assessments have been carried out to ensure that the proposed worksare beneficial for the population and environment.

Environmental Assessment

The Project triggers World Bank OP 4.01 (B rating), thus an EnvironmentalAssessment (EA) is being undertaken. The objective of this framework EA is toensure that any adverse environmental or social impacts arising from the proposedimmediate interventions in Mailuu-Suu are identified and, where possible, eliminatedor minimized through appropriate design or mitigation. Another key aim is to providea mechanism for community participation and information dissemination. The EA isbeing undertaken by a team of local and international experts under the EU JEP IIprogram, and includes preparation of an Environmental Management Plan (EMP)and a program of public consultation and disclosure to ensure full compliance withBank guidelines.

A comprehensive review of current environmental legislation of the Kyrgyz Republicwas carried out which included disaster management, emergency response and

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mine tailings. Interviews were held with appropriate national agencies and sectoralministries responsible for enforcement of environmental regulations and monitoringof environmental quality. Interviews were conducted with personnel within variousdepartments of the Ministry of Environment and Emergencies (MEE) as well as MEEstaff at oblast level in Osh. Other departments consulted included the State Agencyfor Forestry, Ministry of Health and Ministry of Agriculture and Water Resources andFood Industry. Discussion also took place with the Institute of History, Academy ofSciences, to identify cultural heritage aspects. A field visit was made to the Mailuu-Suu area to discuss the proposed interventions with local officials, community eldersand members of the public as well as the local NGO.

Baseline

The majority of areas subject to the proposed interventions are currently degraded,either by current and historical anthropogenic activity e.g. industrial waste, minetailings, waste rock dumps, over-grazing or by natural processes e.g. landslides,mudslides and large scale slumping. The Mailuu-Suu area characterized by naturalrisks from landslides, mudflows etc, severe soil erosion from deforestation andovergrazing, industrial dereliction, radiological contamination, chronic healthproblems and socio-economic decline. Species diversity nevertheless remains highand mitigation will need to be considered in remoter areas.

Benefits

The Project is expected to result in significant environmental and communitybenefits, including i) reduction in risk of landslides and failure of tailingsimpoundments ii) strengthening of tailings banks to prevent river erosion andradiological pollution of the river system iii) associated benefits such as reduction inexposure to radionuclides (water, foodstuffs, direct radiation from tailings iv)improved road infrastructure within the Mailuu-Suu valley and protection of the watersupply pipeline from landslide damage, and v) improved public awareness of theradiological hazards and measures the local community should take to reduce thehealth risks. The Project will seek to provide temporary job opportunities for the localpopulation. It will also provide a mechanism for community consultation andimproved dissemination of information to the public. The Project will also support theBank's policy of promoting improved land-use and the rehabilitation of degradednatural habitats.

D is be nefits

The Project will not result in any significant and/or irreversible environmental orsocio-economic disbenefits. Potential impacts during construction such as soilerosion discharge of sediment to the river and community disturbance from dust,noise and traffic diversion, will be minimized by ensuring the Contractor follows goodmanagement practice. Socio-economic issues during construction such astemporary loss of pasture for grazing livestock, road access, and public safety will beaddressed through a community liaison team. Measures are proposed to ensure thata number of tailings areas are rehabilitated so that they may be returned to the localcommunity for safe grazing. In other cases, compensation will be considered whereloss of grazing land is otherwise unavoidable.

Mitigation and Monitoring Plan


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A comprehensive Environmental Management Plan (EMP) has been developed forthe Project to mitigate and monitor potential adverse impacts during construction.Implementation of mitigation measures (e.g. covering pollution prevention, protectionof natural resources, and worker and public safety) will be passed on to theContractor who will be required to follow guidelines for environmentally soundconstruction practice. These requirements will be included in bidding documents andwill be a contractual requirement of the works. The EMP will cover monitoringrequirements during construction and ongoing operation of the Project. Oversight ofimplementation of the EMP will be the responsibility of the Borrower.

World Bank's Safeguard Policies

The Project will trigger two Bank safeguard policies (Involuntary Resettlement andInternational Waterways). The Project envisages that a few properties that are atimmediate risk of damage by landslides or present a serious health risk becausethey were constructed of radioactive tailings will be subject to remediation and theaffected persons temporarily relocated to an area that provides them with anequivalent livelihood. A Land Acquisition/Resettlement Policy Framework is beingprepared to address this issue and will be cleared before appraisal. The Projecttriggers OP 7.50 as the Mailuu-Suu river flows into the Naryn and Syr-Darya riverswhich are international waterways. The Project interventions are designed to reducethe risk of landslides and consequent flooding and pollution of the Mailuu-Suu riversystem, and will not materially affect the quality or quantity of water flows todownstream riparians. A notification letter was sent in January 2004 to theUzbekistan, Tajikistan and Kazakhstan governments to inform them and to requestcomments about the Project.

Public Consultation

Two public hearings, one in Bishkek and another in Mailuu-Suu, were organizedjointly in early February 2004 by the environmental and socio-economic teams. Thisfollowed an initial public presentation of the Project in Mailuu-Suu held in November2003. The Director of the Department of Tailings Management and Emergencies(MEE) chaired the consultation sessions. The hearings were attended byrepresentatives of the World Bank and the technical team, and were led by local andinternational consultants representing the environmental and social teams.

Approximately 300 persons attended the Mailuu-Suu public hearing. There were 34written responses from the participants. Of these, 12 were comments onenvironmental and socio-economic issues. The main issue raised was the need bythe local community for improved infrastructure (clean water, sewage, better roads)and concern about ill health. Approximately 60 people attended the Bishkek publichearing representing governmental officials, NGOs, academia and members of thepublic. Discussion took place on a range of issues connected with the interventions,including the EIA process, reprocessing of tailings, priority of interventions, thereliability of the social survey data, and exposure to radon and the prevalence ofcancer in the local community.

A record was taken of workshop participants, meeting minutes, and verbal andwritten comments received during the sessions. A summary of the findings is


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included in the EA. The draft Final EA is to be made locally available in Russian inApril 2004.

2 Introduction

2.1 Background

The purpose of the report is to review and assess the environmental issues to beconsidered in the Natural Disaster Mitigation Project (NDMP or "the Project") in theMailuu-Suu area that is envisaged receiving a grant from the World Bank (WB). Theavailable project funds are around US$ 5-7 million.

This Environmental Assessment (EA) together with the associated EnvironmentalManagement Plan (EMP) provides the necessary information to meet World Bankrequirements under Operational Policy 4.01. These documents will later be used inthe Environmental Impact Assessment procedure required by Kyrgyz legislation.

Baseline environmental conditions and technical details of the Study Area, includingthe tailings and landslides, are extensively described in the final report of the recentEU Tacis Project "Remediation of the Uranium Mining and Milling Tailing in Mailuu-Suu District of Kyrgyzstan" (Tacis, 2003).

The assignment was carried out by two international experts assisted by two nationalenvironmental consultants, as follows:

* Dr. Mikko Punkari, Team Leader (hydrogeologist, legislative and institutionaldevelopment of environmental management, EIA);

* Dr. Laurie Gardiner, Environmental Expert (chemist/geologist, EIA and mineenvironmental management);

* Mr. Nurlan Djenchuraev, MSc in Environmental Sciences and Policy, NationalDeputy Team Leader (EIA, environmental management of uranium mining);

* Ms. Djamila Aitmatova, MA in Social Sciences (pending PhD on geo-environmental impact of uranium mining in the Fergana valley), National Expert,translator.

In addition to the experts mentioned above, several other local specialists wereasked to prepare documents on a short-term basis or were interviewed during themission. The EA team reported to Mr. Anarkul Aitaliev, Director Department ofEmergencies Monitoring and Forecasting and Mining Tailings Management of theMinistry of Environment and Emergencies.

The NDMP Environmental Assessment was financed under the Joint EnvironmentProgram (JEPII) with EU grant funds (the EU Tacis Program).

2.2 Project Objectives

The objective of the proposed NDMP is to increase the preparedness and safetyagainst destructive natural disasters, in particular landslides and tailings movement,


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with specific reference to the Mailuu-Suu area. Possible key performance indicatorsinclude:

* Reduction in the number of people affected by landslides;* Improved water quality of the Mailuu-Suu River; and* Reduction in the number of landslides in the Mailuu-Suu area.

The overall objective of the Project is to ameliorate the risk of environmentaldisasters in the area. Therefore, this EA report concentrates primarily on theenvironmental issues that could potentially arise from the technical interventions andthe methods by which they are to be implemented.

2.3 Scope of EA and ToR

The purpose of the Environmental Assessment is to assess the potentialenvironmental impacts of the interventions proposed by the World Bank technicalteam.

The EA was carried out during two preparatory in-country missions - a 4-week visit inNovember 2003 and the second 3-week visit in January/February 2004. During bothmissions, the EA team worked alongside a social assessment team and thetechnical team in determining the specific interventions.

An agreed list of short-term interventions was finalized at the end of the secondmission together with an outline of the required works, indicative schedule and costs.At this stage, the interventions are conceptual and without specific engineeringdetails, hence the findings of the EA are general in nature and provide the basis for aframework environmental assessment.

The scope of this study is to describe the necessary environmental managementprocedures and technical prerequisites for maintaining good environmental practiceregarding the proposed interventions at the Project sites. Subsequently, each majortechnical design and implementation project will be subject to the construction permitprocedure of the Kyrgyz Republic (Technical and Economic Substantiation ofConstruction ("TEO"). This includes an environmental permit procedure and, in mostprojects, an environmental impact assessment (known as State EnvironmentalReview, or SER).

The Environmental Department of the WB will decide at a later stage whichenvironmental assessment procedures of the Bank will be applied in each case. TheProject shall be carried out with due regard to environmental factors includingcompliance with applicable national and local standards and regulations.

This report also gives a basis for the screening and scoping stages of theenvironmental assessment. The environmental documents of the Project will also bereviewed by the local NGOs.

The Terms of Reference (ToR) for the assignment comprises the following specifictasks:

* Review and describe the relevant policies, legal and administrativeframework relevant to natural disaster management, management of national


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and international water bodies, health and safety, and any relevant bi-lateralagreements on water sharing;

* Collect and analyze baseline data on relevant environmental issues, theirtrends, and prepare descriptions of the physical, biological and socio-economicenvironment of the proposed Project sites, including information on climate,human environment and health, botany, zoology, vegetation, and surface andgroundwater quality;

* Identify possible negative and positive environmental impacts of the proposedProject and propose mitigating measures as required. In particular, describeand compare Project alternatives (including 'do nothing') in terms of theirpotential environmental impacts, capital and operating costs, institutional, andtraining requirements;

* Provide key criteria for environmental quality monitoring in the Projectimplementation areas;

* Develop guidelines for environmentally sound construction practices;* Develop a mitigation plan for the proposed Project, incorporating

recommendations for feasible and cost-effective measures to prevent or reduceas far as possible any significant environmental impacts of Projectimplementation (construction and management stages);

* Develop an environmental management and monitoring plan for Projectimplementation, which addresses all key environmental quality indicators andincludes institutional roles, responsibilities, capacities and training requirements,and possible funding sources. The management plan should include proposedwork programs and schedules, a ToR for an environmental specialist within thePIU, and guidelines for environmentally sound construction practices; and

* Carry out the public/NGO consultation process, including a workshop. Thisworkshop in Bishkek will bring together around 30 people with immediateinterest in the Project proposals, including senior officials from the PrimeMinister's office, the implementing agency, relevant research institutes, NGOs,donors, and local administration. The objective of the workshop will be to discussand agree on the findings and recommendations of the EnvironmentalAssessment.

2.4 Structure of the Report

The structure of the Environmental Assessment report follows the standard table ofcontents for Environmental Assessment issued by the World Bank. Duringcompilation of this draft of the report, there were only general concepts on theinterventions and no location-specific plans had yet been prepared.

The report is accompanied by an Environmental Management Plan, which givespractical and environmentally sound guidelines for the Project contractors andauthorities responsible for the overall implementation and control of theinterventions.


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3 Policy, Legal and Administrative Framework

3.1 Introduction

The Natural Disaster Mitigation Project interventions will be designed, built andoperated in conformity with the following legislative and regulatory requirements, andlender policies and guidelines:

* National legislation;* International conventions in force in Kyrgyzstan;* World Bank policies, standards and guidelines.

This section of the EA discusses the relevance of these to the Project. The nationalenvironmental legislative and policy framework is initially described. This includesspecific aspects of policy and legislation dealing with natural disaster mitigation. Thisis followed by a summary of environmental legislation, international agreements andconventions to which Kyrgyzstan is a signatory (or which are under consideration),and regional co-operation in the form of transboundary agreements to deal withnatural disasters. The chapter closes with international finance institution (WorldBank) screening and safeguarding policies that are pertinent to the Project. Thedescription of legislation and World Bank policies and guidelines given below aresummaries only and are qualified by reference to the full text of the actual laws ordocuments.

3.2 National Environmental Institutional and Policy Framework

3.2.1 Institutional Framework

(a) Administrative Structure

The Kyrgyz Republic is a centralized country divided into six oblasts (regions) plusthe metropolitan region of Bishkek, the capital. Each oblast consists of severalrayons (districts) and towns directly subordinated to the oblast. In each of the oblaststhere are regional councils, but the main executive authority is represented by thehead of the oblast administration, who is appointed by central government.

The 105 member Zhogorku Kenesh (Supreme Council) represents the legislativepower and comprises of two chambers: the 35-member, permanent LegislativeAssembly (Lower Chamber) and the 70-member People's Assembly (UpperChamber) which sits twice yearly and represents regional interests.

The directly elected President of the Republic is Head of State and Commander-inChief of the Armed Forces. He appoints and dismisses the Prime Minister (subject toapproval by the legislature), appoints the other members of the Government as wellas heads of administrative offices and other leading state posts and plays a crucialrole in the legislative process.

The President is entitled to pass regulatory decrees, which have the same force aslaws and apply nationwide. International treaties signed by the President and ratifiedby Parliament are part of the country's legislation. They do not have precedence


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over national laws. Governmental regulations are meant to implement laws(including international treaties) and presidential decrees. Ministries and agenciesadopt orders and decrees in accordance with their mandates. The President cansuspend or cancel governmental and ministerial regulations.

In the context of environmental policy, the President has specific authority onestablishing rules of natural resources use, defining and announcing environmentalemergencies and environmental disaster zones as well as procedures for collectionand use of environmental protection funds.

The Prime Minister and the First Vice Prime Minister head the executive arm ofcentral government. Three additional Vice Prime Ministers are responsible forIndustrial, Social and Agricultural (including Environmental) Policies and thesupervision of the respective ministries and national agencies.

(b) Environmental Institutions

At the highest level of government, the Jogorku Kenesh (Parliament) - through theCommission on Agriculture and Environment - is responsible for:

* Defining the overall framework for nature protection policy;* Developing and approving laws and regulations;* Approving government proposals on resource charges and taxes.

A number of environmental responsibilities are delegated to the President's office.The President has the authority to:

* Establish specific rules and decide on the use of natural resources;* Define and announce the boundaries and the status of environmental

emergencies and environmental disaster zones;* Approve procedures for the collection and use of environmental protection funds.

The President is also responsible for signing all laws adopted by the Jogorku Keneshand for conducting international negotiations, as well as signing internationalconventions and treaties and submitting them for ratification by Parliament.

Institutions with a responsibility in environmental matters are discussed below.

(c) Ministry of Environment and Emergencies (MEE)

The key government institution responsible for the establishment and implementationof environmental policy as well as natural disaster management in Kyrgyzstan is theMinistry of Environment and Emergencies (MEE).

According to legal provisions, the MEE is an organ of government in the field ofecology, prevention and elimination of emergency situations, civil defense, industrialsafety and mining supervision. Its major aims and purposes (according to KRGovernmental Provision No. 523, August 3, 2002) are to:

* Exercise State control over environment protection, development andimplementation of a common policy in the field of hydrometeorology,environment protection and nature management;


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* Develop and implement a common policy in the field of prevention andelimination of emergency situations and civil defense;

* Control and license in the field of industrial safety, economic activities andmining.

MEE has a central office and seven local branches (one in each of the oblasts, i.e.Jalal-Abad, Issyk-Kul, Naryn, Osh, Talas, Chui and one in the city of Bishkek). Anorganization chart for the central office of the Ministry of Environment and

Ministry of Environment & Emergencies

Department of Environment and Department of Monitoring, Forecasting of EmergencyNatural Resource Management Situations & Mine Tailings Management

Republican Fund for Nature Department for Prevention and Elimination ofProtection Consequences of Emergency Situations

Southern Regional Department for Prevention andElimination of Consequences of EmergencySituations

Chief Department on Hydrometeorology Gosgortechnadzor(Kyrgyzhydromet)

Oblast and Bishkek City Departments of Environment Headquarters of Civil DefenseProtection (strictly protected areas)

Fleet, garage and 'Ecolog" facilities Emergency ResponseField Teams

Emergencies is given in Figure 3.1.

Figure 3.1 Organization Chart for the Ministry of Environment and Emergencies(MEE)

(d) Other Government Bodies with Environmental Responsibilities

Other government institutions with a responsibility in environmental matters,including radiological hazards in the mining sector, are briefly discussed below.

The State Agency for Hydrometeorology ("Hydromet") falls under the MEE. Besidesproviding meteorological services, it is also monitoring chemical and radioactivepollution of air, water and soil.


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The National Statistics Committee collects all environmental monitoring dataobtained from Hydromet. The generation of toxic waste has been registeredstatistically since 1994 through the issue of an annual questionnaire to industry.

The Ministry of Health controls the standards for radiation protection, theconcentrations of toxic substances in air, water and food and protection of the publicagainst adverse effects of radiation and toxins from waste handling and storage.

The State Sanitary-Epidemiological Department (under the Ministry of Health) wasfounded by Government Ordinance No. 229 of 29 May 1997. Its main remit is toimplement sanitary, hygiene and anti-epidemic measures aimed at preventing andeliminating environmental contamination, improving working conditions, welfare andrecreation of the population and reducing morbidity rates. It operates a network ofregional stations.

The Ministry of the Interior executes the State's policies on environmental protection.It also supervises compliance with safety standards in the transport of wastes.

The State Agency for Geology and Mineral Resources is responsible forimplementing the Government's mineral sector policies. Its key functions includeconducting national geological surveys, administering the minerals sector (licensingand exploration) and protecting the national mineral resources. In this context it hasa program for surveying levels of natural radioactivity in soil and groundwater.

Department of Water Resources (DWR - part of the Ministry of Agriculture and WaterResources). It regulates the use of the country's water resources and is in charge ofdesign, construction and operation of all off-farm irrigation infrastructure. TheDivision of Irrigation (DOI) within DWR is responsible for all aspects of impoundingand distribution of irrigation water and its delivery to farms. It also takes part inregular negotiations with its counterpart organizations in neighboring countries withinthe context of the Water Sharing Agreement. DWR also includes the ScientificResearch Institute for Irrigation (SRFI).

Local administrations for environmental protection and management - these areunder the responsibility of the six oblast and Bishkek city Committees onEnvironmental Protection. Although they are subdivisions of the MEE and report tothe Minister, the local Committees are also accountable to local Governors.

(e) Government Bodies Dealing with Natural Disaster Management

Besides the Ministry of Environment and Emergencies (which includes a CivilDefense capability), there are a number of other organizations whose activities aredirectly or indirectly connected with natural disaster management. These include:

* The Ministry of Transport;* The Ministry of Health;* The Ministry of External Trade and Industry;* The Scientific, Research & Design Construction Institute;* The State Agency for Geology and Mineral Resources;* Local Administrations.


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Monitoring of natural hazards is principally undertaken by two agencies, each withtheir own observation network:

* The Institute of Seismology of the National Academy of Sciences;* The State Agency for Hydrometeorology ("Hydromet").

The observation of high mountain lakes was earlier carried out by Hydromet, but isnow the responsibility of MEE.

3.2.2 National Environmental Policy

The immediate objectives of environmental policy were set out in the NationalEnvironmental Action Plan (NEAP) for the Kyrgyz Republic, which was adopted in1995 for the period 1995-1997. It provides a guiding policy for dealing with keyenvironmental problems facing the country:

* Inefficient water resource management;* Land degradation, mainly due to overgrazing;* Overexploitation of fragile forest resources;* Threat of irreversible loss of biodiversity;* Inefficient mining and refining practices.

According to the NEAP, Kyrgyzstan's overriding objectives are to ensure sustainedeconomic growth and to reduce poverty. Environmental protection is viewed as botha tool and a condition for achieving the broad goals.

More recently, the following priority environmental objectives have been identified foraction:

* Reducing urban air pollution;* Using water resources more efficiently and economically;* Improving wastewater treatment;* Protecting arable lands against degradation;* Establishing the sustainable use of plant resources, including forests;* Updating the Red Data Books;* Expanding the system of specially protected areas and biosphere reserves;* Rehabilitating and making safe radioactive dump sites;* Controlling the production, treatment, transport and disposal of toxic wastes;* Registering harmful substances;* Improving the environmental monitoring system.

The major direction of environmental policy in Kyrgyzstan is aimed at providingenvironmental safety of the country through adoption of a system of principles andpriorities, which define external and internal policy, and legal and economicmechanisms aimed at nature protection and conservation.

In moving towards achieving this goal, Kyrgyzstan has adopted a number of strategicpolicy documents. These include the Concept of Ecological Safety (1997), theNational Strategy for Sustainable Human Development (1997), the ComprehensiveDevelopment Framework for the Kyrgyz Republic to 2010 (CDF), and the NationalStrategy for Poverty Alleviation to 2005.


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In addition, as a country with highland ecosystems increasingly vulnerable towardsanthropogenic impacts, the Kyrgyz Republic initiated the year 2002 as InternationalMountain Year within the United Nations. As a result, the Global Mountain Summitwas held in Bishkek, the capital of Kyrgyzstan, in 2002.

3.2.3 National Disaster Management Policy

The National Environmental Health Action Plan (NEHAP, 1997) drafted by theMinistries of Health and of Environmental Protection, includes a chapter on naturaland industrial disasters. The objectives of the Plan regarding natural disasters are:

1. To limit the consequences of natural disasters, to prevent the occurrence and limitthe consequences of major industrial and nuclear accidents, and to ensure thateffective arrangements in place for emergency preparedness and for response tonatural and man-made disasters, nationally and internationally;

2. To ensure that the appropriate levels of government and the relevant publicservices, as well as members of the public, are fully informed of the probabilityand potential risks of industrial and nuclear accidents, so that they can put thoserisks into perspective and understand the action required of them in anemergency.

In order to achieve these objectives, NEHAP anticipates the following actions:

(i) Restoring the monitoring network for natural and man-made hazards as anintegral part of environmental monitoring;

(ii) Developing and implementing effective measures to prevent and mitigatedamage caused by natural calamities and industrial catastrophes;

(iii) Drawing up a list of and certifying enterprises using technologies pertaining tothe use, storage or transport of hazardous substances that present a threat tothe environment or public health in the event of natural disasters andindustrial accidents.

The National Strategy for Sustainable Human Development, adopted in May 1997, isincreasingly seen by the Kyrgyz Government as the appropriate framework for riskmanagement of natural disasters. The broad objective of government policy in thisarea is to reduce the vulnerability of the population and the economy to hazardousprocesses. In this respect, five specific goals have been set:

* To provide timely warning to the public of the threat of natural disasters;* To reduce and mitigate human and material losses from natural disasters;* To establish a single monitoring system to ensure safety of the population;* To improve disaster preparedness by training the population;* To improve rescue preparedness and deal with consequences of disasters.

3.3 National Environmental Legislation

National environmental legislation (including natural disaster management)applicable to the Project is comprised of the following sources of law listedhierarchically in accordance with the Constitution and other laws of Kyrgyzstan:

* Constitution of Kyrgyzstan;EIA February 2004.doc 14

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* Laws, international treaties and Presidential Decrees;* Governmental regulations;* Ministerial orders and decrees;* Regulations and regulatory decisions of the local administrations

(local kenesh).

The Constitution and the main environmental laws and regulations that are relevantto the Project are reviewed below.

3.3.1 Constitution of Kyrgyzstan

The Constitution was adopted on 5 May 1993 by the Supreme Soviet (then thehighest legislative body in Kyrgyzstan) and has since been amended in 1996, 1998and 2003. The Constitution has the highest legal authority.

The Constitution of Kyrgyzstan directly addresses environmental issues and sets outthe legal framework that guarantees a public consultation process with respect toenvironmental matters. Basic rules on environmental protection and natural resourceuse are established by the Constitution. Article 4 provides that land, its subsoil, air,waters, forest plant life and wildlife, and also other natural resources, are used as abasis for the life and activities of the Kyrgyz people and are afforded specialprotection by the State. It also establishes that land can be in public, communal orprivate ownership.

The Constitution establishes the fundamental right of individuals to a favorable andhealthy environment and to compensation for damage caused to health and propertyfrom the use of natural resources. The right is balanced by the obligation on eachcitizen to use the environment, natural resources and historical monuments withcare. The Constitution does not grant individuals the right to environmentalinformation, although this is covered in the 1999 Law on Environmental Protectionand other specialized legislation (see below).

3.3.2 Environmental Legislation

Environmental laws, standards and regulations in the Kyrgyz Republic were mostlyinherited from the former Soviet Union. Since independence in 1991, extensivelegislative reform has provided a more appropriate market-oriented legal frameworkfor environmental protection. In the process the environmental legislation ofKyrgyzstan has been largely revised.

A brief summary of important legislation in the field of environmental protection andnatural disaster management is set out below.

General Legislation

* Law on Environmental Protection 1999. The 1999 Law on EnvironmentalProtection was signed by the President of Kyrgyz Republic on 16 June 1999 andsupersedes the 1991 Law. This law declares a national policy and regulates legalrelationships in the field of the environmental protection and nature management.

* Law on Mountain Territories 2002 (amendment #194 of August 10, 2003). Thegoal of the present law is establishment of socio-economic and legislative basis


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for sustainable development of mountain territories of Kyrgyz Republic,conservation and rational use of natural resources, historical, cultural andarchitectural heritage. The law provides a ground for regulation of humanactivities in mountain territories.

Emergency Situations

* Law on Protection of Population and Territories from Natural and Technogenic(Man-made) Emergency Situations 2000. The goals of the present law include 1)prevention of triggering and development of emergency situations; 2) decreasingdamages and losses from emergency situations; 3) mitigation of emergencysituations. Emergency situation implies "a situation formed on a certain territoryas a result of dangerous natural or technogenic phenomenon, accident,catastrophe or natural disaster which can result in fatalities, health injuries,adverse environmental impacts, economic losses and violation of vital activity ofhuman beings."

Environmental Assessment

* Law on Ecological Expertise (State Environmental Review) 1999. This Law wassigned on 16 June 1999 with the purpose of regulating legal relationships relatingto environmental review (ecological expertise) and the prevention of negativeenvironmental consequences arising from economic activities. The term"ecological expertise" is defined as "the identification of environmental risks andhazards posed by a proposed activity which, directly or indirectly, will have animpact on the condition of the environment and natural resources." Theprocedure to assess environmental impacts of the proposed activity is known asOVOS (Otsenka Vozdeistviya na Okruzhayutchuyu Sredu).

Air Quality

* Law on Atmosphere Protection 1999 (amendment of June 24, 2003). The Law onAtmosphere Protection was signed into law together with a series of otherimportant environmental laws on June 12, 1999 replacing the Law onAtmosphere Protection of 1981. The new law seeks to regulate legalrelationships in the field of atmosphere protection. This law lays down two typesof air quality standards (Section Il): Maximum Permissible Concentrations (MPC)for pollutants, microorganisms and other biological substances in theatmosphere; and Maximum Permissible Levels (MPL) for acoustic,electromagnetic, ionizing and other physical impacts on the atmosphere. SectionIV of the law sets forth requirements for pollutant emissions from stationarysources, and Section V from mobile ones. Monitoring and inspection policy forthe atmosphere is set out in Section IX.

Biological Resources

* Law on Biosphere Territories 1999. This law lays down legal rules forestablishment and operation of biosphere territories. Biosphere territories arewater or/and ground-based ecological systems providing a stable balance ofbiodiversity, economic development and protection of cultural values. Biosphereterritories have the status of specially protected areas at the national level.


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* Law on Specially Protected Natural Territories 1994. Specially protected naturalterritories are regulated pursuant to the Law of 28 May 1994, #1562. Accordingto the Law, there are six categories of protected areas: State Nature Reserves(zapovedniki) - conservation is the primary objective, economic activities areprohibited; State National Parks (prirodnye natsionalnie park,) - conservation andrecreation are the primary objectives, with different management zones defined;State Specialized Reserves (zakaznik,) - conservation of certain species orhabitats is the primary objective, divided into five sub-categories (complex,zoological, botanical, forest and hydrogeological zakazniki). These areas are ofnational or local importance, established for 10 or more years or for 5 yearsmaximum, respectively; Objects of Natural Heritage - both state and privateproperty - a list is approved by the Government; botanical and zoologicalgardens and dendrological parks; Natural Areas for Health Promotion - a list ofareas of mineral waters, therapeutic mud and valuable landscapes is approvedby the Government.

* Forest Code 1999. The Code establishes legal rules for efficient use, protection,conservation and reproduction of forests, and building their ecological andresource capacities. All forests and lands privately, publicly and communallyowned and granted to the needs of forestry constitute the Forest Fund of theKyrgyz Republic. Land covered by forest, as well as not covered by forest butassigned for forestry, is recognized as forest fund land. This includes forests,plantations, nursery forests, felling areas and clearings as well as non-forest landcleared during construction of roads, pipelines, transmission lines, etc.

* Law on Animal Kingdom 1999. The animal kingdom is legally the property of theKyrgyz Republic; it is an essential element of nature and an important regulatingand stabilizing component of the biosphere; the law requires that it be protectedand efficiently used to meet the material and spiritual requirements of the Kyrgyzpeople. The present law establishes regulations for protection, use andreproduction of animal species e.g. while designing and constructing airports,railways, highways, canals, dams, etc., measures should be taken to preservemigration routes and habitats of animals including breeding and over-winteringsites.

* Law on Protection and Usage of Plant World 2001 (amendment # 114 of June24, 2003). This law establishes legal relationships to provide effective protection,rational use and reproduction of plant resources.

Water Quality

* Law on Water 1994. The major goal of water legislation of Kyrgyz Republic isregulation of relationships in the field of usage and protection of water resources,prevention of environmentally harmful impacts on water sites and water facilitiesand improving their condition, strengthening relationships in the sphere of waterrelationships.

* Law on Drinking Water 1999. This law regulates among other aspects the supplyand quality of drinking water.

Waste and Radiation


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* Law on Radiation Security of Population 1999. The Law defines legalrelationships in the field of radiation security of people and environmentalprotection from the adverse effects of ionizing radiation. Four basic principles ofradiation security are recognized: 1) Rating: individual radiation doses from allthe sources of ionizing radiation should not exceed permissible levels; 2) Basing:prohibition of all activities on usage of ionizing radiation sources when benefitsdo not exceed harm from such an activity; 3) Optimization: when using ionizingradiation sources, doses and number of people exposed to radiation should bekept as low as possible; 4) Openness: people should have free access toinformation about ionizing radiation in their neighborhood and about accidentswith radioactive materials. Sections II and IlIl regulate issues of state control overradiation security and authority of state structures in the field of radiation security.Section V stipulates the rights of people and legal entities on information in thefield of radiation security.

* Law on Tailings Ponds and Dumps 2001. The Law aims to provide safety for theenvironment and present and future generations from tailings ponds and wastedumps. Section III of the law stipulates a state inventory of all tailings ponds andwaste dumps located in the territory of Kyrgyzstan. At present in Kyrgyzstanthere are over 50 tailings ponds containing more than 100 million cubic meters ofradioactive and toxic wastes.

* Law on Wastes of Production and Consumption 2001. This Law regulates legalrelationships arising as a result of the formation, collection, storage, usage,neutralization, transportation and burial of wastes of production andconsumption. Radioactive wastes, air and water pollution are the subject of otherlaws.

Historical and Cultural Values

* Law on Protection of Historic and Cultural Heritage 1999. Cultural resources inKyrgyzstan are regulated pursuant to the Law on Protection of Historic andCultural Heritage (26 July 1999, Number 91) administered by the Ministry ofEducation, Science and Culture. Historic and cultural monuments are subject tostate registration. There is a list of monuments of international, national and localsignificance. A document entitled Concept of Development and Preservation ofCulture and Art (Madaniyat), 1997-2000, indicated that there are approximately5,000 historical monuments in Kyrgyzstan. Of these, approximately 1,300 areregistered and 800 are under the protection of the state.

State Environmental Expertise

State Environmental Expertise (SEE) or State Environmental Review (SER)represents an expert examination of materials submitted to an authorized body toimplement a project. The purpose of SEE is to appraise environmental impacts of theintended project. The outcome of the SER is expressed as a negative or positiveresolution of the project.

Section IV (Environmental Requirements for Economic and Other Activities) of the1999 Law on Environmental Protection and the 1999 Law on EnvironmentalExpertise (State Environmental Review) states that funding or implementation of a


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project that may have a potentially adverse impact on the environment is prohibited,unless approval is obtained from a state environmental expert commission.

The environmental review is carried out in accordance with a procedure approved byan authorized state body on environmental expertise.

The 1997 Instruction on a Procedure of State Environmental Expertise for Pre-Project, Project and other Materials in Kyrgyz Republic provides requirements forwhat information is to be submitted to the State Environmental Expertise and theorganization of the environmental expertise bodies.

An extensive list of documents is required to be subjected to SER. This includes alltypes of planned and pre-project documentation, drafts of environmental and otherprograms, concepts, sectoral development plans, city and area development plans,feasibility studies and projects for reconstruction, development, re-equipment,decommissioning, drafts of international treaties, contracts, and agreements relatedto usage of mineral resources etc.

In order to carry out state environmental review the project proponent should providethe following documentation:

* Materials covering the environmental assessment of economic activities;* Approvals from corresponding state bodies and local administrations;* Statement of public environmental review (if carried out).

State environmental review of a project is a responsibility of an expert commissioncreated by an authorized body on Environmental Expertise. The expert commissioninvolves specialists from the authorized body and part-time experts, including thosefrom environment protection organizations, with the exception of the projectproponent or developer.

The duration of the SER is defined by the complexity of the project but should notexceed three months after submission of the necessary documentation and paymentof fees.

Public Participation

The 2001 Law on Accession of the Kyrgyz Republic to UNECE Convention onAccess to Information, Public Participation and Access to Justice on EnvironmentalMatters (the Aarhus Convention and 1999 Laws on Environment Protection andEnvironmental Expertise) provide the legislative framework for public participation inenvironmental decision-making.

Public environmental expertise is organized and conducted by an initiative ofcitizens, local administrations and public associations, registered according to aprocedure established by Kyrgyz legislation. Public environmental expertise may beorganized independently from the state environmental expertise.

Initiators of any development project possibly having environmental consequenceshave to notify in advance in writing to local administrations and local councils aboutthe performance of the public environmental expertise.


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A statement of public environmental expertise is directed to the body conductingstate environmental expertise, and also the body making a decision about executionof the project under assessment. A statement of public environmental expertise isrecommended. It can be published in the mass media and passed to local stateadministrations and local councils, project initiators, designers and otherstakeholders.

3.4 International Agreements and Conventions

Kyrgyzstan's priorities in international co-operation are related to the country's mosturgent environmental problems:

* Ensuring the safe rehabilitation of nuclear tailings;* Strengthening the pollution monitoring and control system;* Combating desertification and land degradation;* Improving water resource allocation between neighbors.

Since independence in 1991, the Kyrgyz Republic has demonstrated a commitmentto widening its international co-operation in environmental protection, the sustainableuse of natural resources and resolution of transboundary issues, notably watersharing (see below).

The international agreements and conventions of relevance to the Project to whichKyrgyzstan is party (or to which active discussions are taking place) are listed inTable 3.1. The Kyrgyz Republic has signed eleven international conventions in theenvironmental field.


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+ 1 a.

Table 3.1 International Agreements and Conventions of Relevance to the Project

Convention/Treaty/Protocol Status in Kyrgyzstan

Basle Protocol on Transboundary Ratified: 18/1/96 (according to the UN EnvironmentMovements of Hazardous Wastes and Program the Kyrgyz Republic acceded to theTheir Disposal Protocol on 13/8/96)

UN (Rio) Treaty on Biological Diversity Ratified: 26/7/96 (according to the Secretariat theKyrgyz Republic acceded on 6/8/96)

Convention on Navigable Waterways of According to the UN official documents, the KyrgyzInternational Concern Republic was not among the voters for/against the

Convention, neither was it among abstainers orothers attending voting in the UN GeneralAssemblv on 21/5/97

United Nations Treaty to Combat Acceded to the Treaty on 21/7/99 (according to theDesertification Secretariat the Kyrgyz Republic ratified the Treaty

on 19/12/97 and acceded to it on 19/9/97).

UN Framework Convention on Climate Acceded on 14/1/00 (on 25/5/00 according to theChange Secretariat

The Kyoto Protocol - UN framework Currently pending Parliamentary approval.convention on climate change

Convention on Wetlands of International Currently is at the review stage. The list of waterImportance Especially as Wildfowl Habitat and wetland resources of international significance(Ramsar) includes inter alia the Issyk-Kul Lake.

UN Rotterdam Convention of the Procedure Signed on 11/8/99; ratified and the law was signedof Preliminary Justified Agreement on 15/1/00 and published on 26/1/00; according toregarding Chemical Substances and the Secretariat on 25/5/00.Pesticides International Trade

Vienna Convention on the Protection of the Acceded on 15/1/00; on 31/5/00 according to theOzone Layer Secretariat.

Montreal Protocol on Substances That Acceded on 15/1/00; on 31/5/00 according to theDeplete the Ozone Layer (and its London Secretariat.and Copenhagen amendments)

Paris Convention on the Protection of the Acceded on 10/6/95; on 3/7/95 according to theWorld Cultural and Natural Heritage Secretariat.

Geneva Convention on Long-Range Acceded on 14/1/00; on 25/5/00 according to theTransboundary Air Pollution Secretariat.Protocol of the 1979 Convention of Long- Acceded on 14/1/00Range Transboundary Air Pollution

Convention on Transboundary Acceded on 14/1/00Environmental Impact Assessment (TheEspoo Convention)The Aarhus Convention on Access to Acceded on 14/1/00Information and Public Participation inDecision-Making

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The Stockholm Convention on Persistent Acceded on 16/5/02Organic Pollutants

3.5 Regional Cooperation

In addition to international Conventions/Treaties ratified by the Kyrgyz Republic thereare many international agreements in the Central Asian region regarding co-operation in management and conservation of natural resources, as well as dealingwith transboundary matters concerning natural disasters, including uranium minetailings and international waters. Those most relevant to the Project are as follows:

* Agreement between the Government of the Kyrgyz Republic, the Government ofthe Republic of Kazakhstan and the Government of the Republic of Uzbekistanon joint efforts to rehabilitate areas of tailings and waste dumps that havetransboundary impact (signed Tashkent on April 5, 1996). A joint program ofaction to rehabilitate tailings on the territories of the countries of the CentralAsian Economic Community was prepared and adopted on 17 June 1999 by theHeads of Government.

* Agreement between the Government of the Kyrgyz Republic, the Government ofthe Republic of Kazakhstan and the Government of the Republic of Uzbekistanon the use of water and energy resources of the Syr Darya river basin (signed inBishkek, March 17, 1998). This includes reference to collaboration to reduce theadverse effects of spring flood waters, mudflows and other natural hazards.

* Agreement between the Government of the Kyrgyz Republic, the Government ofthe Republic of Kazakhstan and the Government of the Republic of Uzbekistanon the environmental protection and rational management and conservation ofnature (signed in Bishkek on March 17, 1998)

* Declaration between the Government of the Kyrgyz Republic, the Government ofthe Republic of Kazakhstan and the Government of the Republic of Uzbekistanconcerning co-operation and collaboration on uranium legacy issues (signed inBishkek on 10 October 2003)

The last -mentioned Declaration arose out of a workshop held in Bishkek from 9 to10 October 2003 entitled Followup Workshop to Report on the Progress of theMailuu-Suu International Database and to Exchange Views on Other RegionallyImportant Uranium Mine Tailings, held under the auspices of OSCE. At thisworkshop it was acknowledged that the Mailuu-Suu uranium mill tailings represent asignificant transboundary threat to the Fergana Valley and there was intent betweenthe parties to continue co-operation in the characterization, rehabilitation planningand rehabilitation activities, including the sharing of technical data.

Kyrgyzstan is also a Member of the CIS Interstate Council Agreement onEmergencies of a Natural or Technogenic Character, the goals of which includefacilitating transboundary co-operation in prevention of and response to emergenciesthrough co-ordination of policy and participating jointly in technical internationalprogrammes. These include, for example, co-operation and interaction in earthquakeresearch and seismic risk prediction.


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In addition to intergovernmental, bilateral and mutual agreements with neighbouringCIS members (Kazakhstan, Tajikistan and Uzbekistan), there continues to be a highlevel of co-operation with international funding agencies, western governments andother donors/aid agencies on projects to support natural disaster preparedness andsustainable development. These include the World Bank, Tacis, UNDP, UNEP, ADB,GEF, EBRD and the governments of Finland, Germany, Japan and Switzerland, aswell as other organisations.

3.6 World Bank Screening and Safeguard Policies

3.6.1 World Bank Screening Categories

The World Bank undertakes environmental screening of each proposed project todetermine the appropriate extent and type of EA. The Bank classifies the proposedproject into one of three categories, depending on the type, location, sensitivity, andscale of the project and the nature and magnitude of its potential environmentalimpacts.

Category A projects are likely to have significant adverse environmental impacts thatare sensitive, diverse, or unprecedented. These impacts may affect an area broaderthan the sites or facilities subject to physical works. EA for a Category A projectexamines 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, orcompensate for adverse impacts and improve environmental performance. For aCategory A project, the borrower is responsible for preparing a report, normally anEIA (or a suitably comprehensive regional or sectoral EA) that includes, asnecessary, elements of the other instruments.

Category B projects have potentially adverse environmental impacts on humanpopulations or environmentally important areas - including wetlands, forests,grasslands, and other natural habitats - but are less adverse than those of CategoryA projects. These impacts are site-specific; few if any of them are irreversible and inmost cases mitigatory measures can be designed more readily than for Category Aprojects. The scope of EA for a Category B project may vary from project to project,but it is narrower than that of Category A. Like EA for Category A projects, itexamines the project's potential negative and positive environmental impacts andrecommends any measures needed to prevent, minimize, mitigate, or compensatefor adverse impacts and improve environmental performance.

Category C projects are likely to have minimal or no adverse environmental impacts.Beyond screening, no further EA action is required for a Category C project.

3.6.2 World Bank Safeguard Policies

Operational Policy (OP) and Bank Procedure (BP) 4.01 are the World Bank'sprincipal policy documents on Environmental Assessment (EA). EA is one of ten"Safeguard Policies" that projects must comply with to be eligible for Bank financing.These key policies are intended to ensure that potentially adverse environmental andsocial consequences of Bank-financed projects are identified, minimized andmitigated.


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The ten Safeguard Policies define Bank requirements for project lending under thefollowing areas:

i. Environmental Assessment (OP/BP 4.01);ii. Natural Habitats (OP/BP 4.04);iii. Pest Management (OP 4.09);iv. Cultural Property (OP 4.11);v. Involuntary Resettlement (OP/BP 4.12);vi. Indigenous Peoples (OP 4.20);vii. Forests (OP/BP 4.36);viii. Safety of Dams (OP/BP 4.37);ix. Projects on International Waterways (BP 7.50);x. Projects in Disputed Areas (OP/BP 7.60).

The subject Natural Disaster Mitigation Project is relevant to Safeguard Policy i and,potentially, to ii, iv, v, viii and ix. A brief summary of these World Bank safeguardpolicies is given below.

OP 4.01 Environmental Assessment

EA evaluates a project's potential environmental risks and impacts in its area ofinfluence. It examines project alternatives, identifies means for improving projectselection, siting, planning, design, and implementation by preventing, minimizing,mitigating, or compensating for adverse environmental impacts and enhancingpositive impacts; and includes the process of mitigating and managing adverseenvironmental impacts throughout project implementation. The Bank favorspreventive measures over mitigatory or compensatory measures, whenever feasible.

EA takes into account the natural environment (air, water, and land); human healthand safety; social aspects (involuntary resettlement, indigenous peoples, and culturalproperty); and transboundary and global environmental aspects. EA considersnatural and social aspects in an integrated way. EA is initiated as early as possible inproject processing and is integrated closely with the economic, financial, institutional,social, and technical analyses of a proposed project.

OP 4.04 Natural Habitats

The Bank promotes and supports natural habitat conservation and improved landuse by financing projects designed to integrate into national and regionaldevelopment the conservation of natural habitats and the maintenance of ecologicalfunctions. Furthermore, the Bank promotes the rehabilitation of degraded naturalhabitats. The Bank does not support projects that involve the significant conversionor degradation of critical natural habitats.

OP 4.11 Cultural Property

The United Nations term "cultural property" includes sites having archaeological(prehistoric), palaeontological, historical, religious, and unique natural values.Cultural property, therefore, encompasses both remains left by previous humaninhabitants and unique natural environmental features such as canyons andwaterfalls. The Bank normally declines to finance projects that will significantly


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damage non-replicable cultural property, and will assist only those projects that aresited or designed so as to prevent such damage.

OP 4.12 Involuntary Resettlement

If there is potential for people to be displaced as the result of the project, consultationon the resettlement should start at as early stage as possible among affectedcommunities/individuals. To obtain co-operation, the affected persons (resettledpersons and their potential hosts) need to be systematically informed and consultedduring preparation of the resettlement action plan about their options and rights, andresettlement opportunities. Community participation is encouraged.

OP 4.37 Safety of Dams

The Bank distinguishes between small and large dams. Small dams are normallyless than 15 meters in height. This category includes, for example, farm ponds, localsilt retention dams, and low embankment tanks. For small dams, generic dam safetymeasures designed by qualified engineers are usually adequate.

OP 7.50 International Waterways

This policy is designed to protect international waterways from pollution. An"international waterway" is defined as "any water body that forms a boundarybetween or flows through the territory of two or more states". It thus covers:

* Any river, canal, lake, or similar body of water that forms a boundary between, orany river or body of surface water that flows through, two or more states;

* Any tributary or other body of surface water that is a component of any waterwaydescribed above.

This policy applies to the following types of projects: hydroelectric, irrigation, floodcontrol, navigation, drainage, water and sewerage, industrial, and similar projectsthat involve the use or potential pollution of international waterways as describedabove. Riparian states whose water bodies are likely to be affected should benotified.

Project compliance with Bank Safeguard Policy requirements is discussed in Section12.9.

Project Description

4.1 Need for the Project

The Natural Disaster Mitigation Project (NDMP) is aiming at increasing thepreparedness and safety against natural disasters, in particular landslides andtailings movement, which threaten the environment and human health in the Mailuu-Suu River valley. Consequently, the Project will improve the quality of theenvironment in this area, in general, if implemented properly.


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Uranium mining and milling industrial activities in the Mailuu-Suu area occurredduring 1946 - 1968. The associated deposition of tailings (residues from oreprocessing) and of low-grade ore and waste rocks from mining, covering an area ofapproximately 44 hectares and with an estimated volume of 3 million m3, was carriedout in a moderate mountainous terrain and in gently sloping alluvial areas, often inclose proximity to the Mailuu-Suu, Kara-Agach, Kulmen-Say and Aylampa-SayRivers.

In the Mailuu-Suu valley there are 23 tailing sites and 13 waste rock dumps. Ofthese, 14 tailing sites and 12 waste dumps are inside the town boundary. Hazardoussubstances within the tailing sites include radionuclides and heavy metals, bothdangerous to human health. There are number of houses which are located in closeproximity to the tailings and a few are even built on the dumps. Cattle frequentlygraze on the tailings and transfer toxic substances to the food chain.

Some of the tailing sites are located close to the river and on unstable mountainslopes. A few have earlier been partly damaged due to landslides and river erosion.Hazardous substances (radionuclides and heavy metals) within tailings located closeto the river are leaking with the result that increased levels of radiation have beenobserved in river water and sediment samples. There is also a danger that alandslide could dam the river and the tailings could be submerged, eroded andwashed downstream. In the worst scenario, a landslide could push some of thetailings to the river, which could then wash the dangerous substances throughMailuu-Suu town to areas used for irrigation, and possibly further downstream to theFergana valley. Such an event could irreversibly contaminate agricultural areaswithin the flood plain, prevent the use of river water for irrigation and damage thesocio-economic structure of the region.

The Ministry of Environment and Emergencies (MEE) has classified the Mailuu-Suuarea as a hazard zone of environmental pollution. A large number of earlier projectsand international organizations have recognized the urgency of interventions in thisarea. Consequently, implementation of the Project has a high priority in theenvironmental management of the country.

4.2 Project Location

Mailuu-Suu town is located at 41.13 degrees north latitude and 72.51 degrees eastlongitude, about 60 km north-west of Jalal-Abad and about 25 km from the borderwith Uzbekistan. The town has approximately 25,000 inhabitants and is located inproximity to the tailing impoundments and mine waste rock deposits. Smallersettlements are located in the valleys of the Mailuu-Suu, Kara-Agach and Aylampa-Say rivers. In most cases the tailings and waste rock dumps lie upstream of thecommunities, sometimes close to the houses. In the settlement of Kara-Agach,waste rock dumps are located in the centre of the settlement.

Hazardous substances from the tailings can migrate to local groundwater, bereleased downstream along the Mailuu-Suu River or be dispersed downwind by theprevailing wind (dust and radon gas). Accordingly, the Project area for environmentalexamination purposes is defined in general terms as the area adjacent to theproposed intervention sites and the immediate area downstream of the Mailuu-Suuvalley.


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4.3 Priority Interventions

The final list of Project interventions that were proposed by the technical teamcomprises the following five components (see Figure 5.1 for location of tailings):

A. Immediate Needs

1. Tectonic landslide - unloading top of landslide ("Tectonic triangle" on south side)to reduce risk of impact on Tailing 3 (survey, design and removal of rock/soil).

2. Tailings - basic maintenance and repair to include improving surface drainageand repair of erosion channels, and improved cover to reduce radiologicalexposures.

3. Koi-Tash landslide - design and implementation of a surface water drainagesystem to capture and remove water run-off so as to reduce risk of reactivation.

4. Seismic monitoring system - install monitoring stations on top of Tectonic andKoi-Tash and link to central early warning system in Mailuu-Suu.

5. Riverbank strengthening - design and implement engineering protection toprevent erosion along banks of Mailuu-Suu and Alympasay Rivers (mainlyprotection to Tailings 1, 2, 4 and 8).

6. Waste rock dump rehabilitation - Dumps 1 and 2 in Kulmensay valley to preventheavy metal and radiological pollution of river (design and implement riverculvert/bypass around dumps).

B. Feasibility study

In parallel to the above immediate interventions, a feasibility study will be undertakenof options to provide a long-term solution to the risks at Mailuu-Suu. This will enablethe preferred option to be determined based on technical, socio-economic andenvironmental considerations. The study will consider options for stabilizing Tailing3 in-situ or moving Tailing 3 to a new secure disposal location (to include siteselection and environmental impact assessment studies). If sufficient funds areavailable, the feasibility study will also consider options to stabilize the Koi-Tashlandslide or reduce the risk of a natural dam from this landslide blocking the valleyusing a flank bypass of the river. This would include consideration of possible newalignments for the valley road north of Kara-Agach.

C. Monitoring Program

A detailed monitoring program to include seismic, hydrogeological, geochemical andenvironmental parameters is being planned to support and complement the aboveinterventions and determine the baseline situation. This will include a weatherstation in Mailuu-Suu, a gauging station on the Mailuu-Suu River (at Kara-Agach);sampling selected wells and springs; and up to two seismic stations. This programwill enable a clear picture to emerge of contamination fate and transport from the


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tailings and dumps, and assist in the design of interventions to reduce the risk ofnatural disasters.

D. Capacity Building

A program of capacity building will be included to strengthen the ability of the MEE tofulfill its duties and functions. This component will include training and provision ofequipment to provide a more effective emergency response system.

E. Project Implementation Unit (PIU)

A PIU will be assembled to handle day-to-day Project management issues. This willcomprise a small team with expertise covering financial management, procurementand technical capacity (including environmental management). The PIU will beresponsible for overseeing the activities of the Consultant and Contractor. Theassumed World Bank EIA screening category for the proposed interventions is asfollows:

1. Management of tailings and waste rock dumps (Category B-C);2. Management of landslides (Category B-C);3. Construction of a pipe bypass for the Mailuu-Suu River (Category B);4. Relocation of tailings (Category A);5. Infrastructure rehabilitation interventions (Category B-C).

Management of tailings and waste rock dumps include the following activities:

* Restricting access by people and animals to the tailing sites;* Capping of tailings safely to allow revegetation and grazing;* Stormwater drainage to prevent run-off water infiltrating the tailings and

dispersing hazardous substances off-site;* River bank strengthening adjacent to tailings to avoid erosion;* Seepage prevention by dam strengthening.

Management of landslides includes the following activities:

* Unloading land mass from the top of landslide prone areas;* Drainage to prevent inflow of stormwater run-off to landslide prone areas;* Dewatering landslide prone areas;* Early warning systems and alarms to facilitate evacuation in the event of

activation.

Construction of a pipe bypass for the Mailuu-Suu River includes the followingactivities;

* Earthworks to prepare the siting of the pipes;* Construction of a concrete casing for pipes;* Transportation and installation of metal pipes.

Relocating of tailings includes the following activities:

* Pre-excavation conditioning of tailings;* Excavation of tailings;


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* Developing transportation infrastructure;* Site selection for disposal cell;* Disposal site preparation;* Closure of the disposal site;* Environmental monitoring (baseline, during operation and post-closure).

Infrastructure rehabilitation interventions could include the following components:

* Road rehabilitation supporting earthworks of other interventions (e.g. the Mailuu-Suu - Sarybeya road);

* Facilities rehabilitation e.g. upgrade and rerouting drinking water pipeline;* Removal of potentially polluting substances from landslide or flood-prone areas;* Management of industrial waste landfills and contaminated soils.

5 Baseline Environment

5.1 Introduction

The environmental baseline is a detailed description of the physical, biological andsocio-economic characteristics of the Project area before construction andoperational of the proposed interventions. The purpose is to document the conditionof the environment, evaluate pertinent sensitive issues and allow evaluation ofpotential impacts. This process is necessary to provide direction in definingmitigation measures that avoid or minimize adverse environmental impacts.

The description of the physical, biological and socio-economic characteristics of theProject area has been based on a review of available literature, discussions withrelevant government departments and a visit to the Mailuu-Suu area.

The baseline review identified that while information is available for the Jalal-Abadoblast, there is a lack of published environmental information for the Mailuu-Suuarea, notable detailed ecological baseline survey data, as this has historically been aclosed area and not subject to normal scientific research. In addition, the specificlocations likely to be subject to interventions have not yet been finalized.

For these reasons, it is recognized that there are information gaps in a number ofareas, notably local fauna and flora. As part of the EIA process in support of theapplication for a construction permit for the Project interventions, further field surveyswill be needed in the local areas.

5.2 Description of Project Area

The potentially impacted environment related to a given Project (generally referred toas the Project area) is defined primarily in regard to two factors:


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* The nature of the proposed interventions* The sensitivity and circumstances of the environment in which the proposed

interventions will occur.

The proposed interventions comprise engineering works to reduce the risk oflandslides and tailings failure in specific locations within the Mailuu-Suu valley. TheProject area is therefore defined by the local area that could be affected by theseinterventions.

However, the consequences of a major natural disaster in the Mailuu-Suu valleyhave potential to impact the wider downstream environment of the Fergana Valley.For this reason the Project area includes a regional transboundary elementstretching across the border into Uzbekistan.

5.2.1 Mailuu-Suu Valley

The Mailuu Suu valley lies within the Nooken rayon of Jalal-Abad oblast in thecentral western part of the Kyrgyz Republic within the foothills of the Fergana Valley,approximately 25 km north of the border with Uzbekistan.

The Kyrgyz part of this valley is defined by the Mailuu-Suu River and a number oftributaries which run from the source area in the Babash-Ata mountains north-east ofMailuu-Suu to the Uzbekistan border in the south.

Mailuu-Suu town is situated about 25 km north of the Uzbekistan border and is thelargest residential areas with a population of some 25,000. A number of smallersettlements are situated along the valley floor. These comprise from south to north:

* Kypchak-Talaa (about 5 km from the Uzbekistan border)* Kok-Tash* Kara-Agach* Sarybiya

Figure 5.1 defines the local Project area and the main population centers atimmediate risk from natural disasters in the valley. It stretches from the northern endof Mailuu-Suu town to the settlement of Sarybiya about 2 km up the valley. Thevalley in this section forms a narrow ravine with steep eroded and unstable mountainslopes rising up to a height of about 500 m from the riverbed. Figure 5.1 also showsthe location of the main active landslide areas, uranium tailings and waste rockdumps which are the focus of the Project interventions.

ELA February 2004.doc 30

* t'~ -,1, C]JACOBS GIBB 1J HCG Environment* *

Mayloo-Suudeposit area -- - .g

1 km

MSarybiya settlemen

\ \ 9 8 \ 6 M1i9~M16

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89 e e 0X, F11-1 Kara-Agach setHement1 M48 kmIdov - M42

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Figure 5.1. Mapof Project are shwn taiig an%ok4 up

*g' i ,4B ~~~~Mailoo-Suu setHlement

5.2.2 Fergana Va~~~~~~~~Ylley

* l: ~~~~~~~~Legend\ g////,// / M48 * Punktsof samp[ng of surf-c)( 1 / E:3 ~~~~~~~Settlem.ns

,/Z/ / ~~~~~X Ta,hlngs impoundment

/ 61 5 e~~~~~~~& Dumps7 118 km down ~~~~~~ Roads

Figure 5. 1. Map of Project area showing tailings and rock dumps

5.2.2 Fergana Valley

The Fergana valley is an intermountain depression located within the Tien Shanmountain system with a total area of about 78 km2. The central part of thedepression is an elliptical plain, approximately 300 km long and up to 60 km wide.The valley is situated between 350 m and 600 m above sea level. The mainwaterways are the Syr-Darya, Naryn and Kara-Darya rivers while numerous canalsare used for irrigation.

The greater part of the Fergana Valley belongs to Uzbekistan while the surroundingfoothills are mainly in Kyrgyzstan and Tajikistan. There are three districts withinKyrgyzstan - Djalal-Abad, Osh and Batkent - which are situated within thesefoothills. The valley in these regions is densely populated with more than 300inhabitants per km2.

The Fergana region has a highly developed agricultural and mining industry(including gold, uranium, base metals, oil gas and coal). The Fergana Valley in Oshand Djalal-Abad Oblasts is one of the country's main crop producing regions. Cottonis the main crop and is rotated with alfalfa. Early vegetables are primarily grown inthe valley while fruit orchards can be found on the lower slopes in all regions.


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The Project area includes the eastern outskirts of the Fergana valley. For thepurposes of this assessment, the area of potential impact comprises the flood plainof the Mailuu-Suu River stretching from the Uzbek border about 25 km south to thevicinity of the town of Andijon.

5.3 Meteorology and Climate

In the Fergana valley and up to around the border with Kyrgyzstan the climate ismoderate temperate. In the region of the Mailuu-Suu valley the climate is cooler anddry, and characterized as Steppe. Only at higher elevations in the mountainsfeeding the Mailuu-Suu River does precipitation increase with the climate becomingBoreal with clearly defined summers and winters merging to Glacial.

The regional climate is continental with long, dry and hot summers and relativelyshort moderate winters. Frequent periods of thawing and high precipitation (snowand rain) are characteristic of the winter climate.

The maximum recorded temperature is +38,5 °C, minimum -8,5 0C, and annualmean temperature is +13,1 0C. The period of stable temperatures above 0 0C startsat the beginning of April, while the frost period starts in the second half of October.

Climatic characteristics for the Project area have been based on data from themeteorological station "Lenin Jol" located at an altitude of 706 m in the village withthe same name. The minimal average monthly temperatures are experienced inDecember-January and average - 0.6 °C. Average long-term snow cover is 0.37 mwithin the valley part of the Project area. The freezing depth of the soil is 15 cm.

Mean annual precipitation in the area is 447 to 578 mm (200 mm as snow). Themaximum is 815 mm and the minimum is 225 mm. Over the year, precipitation isdistributed as follows: spring - 40%, winter - 27%, autumn - 23%, summer - 10%.The greatest amount of precipitation is observed in spring, in March, April and May,with a low in August. Generally, the Project area is located in a zone of low humiditywhere the total annual precipitation is less than the surface evaporation. This factadversely affects recharge of groundwater. The conditions are most favorable in theautumn-winter period when atmospheric precipitation is most intensive, andevaporation is minimal.

Snows falls typically falls in period from mid-October to mid-December and melt inthe period from mid-March to mid-April. The total number of days with snow covervaries from 100 to 205 per year. The climate is typical for areas situated between800-1400 m altitude. Microclimatic conditions can exist e.g. dry and hot conditions 20km down the Mailuu-Suu River and wet and colder 20 km upstream. These climaticconditions favor intensive water saturation of loose clayish sediments on mountainslopes with the result that soils gain plasticity.

The prevailing wind directions are NNE and S, mainly resulting from the course ofthe Mailuu-Suu River valley. Mean wind velocity varies between 2 - 5 m/sec. Thehighest wind velocity of 17 m/s from the north was registered in January 1995.

5.4 Air quality

Three potential sources of air pollution in Mailuu-Suu area are:


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1) Mine workings, waste rock and tailings of the uranium industry;2) Emissions generated by current industrial activities in Mailuu-Suu;3) Road transport emissions.

Uranium industry

The first source of atmosphere pollution clearly dominates over the second and thirdones in terms of hazard and scale. Of major concern are substances which canpotentially threaten people's health, namely radon and radioactive dust.

Radon is a colourless, odourless and heavy radioactive gas formed by the decay ofradium, which is itself a decay product of uranium. The longest-lived isotope, radon-222 (3.8-day half-life), arises in the uranium series. Radon and its decay productsmay be transported by the wind over long distances from a mining site.

Naturally occurring radon gas is a potentially serious health hazard. Radon's mainhazard is caused from inhalation of the gas and its highly radioactive daughters,which emit alpha radiation, resulting in damage to lung tissue. A distinctive feature ofradon daughter particles is their ability to attach themselves to dust resulting inpenetration of alpha radiation to the deepest parts of the lung.

Low concentrations of radon emissions from uranium mill tailings and waste rockwould not make any significant contribution to total radon dose. However, effects ofradon accumulated in a cloistered space, such as a mine may be significant.

Risks associated with radon include:

* Radioactive waste as building material. Uncontrolled usage of radioactive wasteas building material for houses as determined from previous radiation surveys isof concern as indoor radon may cause significant harm to people's health.

* Access to mining sites. Since access to many mines in Mailuu-Suu is notrestricted people may freely enter mines and suffer considerable exposure toradon. The concentration of radon in underground mines may reach up to100,000 becquerel per cubic meter. Of considerable concern are children whoretrieve scrap metal from the mine workings.

* Settlements - people living in houses built on old mine waste dumps e.g. Kara-Agach.

Tailings impoundments, including rehabilitated ones, represent a considerablesurface area from where radon is emitted. Radon emissions from tailings exceedemissions from underground mines by a factor of 4-5. Radon measurementsconducted in Mailuu-Suu on tailings #3, 5 and 7 show levels well in excess ofbackground (50-100 eman against 0-5 eman). The existing protective layer coveringtailings with a thickness of up to 1 meter does not adequately prevent release ofradon to atmosphere. Accumulation of substantial amounts of radon over tailingsurfaces can in part be explained by poor wind dispersion due to landscape features.Moreover, in Mailuu-Suu, such residential areas as South Kara-Agach and Koi-Tashare in close vicinity to tailings.

Waste rock dumps located in or close to rivers in the Mailuu-Suu valley generatelarge quantities of radon as they are represented by unconsolidated porous material


* Iii4ACOB8GIB LL I HCG Environment

that allows radon to pass through. Lack of cover over the dumps also contributes tofree emanation of radon into the atmosphere.

Radioactive dust is formed as a result of wind erosion of waste dump surfaces.Dispersion of fugitive dust from around waste disposal sites causes gradualcontamination of the surrounding areas with toxic and radioactive materials.

Industrial air pollution sources

Emissions generated from stationary pollution sources include waste gases from thelight bulb factory, oil industry, agriculture and the coal-fired power station. Nosignificant impact on air quality is anticipated from industry within the Mailuu-Suuvalley.

Road transport

Emissions from this source are exhaust gases generated by cars and trucks. Giventhe low number of vehicles using the road, no significant impact on air quality isanticipated from transport.

5.5 Noise

Current regulatory responsibilities, applicable standards and the concept of sensitivereceptors in noise and vibration control within the Kyrgyz Republic are initiallydiscussed. This is followed by an identification of potential noise impact sites withinthe Project area.

Regulatory Responsibility. Regulatory responsibility for the control of noise andvibration and electromagnetic monitoring rests with the local SanitaryEpidemiological Station (Ministry of Health).

Noise Standards. The technical terms and units of noise measurements employedby Kyrgyzstan noise standards are defined as follows:

Leq = the sound level equivalent, i.e., an energy-averaged sound level that includesboth steady background sounds and transient short-term sounds. The Leqrepresents the level of steady sound which, when averaged over the samplingperiod, is equivalent in energy to the fluctuating sound level over the same period.The Leq is commonly used to describe traffic noise levels that tend to experiencehourly peaks.

LMax = maximum sound level.

dB(A) = A' weighted measurement of sound. Since the range of sound pressurelevels varies greatly, sound levels are expressed on a logarithmic scale, whichcompresses the range. The standard measurement unit of sound is the decibel (dB),which represents a ratio of pressure levels referenced to the 0.0002 microbar whichis considered the threshold of human hearing. The threshold of pain, which is theother end of the audible range, occurs at approximately 140 decibels. Using thedecibel scale, an increase of three decibels is barely perceptible and an increase ordecrease of ten decibels is perceived as a doubling or halving of the sound level.Humans are capable of hearing only a limited frequency range of sound and the


*3 JACOBS GlB 3ft ~ |IR ~HCG Environment

human ear is not equally sensitive to all frequencies. The human ear is moretolerant to higher noise levels at lower frequencies and can hear frequencies rangingfrom 20 hertz (Hz) to 20,000 Hz. In order to take this characteristic into account innoise measurements, a frequency weighting known as A-weighting is commonlyapplied to the sound pressure levels which approximate the frequency response ofthe human ear by placing most emphasis on the frequency range of 1,000 to 5,000hertz. Because the A-weighted scale closely describes the subjective response ofthe human ear, it is most commonly used in noise measurements. Sound levelmeasurements using A-weighting are expressed as dB(A).

Vibration Standards. Levels of permissible vibration are based on a former Russianstandard entitled "Sanitary Norms on Permissible Vibration in Residential Buildings".

The Project area. Ambient noise levels have not been measured but outside Mailuu-Suu town are expected to be similar to those found in rural areas. No sensitivereceptors (schools, hospitals, etc.) have been identified as being of special concernwithin the potential noise impact area of the interventions. However, if the Projectworks will involve significant noise-generating activity, such as transportation ofexcavation waste through Mailuu-Suu town or as blasting and piling operations in thevicinity of settlements - appropriate baseline noise monitoring (day and nighttime)should be included in the Project design.

5.6 Geomorphology, Geology and Geohazards

5.6.1 Regional Geological Framework

The Mailuu-Suu area is situated in the transitional zone between the Variscianconsolidated basement block in the north (Arslanbob) and the Fergana Basin in thesouth. In the area of Mailuu-Suu town the northern rim of the Fergana Basin isformed by an anticline consisting of weakly consolidated sediments (UpperCretaceous up to Paleocene), which is folded along an E-W axis. This fold structureof the older Alpine structural phase forms a morphological saddle. In the northwestthis structure interlocks with a NE-SW syncline which developed during the laterAlpine structural phase. A shear zone separates the older consolidated basementfrom the younger structure of the Fergana Basin. In this shear zone young NW - SEstructures have been developed which can be interpreted as extensional elements.

5.6.2 Geology of the Mailuu-Suu Uranium Mining District

The Mailuu-Suu uranium deposit is located within the Mailuu-Suu River valley and inthe adjoining areas to the east and west. The deposit is situated within the periclineof the Angrek-Sarybee Uplift. The uranium ore zones are associated with theCarboniferous horizons "Li" and "L2" of the Alai Sequence and the Paleogenehorizon "m" of the Turkestan-Sequence.

The Shaidansk Overthrust limits the deposit to the north where strata of thePalaeozoic basement are overthrusted on Mesozoic and Cenozoic sediments. Thistectonic lineament extends over a distance of 60 km. The tectonic movements alongthis line have continued until recent times and are still active. The geologicalstructure to the south is called the Dzhurek-Akbalyksk Syncline. This depressionextends to the SW with a length of 6 - 7 km and a width of 4 km.


i .h3 JACOBS GIBB iL S HCG Environment

The periclinal termination of the Angrek-Sarybi Uplift in the areas underlain by Meso-and Cenozoic sediments is complicated by second order fold structures.

In this area, the Northern (Kara-Agach) and the Main (Mailuu-Suu) Anticline areinterrupted by the Central Syncline. The axes of these anticlines arch to the SW andW forming the Bedre-Coupola which limits the Central Syncline to the west. Thesouthern limb of the main synclines does not exhibit any structural complications.

The Northern Anticline is an asymmetric fold with a less inclined north-western limb(25-300) and a steeply dipping south-eastern limb (up to 900). At the location wherethe Mailuu-Suu River valley intersects this limb is a fault intersecting Cretaceous andPalaeogene sediments.

In WSW direction the profile intersecting the Main Anticline exhibits an asymmetricarch. This anticline is approximately 4 km long and has a maximum width of 700 m.The depression is underlain by Palaeogene and Neogene sediments. The tectoniczone of the Central overthrust runs along this depression and determines thestructural differences between the northern and southern limbs (or boundaries of thesyncline). The former is steeply inclined (becoming steeper with depth), while thelatter is less steeply inclined (35-400), with a decreasing angle at depth.

Within the zone of the Central Fault, the south-eastern limb of the Northern Anticlineoverthrusts the western limb of the Main Anticline. The total amplitude of thedisplacement does not exceed several hundred meters at this location.

The Bedre-Coupola (or dome) is an isometric positive structure with gently inclinedstrata (15-200) in the S of the western pericline. Cretaceous sediments are exposedin the centre of the Coupola. The limbs consist of Paleogene and Neogenesediments. The northern limb of this dome structure is straddled by a flexure-faultzone.

A second zone of this type, which limits the Bedre-Coupola to the S, extends in aNW direction from the Mailuu-Suu River valley. Here, a sudden change of dip inCenozoic strata can be observed to the south: from 15-65° to 12-150. An extendedtectonic zone strikes more or less N-S along the Mailuu-Suu River valley (Mailuu-Suu-Faults). East of the Mailuu-Suu-Faults (Kulmen Section) the southern limb ofthe Main Anticline is complicated by numerous fractures or faults

5.6.3 Landscape

References to topographic classifications are those provided by the Atlas of KyrgyzSSR (Central Directorate for Geodesy and Cartography of the Council of Ministers ofthe USSR, 1987).

The Project area is classified as mostly "tectonic denudation accumulative,predominantly foothill". The relief is characterized by large hill/ridges and adyrs (lowfoothills bordering the Fergana depression), and rock benches of mainly Cenozoicand to a lesser degree Mesozoic age. This type of relief is also represented by spur-like valleys with small hills and gently rolling topography in Quaternary loessdeposits.


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a * 1

Topography at the head of the Mailuu-Suu valley is classified as "tectonic -

accumulative plain, mainly gently-sloping alluvial - proluvial".

5.6.4 Landslides and Mudflows

Landslides

Large landslides, up to more than one million cubic meters per event, arewidespread at the eastern rim of the Fergana basin (foothills of the Western Tien-Shan mountains). Every year landslide activity in this part of Kyrgyzstan causessignificant damage to settlements and infrastructure, and also loss of human lives.

The landslides and slope instability are caused by complex interactions between anumber of endogenic and exogenic factors within the general geological settingincluding:

* Relief;* Nature of surficial deposits;* Structural geology;* Engineering geology;* Meteorology and climate;* Vegetation and land use;* Specifics of the regional geology.

In general, landslides may occur at an elevation of between about 700m and 2000mrepresenting the weakly consolidated sediments of the topographically rising rim ofthe Fergana basin below its transition into the high mountains.

Three geologically determined main groups of landslides may be distinguished:

* Landslides developing in loess units of the Lower, Middle and Upper Quaternary(Ql -Q3);

* Landslides developing in weakly consolidated Meso- and Cenozoic sediments(Jura up to Palaeogene) consisting of sand- and siltstones with intercalated clays,loams, carbonates and sulfates;

* Landslides developing in older and younger sedimentary units at the same timeand event.

In the first type of landslides (Q1-Q3), the actual mass movement can happen withinminutes or hours, and affect up to more than one million cubic meters of material. Inthe other two types, active mass movement takes place in a period ranging fromdays up to several weeks.

Sediments of the Upper Neogene (N2) are rarely affected by landslides. These unitsmainly consist of conglomerates and weakly consolidated gravels with interbeddedloess-like loams. High porosity and permeability of these units seem to preventengineering-geological conditions which are critical to slope failure. In the samearea, phases of landslides activity can alternate with inactive phases over longerperiods of time.

Landslide activity has been documented by local authorities for many years basedon topographic and geological mapping, engineering-geological investigations and


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aerial photography. (These data are administered by the Kyrgyz Ministry ofEnvironment and Emergencies). Because of the local character of theseinvestigations, this information only allows partial geological interpretation oflandslide activity on a regional scale.

Scientific investigations of factors causing landslides have been the subject ofcollaboration between the Remote Sensing Section of GFZ Potsdam and theMinistry of Environment and Emergencies using remote sensing and GIStechniques.

The Mailuu-Suu area has a high degree of risk from landslides in the high mountainsand in the hill-country part of the basin. More than 150 landslides are known in thegeneral area, almost 40% of which are considered unstable. During the last 10 yearsan increase in landslide activity has been observed in this region. Several hundredbuildings have reportedly been damaged or destroyed and nine people have died asa result.

Three quarters of all watercourses in the basin exhibit dangerous conditions forconstruction or cultivation in the lower reaches of the river valleys as many factorsresponsible for the occurrence of mud- or landslides are very strongly developed inthe respective catchment basins. The factors that promote the formation ofsignificant slope movement as well as major mud- and landslides include:

* Existence of easily erodible sediments;* Strongly structured relief;* Thinning steppe vegetation;* Dry and hot summers.

Mudslides

Heavy rainfall is the main reason for the formation of mudslides. Up to 98 % of theobserved mudslides on the slopes of the Fergana Mountain Range are directlyassociated with rainfall, particularly during the period of snow melt. The extent towhich mudslides are prevalent in the Mailuu-Suu area is shown in the Kyrgyz Atlas1987.

The Mailuu-Suu valley with its steeply sided and eroded hillsides and heavy springrains is particularly susceptible to mudslides and is situated in the highest risk zone.The frequency of mudslides in the Mailuu-Suu basin averages 1-1,5 per year. Themudslide activity starts in April and ends in August. Mudslides are most frequent inMay when 33 % of all observed events are registered. The highest mudslide activitywas registered during the years from 1929 to 1958 when 5 mudslides occurred peryear. The volumetric flow rate of the slides ranged from 8,4 m3/s to 60 m3/s.

5.7 Soils

References to soil types are those provided by the Atlas of Kyrgyz SSR (CentralDirectorate for Geodesy and Cartography of the Council of Ministers of the USSR,1987).


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5.7.1 Soil Types

Under the former Soviet system, soils were classified by color which vary in type andcolor according to altitude. The soils of the lower agricultural areas are dominated byheavy grey, alkaline Serozyems, altemating with sands and gravels; the soils in thepiedmont areas include darker Kashtanovye (Chestnut) soils or Chemozyems(Black) soils. Under the former Soviet system the soils of the Fergana valley areclassified as Calcic Xerosols. In total, Kyrgyzstan has about 1,200,000 ha of arablesoils including 830,000 ha of irrigated soils.

All soils of Kyrgyzstan can be divided into two groups: soils of inter-mountain valleysand syrt plateaus, and soils of mountain slopes. The Project area is characterizedby both groups of soils.

In the Fergana valley and towards Mailuu-Suu, soils are classified as grey Turanlight, while closer to Mailuu Suu town they become grey Turan dark (e.g. Kok-Tashvillage). Upstream of Mailuu-Suu the soils are grey Turan normal while the slopesaround Mailuu-Suu are covered mostly by mountainous grey soils. In terms ofzoning, soils of the Project area belong to the Fergana district of South KyrgyzProvince.

5.7.2 Soil Contamination

Local soil contamination generally arises from industrial wastes which can beremobilized by atmospheric and water transport processes. Several sources thatpotentially can contaminate soils in the Project area have been reported:

1) Radioactive elements. This group includes U-238, Ra-226, Th-230, Pb-21 0, etc.These elements can be spread as radioactive dust blown off waste dumps andtailings and by surface water runoff into streams, and as a result of accidents. In1958 there was a major release from Tailing 7 in Mailuu-Suu. As a result, more than60,000 cubic meters of radioactive waste were released into the river causingextensive downstream contamination.

2) Heavy metals. Most of the radionuclides are also classified as heavy metals. Inaddition to these, tailings and waste rock dumps may contain other toxic metals suchas arsenic, cobalt, nickel, molybdenum, cadmium and selenium. The presence ofindustrial waste (e.g. glass from the light bulb factory dumped in the Aylampa-Sayvalley) is an additional source of soil contamination.

3) Organic substances. Organic substances contained in natural underground oilreserves may be a source of pollution in the Mailuu-Suu area from oil producingactivities. There is also potential for oil tanks in the abandoned Isolit factory to leaktheir contents.

5.7.3 Soil Erosion Potential

Soil erosion is a major environmental concern throughout Kyrgyzstan due to seismicactivity, steep slopes, the fragility of the soils and human activities such asinappropriate livestock management, the removal of protective vegetative cover andpoor water management practices.


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Soil erosion has become one of the primary issues in the agricultural sector,affecting soil fertility, causing diffuse water pollution and the accelerated silting ofwater reservoirs, lakes and irrigation systems. It is estimated that 31% percent of thearable lands are heavily eroded, 27 % are eroded and only 17 % are slightly eroded.

The erosion potential of soils in the Mailuu-Suu region above the town ischaracterised as medium-to-strong. The landslides in this area are comprised mainlyof loose loess-type soils with low plasticity formed over many thousands of years bywind erosion.

5.8 Hydrology and Surface Water Quality

Hydrogeology and regional hydrology data are abstracted from the 2003 report ofTacis Project #SCRE1/#38 "Remediation of Uranium Mining and Milling Tailing inMailuu-Suu District of Kyrgyzstan".

5.8.1 Hydrology of Mailuu-Suu River and its Tributaries

Within the landslide risk area the main hydrographic element is the Mailuu-SuuRiver, where the Bedre, Kara-Agach, Kugai, Sarybiya and Kulmen waters inflow. Therivers are fed by snow and springs. The water discharge varies depending on theamount of precipitation and the intensity of snow melt, and is highest in May-June.The density of the hydrographic network is 0.66 km/km2.

The Mailuu-Suu River belongs to the north Fergana area of the Syr-Darya basin. Thetopographic relief of the area is characterized by a system of hills and mountainswhich belong to the north-western extensions of the south-western slope of theFergana mountain range. The Mailuu-Suu basin is surrounded on three sides bythese topographic features.

The average altitude of inflows to the Mailuu-Suu basin does not surpass 2,000-2,600 m. On the upper reaches of the Mailuu-Suu there are 9 glaciers with a totalsurface area of 3.2 kM2, which do not have an essential impact on the inflow andoutflow regime. Precipitation on the western slopes of the Fergana mountain range isrelatively high, especially during the cold season. Because of this, a lm to 3m thicksnow cover accumulates in this area. This corresponds to a water reservoir in theorder of 200-500 mm. The annual precipitation rate amounts to 500 mm at 1,000maltitude (above sea level), and 1,000-1,100 mm at 2,500-3,000 m altitude.

The Mailuu-Suu River during its course from the NE to the SW collects 169tributaries. There are four lakes in the basin. At its oufflow from the mountainousarea the Mailuu-Suu River builds a delta and fans out in numerous channels andforks. The recharge area of the Mailuu-Suu is 530 km2. The biggest tributaries arethe rivers Davansay, Semendyk-Say, Kurgai, Sarybiya and Kara-Agach.

The Project area is crossed by the Kara-Agach River and the Kulmensay stream.The Kara-Agach is the right tributary of the Mailuu-Suu and begins at an altitude of2.100m on the eastern slopes of the Kelmtau mountain range. Its recharge area is36,9 km2 over a 14,6 km river length. The averaged, balanced slope angle of theriver bed is 114%, with 191% for the recharge area. The Kulmensay stream is 8,1km long with a recharge area of 13,7 km2.


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The Mailuu-Suu River belongs to the rivers fed by snow and glaciers. The run-offregime is characterized by three periods:

* Period of snow high water regime (March to May) when the runoff is mainlyfed by melt water from the lower and medium altitude mountain regions;

* May to August: snow-glacier discharge period, thawing period of snow andglaciers in higher altitudes. The mean duration of high water periods is 176days, with a maximum of 221 days and a minimum of 118 days. On average,77% of the entire annual rate is discharged during these high-water periods;

* From the end of August to the beginning of March is the period of normalwater levels. Rivers are recharged by groundwater. During some years minorhigh-water periods occur in the autumn caused by autumn rainfall.

The highest water levels are observed during the spring and summer high waterperiods and the lowest water levels during autumn and winter time. The highestwater level was recorded on 16th April 1958 when, because of a rupture of tailingspond No. 7, the water level increased to 636 cm. The lowest water level wasmeasured on 11th February 1956 with 29 cm. In humid years (e.g. 1959, 1969) thewater level rose to 213 cm and 192 cm, respectively.

During the course of the warm season, variations in water level can be observedthroughout a single day depending on the time of the day. This is explained by thevariation in intensity of thawing of snow and ice at higher altitudes.

The flow in the Kara-Agach River is determined by snow melt and strong rainfall.Until recently there has been no systematic observation of the flow regime in thisriver. Therefore the description is analogous to that of the Kurgai River which joinsthe Mailuu-Suu River further upstream. The flow regime is characterized by astepwise increase of the water level from November to March due to the melting ofthe unstable snow cover. A sudden increase in water level takes place from April toMarch due to seasonal snow melt and rainfall. This increase terminates at the end ofMay, after which there is a continuous decrease in water level until June when thenormal level prevails.

The flow in the Kulmensay River is relatively regular and is fed by groundwater.During the period of seasonal snow melt a slight increase in river flow is observed.Significant and short periods of increased flow are recorded during rainfall.

The Mailuu-Suu River flows through the western and north-western sides of theBabash-Ata Mountains. It reaches the border with Uzbekistan near the village oflzbaskent. The river then flows into the Kara-Darya, which in turn flows into theNaryn River, which becomes the Syr-Darya.

The Mailuu-Suu River is 87 km long with a catchment area of 530 km2. It is fed byglaciers, snow and rainfall. Glaciers, with an elevation above 4,000 m, cover an areaof about 3.2 km2. There are also four lakes in the river basin, with outlets into theriver. The largest lake is Kutmankul, with a surface area of 0,6 km2 and catchmentarea of 38 km2. Trees and bushes cover less than 20 % of the catchment area.


JACOBSGIB 3 HCG Environment

The river flows from north to the south in the Project area. Where it enters theFergana valley, a part is diverted for irrigation. The river feeds water-bearinghorizons in the valley of the Karaungur River. The Kara-Darya River has its sourcefar beyond the area of investigation and is formed by the confluence of several rivers(Tar, Karakuldja, Kurshab, Kugart) that are fed by snow and spring melt water.

Water discharge in the Mailuu-Suu River varies from 1.8 m3/s (October-January) to38 m3/s (April-June). Many springs dry out by the end of summer in the south part ofthe area. The normal flow rate of the Mailuu-Suu River during the time of systematicobservation is recorded as 9.01 m3/s. Average annual long-term water discharge is10.83 m3/sec.

The average flow rate of the Kara Agach River is 0.61 m3/s according to calculations.The maximum annual mean flow rate was measured in 1969 as 19 m3/s, and theminimum annual mean in 1938 was 4.58 m3/s.

The minimal discharges are observed generally in January and February andamount to on average 3.7 m3/sec (the lowest average monthly discharge is 2.17m3/sec). Minimum flow is observed towards the end of the period with normal waterlevels. The mean minimum flow volume is 2,08 m3/s.

Maximum discharge in the Mailuu-Suu River occurs normally during May and June,i.e. in the months of intensive snow melt. Based on a 58-year observation period, itcan be seen that the maximum peak discharges take place when rainfall coincideswith peak snow melting.

During the high water season in May the discharge is on average 30.8 m3/sec (thehighest average monthly discharge is 47.20 m3/sec). The highest recorded volume offlow during the period of observation was measured in 1969 with 108 m3/s, while thelowest flow volume was in 1974 with 17.4 m3/s. The average maximum discharge ofthe Mailuu-Suu River for a period of 58 years has been recorded as 51.5 m3/s.

The estimates of the 1 in 100 year flood event discharge are rather variable andrange between 130 and 170 m3/s.

5.8.2 Surface Water Quality

The quality of the surface water in the Kyrgyz Republic is generally considered to begood because the primary source of river waters is snowfall on the high mountainslopes. Glacial melt rivers have a low concentration of salts (0.04 to 0.15 g/l). Mostcontain only 0.1-0.3 g/l of minerals on leaving the mountains. According to the NEAPreport the water of most river basins in the Kyrgyz Republic has low levels ofpollution. Observation in all river basins shows an adequate oxygen regime and lowcontent of organic and nutrient substances (BOD5 is usually below 2-3 mg/I andnitrates below 1 mg/I).

The Mailuu-Suu is a weakly mineralized river. Highest mineralization (290-450 mg/I)is observed during the period of normal water levels. Lowest mineralization (190-215 mg/I) is recorded during the high water period when snow melt waterspredominate.


* * n"' JACOBSG B t IHCG Environment

The chemical composition of the river water is hydro-carbonatic and calcium bearing.The waters are generally soft with a degree of hardness not exceeding 2-3.5 mg/I.The water in the Mailuu-Suu River is fresh with mineralization of 0.27 g/l.

Information on solid particle transport exists only for the Mailuu-Suu River. The meanquantity of transported solid particle matter is 4.13 kg/s, and the mean annual degreeof turbidity (due to suspended solids) is 459 g/m3. The calculated norm for solidparticle transport is 4.57 kg/s, close to the actual value. During the passage ofmudflows the degree of turbidity (due to suspended solids) can reach more than10,000 g/m3.

During the period of systematic observation the highest degree of turbidity wasmeasured on May 2, 1980 as 12,000 g/m3. The highest volume of transported solidswas observed on May 23, 1979 and amounted to 650 kg/s at a degree of turbidity of9,500 g/m3.

More than 90 % of total suspended solids are transported during the warm period ofthe year. The highest mean monthly volumes are recorded during the periods ofmaximum flow. For the Kara-Agach River the norm for solid particle transport wasdetermined in a modular way according to the Mailuu-Suu River and amounts to 0.32kg/s.

Oil in water. The name "Mailuu-Suu" means "oily water" due to the natural presenceof oil deposits at depth in the area. For this reason, organic substances are naturallypresent in the Mailuu-Suu River and have been aggravated by polluted surface waterrun-off from oil well heads formerly in operation on the banks of the river.

Radionuclides

The Tacis 2003 study sampled water from a number of locations along the Mailuu-Suu River, stretching from the water reservoir above Sarabiya downstream to theentrance of the town at the confluence of the Alma Say and the Mailuu-Suu. Analysiswas performed at SCK-CEN using ICP-MS. Data are given in Table 5.1.

Table 5.1 Uranium concentrations along the Mailuu-Suu River

Sampling Location Uranium (ug/l)(after filtration)

At water reservoir north of Sara-Biya 1.9Confluence Kara-Agach and Mailuu-Suu Rivers 3.5After T3, T9, Ti 9, T22 4.1Confluence Kulmen-Say and Mailuu-Suu Rivers 5.1Confluence Aylampa-Say and Mailuu-Suu Rivers 6.9

Source: after Tacis 2003

A clear increase was found in the uranium concentration with downstream distancefrom the water reservoir, and evidence was seen of leaching of uranium from thetailings and background sources. The uranium values are a factor of 1000 lower thanthe drinking water limit proposed for Kyrgyzstan (1.8 mg/I), although this limit is highby international standards. Tacis found no trend in alpha concentration along theMailuu-Suu River.


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5.9 Hydrogeology and Groundwater Quality

Aquifers in the Mailuu-Suu area are as follows:

1) In the Mailuu-Suu River valley a widely distributed water bearing horizon ispresent in alluvial, and proluvial younger deposits of upper Quaternary ( QIII-IV)age. This layer has a band-like distribution along the valley and a down valleyinclination and is overlain by boulders, detritus and gravel deposits with a matrixof clayey sandstone. These latter deposits have a maximum thickness of about30 m. The average depth of this aquifer ranges between 1-20 m. The flow rate is2-39 m/d. The groundwater has a mineral content of 0.2-0.7 g/l. Its chemicalcomposition resulting from surface water infiltration is hydrocarbonatic-sulphaticand sulphatic-hydrocarbonatic. The water resource of this deposit is described asapproximately 27 I/s (2,556 m3/d).

2) The aquifer (water bearing horizons) in the deposits of the Lower BaktriskiSequence (N2 BK1). Aquifers are boulder detritus and boulder conglomerates ofvariable composition on the basis of a clay carbonate matrix. Water intake resultsfrom infiltration of atmospheric precipitation in Quaternary deposits. The yield ofdrilled wells is 3-5 I/s, the flow rate is 0.3-11 m/d, mineralization is 0.3-3.4 g/l,averaging approximately 1 g/l.

3) A weak aquifer in the deposits of the Massagetski Sequence (P3 -N1 ms). Thisaquifer is not very widely distributed. Surface outcrops exist in the erosionchannels of rivers and streams. Sediments consist of sandstone and graveldeposits and to a lesser extent conglomerates. Water yields are extremelyvariable. In the Mailuu-Suu River valley (altitude 2547 m) the yield isapproximately 0.6 I/s. The yield of springs at 141 m lower elevation is 0.2 I/s.

The chemistry of the above aquifers is not very well investigated. Different zones areobserved with increasing depth. The mineralization increases from 0.5 g/l to 3 g/lwith components containing sulphate and chloride.

5.10 Ecology

Mountain areas within Kyrgyzstan have for many thousands of years been subject tonatural geohazards (e.g. landslides, mudslides, flooding, fault zones, seismicactivity). Most of these regions have also been subject to extensive deforestationand overgrazing. As forest cover has disappeared, floods and mudslides havebecome common phenomena, killing many people every year and furtheraccelerating erosion.

The Project area situated within the Mailuu-Suu valley represents a microcosm ofmany of the ecological problems facing the country. Added to this, the areaimmediately to the north of Mailuu-Suu has been subject to intensive uranium miningand milling since the 1940's, although this activity ceased some 12 years ago. Thehills overlooking the valley exhibit severe soil erosion and slope instability problems,exacerbated by overgrazing, and have comparatively low conservation value. Thesmall areas of flat productive land within the flood plain have been intensivelycultivated with small scale subsistence farming (including nuts, fruit and riceplantation to the south of the town).


** * : JACOBS GIBB HCG Environment

It was reported by a number of authorities that there is no exact information aboutthe current situation with respect to flora and fauna in Kyrgyzstan, and specifically inthe area around Mailuu-Suu. The lack of ecological survey data is due to the factthat, until comparatively recently, this has remained a closed area.

Baseline ecological information on the Mailuu-Suu area was therefore obtained fromThe Kyrgyz Atlas, 19871 as well as field observations. This was supplemented bydiscussions with experts from the Institute of Biology, National Academy of Sciences(Dr. Valentina Toropova, Chief of the Laboratory on Vertebrate Zoology, Institute ofBiology and Soil; Dr. Lidiya Kustariova, Leading Researcher, Issyk-Kul BiologicalStation under the Institute of Biology and Soil; Nazgul Kendjebaeva, a researcher ofthe Laboratory on Flora, Institute of Biology and Soil)

In addition, officials from the State Department of Forestry (the responsiblegovernment department for ecology) were consulted. In particular, ForestryDepartment officials included Dr. Vladimir Zamoshnikov (one of the principal authorsof the Red Data Book of the Kyrgyz Republic), Bakyt Alymbaev (Leading specialist ofSector of Forestry and Forestation), Alimdjan Bektemirov (Head of the Sector ofBiological Diversity), Venera Surappaeva and Kylychbek Jundubaev (LeadingSpecialists of the Sector of Biological Diversity) and Mairambek Aliev (Head of theSector of Forestry and Forestation).

This section provides a general description of ecological resources under thefollowing three aspects:

* Protected areas (and other sensitive habitats)* Fauna (animal species)* Flora (plant species)

The aspects are discussed below in terms of their national context and localsignificance within the Project area.

5.10.1 Ecological Overview

The Republic's diverse range of landscape types and microclimates leads to acorresponding diversity of ecosystems. Anthropogenic activity occupies only about 7% of the Republic's territory. The rest is represented by undisturbed or onlymoderately disturbed natural ecosystems, some 22 types of which have beendistinguished (Strategy and Action Plan to Preserve Biodiversity - MEE, 1998). Manyof these ecosystems (14 out of 22) are located at middle altitudes (2,000-3,000 mabove mean sea level). More than 20 % of Kyrgyzstan's area is located inpermafrost and unfit for habitation.

Despite its relatively small size, Kyrgyzstan has a very important regional ecologicalcontext, comprising part of the Central Asian global biodiversity hotspot. The countryis host to nearly 1 % of all known species on just 0.13 % of the world's landmass(UNECE, 2000). Walnut forests growing on the northern slopes of the western TienShan are unique and extremely rich in biodiversity.

1 Atlas of the Kyrgyz SSR, Vol.1 Natural Conditions and Resources. Editor-in-Chief Prof. M.M.Adyshev.Moscow. 1987.157 pages.EIA February 2004.doc 45

* * Cli~i JIACOBS~ IGlRR 't-I | HCG Environment

Nevertheless, a decline in the population of many species has become evident, with9.5 % of bird species and 18 % of mammal species currently considered to be at riskof extinction. A number of rare and valuable ecosystems have also nearlydisappeared, and forest cover has more than halved in the past 50 years (UNECEForestry Sector Report of Kyrgyzstan, 1994).

The Red Data Book of the Republic of Kyrgyzstan, published in 1985, is part of thecountry's national biodiversity policy but has not since been updated. Table 5.2 givesthe IUCN Red List categories and their Kyrgyz equivalent. The current status ofmany of the listed species is unknown and is likely to have suffered throughextensive hunting and overgrazing. It is therefore difficult from the listed categories todetermine the true risk faced by species in Kyrgyzstan.

Nevertheless, a decline in the population of many species has become evident, with9.5 % of bird species and 18.1 % of mammal species currently considered to be atrisk of extinction. A number of rare and valuable ecosystems have also nearlydisappeared, and forest cover has more than halved in the past 50 years (UNECEForestry Sector Report of Kyrgyzstan, 1994).

Table 5.2 IUCN Red List categories and their Kyrgyz equivalent

Red List Category EquivalenceIUCN Kyrgyzstan

Extinct (EX) Category 0Extinct in the Wild (EW) Category 0Critically Endangered (CR) Category 1Endangered (EN) Category 2Vulnerable (VU) Category 3Near threatened (NT) Category 2Least Concern (LC)Data Deficient (DD Category 4Not Evaluated (NE)

5.10.2 Protected Areas and Sensitive Habitats

National Context

Protected areas in Kyrgyzstan occupy only 3.9 % of the Republic. These comprisesix nature reserves (zapovedniki - equivalent to IUCN Category I), one national park(equivalent to IUCN Category II), 70 nature reserves (zakazniki- equivalent to IUCNCategory ll) and nature memorial parks grouped into forest, botanical, hunting andcomplex parks (equivalent to IUCN Category IV) and five nature parks. Thezapavednik are under the responsibility of the Ministry of Environment andEmergency Situations while the zakazniki and the national park are under theresponsibility of the State Forest Service.


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Regional/Local Context

There are no protected areas within or close to the Project area.

The closest Nature Reserve (Sary Chelek) is located approximately 75 km to thenorth-west of Mailuu-Suu. Sary Chelek is a Zapovednik (Strict Nature Reserve) andis located in Ak-Syi Raion of Jalal Abad Oblast approximately 60 km to the north-west of Tash Kumyr. The Reserve was established in 1959 and currently occupies23,868 ha (total area) and 18,080 ha (core area). It is divided into two sections: Arkyt(12,125 ha) and Sary Chelek (11,743 ha) and surrounded by a buffer zone. TheZapovednik lies 1,200 to 4,250 m above sea level. Average relative humidity is about60 % and annual rainfall is about 817 mm.

According to the State Forest Service, the most important protected areas in thevicinity of Mailuu-Suu are the Djilgyndy Forest and Jel-Tiybez Botanic Preserves.These zakazniki lie 45-50 km north-west and 25-30 km south-east of the study area,respectively. A brief description of their characteristics is given below.

Djilgyny Forest Preserve is located on the territory of the State Forest Reserves andwas established within the area of the Kara-Misty forest. It lies at an altitude ofbetween 700 and 1500m above sea level on the slopes of dry mountains, along thefoothills (adyrs) and on the forest hills. This Sanctuary was established to preserveand conserve natural pistachio bushes with large fruiting area of 300 ha. Inaccordance with data from 1975, the total area of the sanctuary is 300 ha, of which206 ha are covered with forest; 91.7 ha is under pasture and 1.2 ha comprises riversand lakes. Typical local fauna include hare, fox, porcupine and badger.

Jel-Tiybez Botanic Preserve is located on the territory of the State Forest Reservesand was established within the Aksy Forest. It has an area of 300 ha and wasestablished to preserve the type area of south semi-desert. Polecat, fox, hare ('tolayspecies), jerboa, Turkestani lynx and other small rodents inhabit the sanctuary.

5.10.3 Flora

National Context

Over 4,500 species of higher plants are reported to exist in Kyrgyzstan. Sixty-fiveplant species found in the Republic were listed as endangered by official sources in1985. By 1997 the number had risen to 71. A 1998 report of the Ministry ofEnvironment and Emergencies noted that over 300 species of wild plants wereclassified as rare and threatened. Of these, 125 species are endemic and 200 areclassified as valuable medical herbs.'

Approximately 4.2% of the country (843,000 ha) is estimated to be under forestcover, 101,600 ha of which are forest plantations. The natural forest is comprised ofmore than 120 woody species. The forests are mainly spruce (Picea schrenkiana)located on the northern ranges of the Tien Shan. Various species of Juniper grow onthe drier mountainsides in both the north and south. Forests of spruce, larch andjunipers occur within the Tien Shan and wildflowers including irises and edelweissbloom in the summer along the mountainsides and meadows.


r E1I JACOBS GIBB HCG Environment

The lower slopes of the mountains include ancient forest of wild walnut trees. Riversand lakeshores have dense thickets of elm, poplar, reeds and shrubs. The steppesof Kyrgyzstan are covered with grasses and low shrubs such as saxaul and in someareas have vast fields of wild poppies (including some opium poppies) and tulips.

A number of trees and plants species are diminishing or even disappearing inKyrgyzstan (including the Mailuu-Suu area) due to widespread wood cutting bycommunities for fuel, as well as extensive overgrazing by livestock.

Local Context

Information on local flora in the Project area was obtained from the Kyrgyz Atlas(1987) supplemented by field observations. The main types of vegetation and florathat occur in this area are described below. The Project area is broadly comprised offive phytogeographical units (areas exhibiting similar floral species). Their generalcharacteristics and typical flora are given in Table 5.3.

Table 5.3 Typical flora in the Project Area

Map Phytogeographical Typical FloraLegend Unit and Location33a Arable irrigated lands Wormwood (Artemisia prolixa) often with

located on the territory of ephmeroids, ephemers (Carex pachystylis,the former steppes and Poa bulbosa, Strigosella Africana), and otherdeserts. On the foothills communities (Climatoptera bracgiata, Stipaat Uzbek border. caucasica, Festuca sulcata) with significant

areas of Caragana kirghisorum.2g Desert. Mailuu-Suu, W Wormwood or absinthe (Artemisia prolixa)

side of river.9k Steppe - beard-grass Hordeum bulbosum with frequent (Aegilops

communities. S and N of triuncialis, Strigosella Africana, AlyssumMailuu-Suu. turkestanicum, Arenaria leptoclados,

Anisantha tectorum), occasional bushes of(Spiraea hypericifolia, Rosa spinosissima,Rosa kokanica, Caragana laeta) andoccasional Juniperus semiglobosa.

1a Desert (Halophytic). Salsova orientalisLower mountain slopesW of Kok-Tash.

23a Deciduous bushes. Kok- Pistacia veraTash region and SE ofMailuu-Suu.

Of species registered in the Kyrgyz Red Data Book, only Bladder fern (Coluteabrachyptera) is reportedly found in the study area. This species is classified as"threatened" (Category 2 - Institute of Biology and Soils, National Academy ofSciences). The Institute of Biology and Soils also notes that pistachio is the onlyeconomically important floral species in the Mailuu-Suu area.

According to the Kyrgyz Red Data Book a number of other rare and threatenedspecies (Categories 1 and 2) can be found in the vicinity of the Project area which


*+ t4 JACOBS GIBB it HCG Environment

includes the Fergana foothills. These taxa are listed in Table 5.4. This tableexcludes the many red list species found in the Fergana mountain range e.g.Babash-Ata mountains in which the Mailuu-Suu river has its source, as this region isconsidered to be outside the influence of the Project area.

Table 5.4 Rare and threatened flora in the vicinity of the Project Area

Taxa Extract from Kyrgyz Red Data Book

Lamyropappus Family: Asteraceae Dum (Compositae Giseke)schakaptaricus Status: Narrow-endemic, very rare species, creating the monotype

genus known only in Central AsiaArea: South Tien Shan - Fergana, Chatkal mountain ranges (riverbasins of Mailuu-Suu, Djiyde-Say), vicinities of Tash-Kumyr andShekaftar village (near Sumsar populated area)Reason for decline: overgrazing, ploughing up of virgin lands andbuilding works.

Scutellaria Family: Lamiaceae Lindl. (Labiatae Juss)andrachnoides Area: Along the Naryn river on the Kyrgyz foothills of the Fergana valleyVved. Status: Rare narrow-endemic specimenIridodicum Family: Iriskolpakowii Status: Decreasing in number species, Category 3

Area: Fergana mountain range, in particular the Mailuu-Suu riverbasinReason for decline: Overgrazing, digging out by the populationduring the spring period

5.10.4 Fauna

National Context

Wildlife biodiversity in the Republic of Kyrgyzstan is very high. Over 500 species ofvertebrates, including 83 mammals, 368 reptiles and 75 fishes are reported, alongwith 2,000 species of fungi and over 3,000 insect species. Thirteen mammals, 33birds, two fish and 18 insect species found in the Republic are listed as endangeredspecies in the Red Data Book published in 1985. The current number is likely to beconsiderably higher.

Loss of habitat (deforestation) and competition with livestock, as well as hunting andpoaching, have caused the number of species to dwindle. The most critical situationinvolves protecting the habitats and populations of the most valuable species (botheconomically and scientifically) of large mammals such as mountain goats, djeyran,mountain sheep, snow leopard, tien-shan bear, lynx and Menzbir's marmot.

Hunting is allowed in about 75 % of the country. Most (but not all) of the hunting isregulated by the Central Administrative Board of Hunting and Hunting Supervisionwithin the Ministry of Environment and Emergencies. The primary game species arecapricorn (mountain goat), Marco Polo sheep, roe deer, wild boar, wolf, marmot, fox,badger, musk-rat, hare, weasel, squirrel, Himalayan snowcock, chukar partridge,pheasant, quail, pigeon and waterfowl. Quotas are set for each species (generally 10% of the population).


* * +i4 E IJACOBSf IBB VI HCG Environment* r * uw

Local Context

Information on mammals, birds, reptiles, amphibians and invertebrates in the Projectarea was obtained from the Kyrgyz Atlas (1987) supplemented by field observations.

A generalised faunal classification of the area around Mailuu-Suu is shown in Table5.5 which also lists the dominant faunal species by landscape type. The Project areaencompasses a number of distinct zoogeographical regions from the foothills of theFergana valley up through the Mailuu-Suu gorge to the sub-alpine areas on higherground beyond the northern village of Sarybiya.

Table 5.5 Dominant faunal species by landscape type in the Project Area

Map Landscape Type and Location Typical FaunaLegendla Desert and semi-desert (foothill Grey gekkos (Cytopodion russowi)

plains). SW of Kok-Tash. and other lizards4a Cultivated land on steppes and Gophers and other rodents

desert. Uzbek border region.5a Desert and semi-desert. Reptiles: Turkestani agama, grey

Mailuu-Suu, W side of river. giant lizard; Amphibia: toad; Birds:wheatear; field pipit; Mammals:rats, jerboa, house mouse, relicgopher (Spemophi;ius relictus),hare-tolai, slepushonka (Ellobiustalpinus)(mole); Birds: Robins(Oenanthe isabelina and Oenanthepleshanka), field-lark, pipits,sandgrouse.

6 Steppe (gorge/foothill). Reptiles: lizards, snakes; Birds:Mailuu-Suu, E side of river and bustard, steppe eagle, harrier (hen-N of Sarybiya. harrier, meadow harrier), lesser

kestrel, daurian partridge, commonquail, corncrake, roller, hoopoe,sand-martin, skylarks (field-lark,steppe-lark, tufted lark), shrike,linnet, jackdaw, common turtledove;Mammals: badger, weasel, fox,grey hamster, gopher, Tolai hare,big-eared hedgehog, small shrew.

12 Sub-alpine meadows. Reptiles: Common grass-snakeE of Sarybiya. (natrix tesselata), lizards (including

13 b Alpine meadows. The Mailuu- Assymblepharus alaicus);Suu River valley. Mammals: mouse, gophers, Tolai

hare (Lepus capensis), fox,porcupine, stoat; Birds: eagles,hawk, bearded partridge, chukar,quail, pigeon, pheasant.

14 Deciduous bushes. Mammals: porcupine, badger, fox,Kok-Tash region and SE of jackal, slepushonka (mole); Birds:Mailuu-Suu. kestrel, hobby, nightingale, Cetti's


* * Ej4 JA(CflRBS~IBB ~Lt IHCG Environment

Bush warbler, shrikes (red-backed,rufous-tailed), white-throated Dipper,brown Dipper, Blue-whistlingThrush, common wood Pigeon(Columba polumbus), EurasianCollared Dove (usually at thepopulated areas), (black) kite,Egyptian vulture, meadow harrier,sparrows and snowfinches.

Common birds in the Mailuu-Suu area are: Daurian Partridge, chukar, common quail(also customarily bred in farms by the Uzbek population), blue whistling thrush, andcommon kestrel.

According to the Institute of Biology, a large colony of white storks (Ciconia ciconia)has been registered by scientists in the Mailuu-Suu valley. These are classifiedCategory 2 in the Red Data Book. Approximately 16 nests of this bird were observedin the vicinity of Kochkor-Ata situated 25-27 km south-west from Mailuu-Suu (at theKyrgyz-Uzbek boundary), which is within the zone of the influence of the proposedinterventions. The black stork (Ciconia nigra) is not resident in the Mailuu-Suu area,but its migration route usually passes through this territory.

Typical mammals include: fox, roedeer (Capreolus capreolus), slepushonka (localspecies of mole), badger, porcupine, gopher (ground squirrel) and jerboa. Thebadger and porcupine are not yet listed in the Red Data Book, but Kyrgyz scientistsare currently studying the status of these mammals to decide what measures have tobe taken in order to protect their dwindling numbers. At present they are consideredto be rated Category 4.

About 80 % of all Kyrgyz birds of prey can be found in the higher mountain areasabove the Mailuu-Suu valley. Among these are the following species listed in theRed Data Book:

* Short-toed snake eagle (Category 2);* Golden eagle (Category 2/3);* Lammergeier (Category 3);* Himalayan Griffon (Category 2/3);* Saker Falcon (Category 1).

During the November field trip a number of Lammergeiers were seen flying highabove the Mailuu-Suu valley. It was also reported that a Saker Falcon was seen inthe vicinity of Uzgen town in 2004.

In summary, based on the Kyrgyz Red Data Book and discussions with the ForestryService, the Project area itself is likely to contain the following Red List species:

* Desert Monitor Lizard (Varanus griseus) - Category 1 (CriticallyEndangered);

* White stork (Ciconia ciconia) - Category 2 (Endangered);* Lammergeier (Gypaetus barbatus) - Category 3 (Vulnerable);


JACOBS GIBB HCG Environment

* Badger (Meles meles) - Category 3/4 (Vulnerable);* Porcupine (Hystrix indica) - Category 3/4 (Vulnerable);* A snake (Coluberkarelini) - Category 1/2 (Endangered).

Fish Species

Within water reservoirs of the region it is possible to find Amu-Darya trout, mudfish(snake heads), pickerel, Syr-Darya dace and Turkestani barbel, although thesespecies have almost completely disappeared from the rivers (see: *Salikhov,Vundzettel, 1986). Grass (Chinese) and silver carps have self-reproducing shoals inthe middle current of the Syr-Darya river and its tributaries.

According to Dr. Kustariova, the Syr-Darya River and its main tributaries lost theircommercial value in terms of fishing due to regulated run-off and irrigation needs.Fishing now is restricted to artificial water reservoirs and lakes as well as at specialfish-farming ponds. Table 5.6 lists fish species found in rivers flowing in the Mailuu-Suu area.

Table 5.6 Fish species in rivers flowing in the Mailuu-Suu area

(Note: the status of several species is indicated as follows: rare, Red Data Book, etc; theothers are common species).

# Russian Name English Latin Name Area of Habitat and/orName Current Status

1. KpacHonepKa Rudd Scadinius Does not reach the boundarieserythrophthalmus of Kyrgyzstan (see: **Turdakov,(L.) 1963)

2. Jlblcaq, Pike, Asp Aspiolucius Naryn and Syr-Darya riversU4yKoBeAHbIlA Caspian esocinus (Kessler)Kepex

3. Apanbc=i40 Asp Aral Aspius iblioides Does not reach the boundariesKpacHory6blO (Kessler) of Kyrgyzstan (see: Turdakov,wepex 1963)

4. TypKecTaHcKWO Gudgeon Gobio gobio The Kara-Darya river, belownecKapb lepidolaemus Uzgen town, near Uchkurgan

Kessler town5. O6bIKHoBeHHaq Marinka Schizothorax The Naryn river and all

MapWHKa intermedus tributaries, Kara-Darya riverMcClelland from the source (see: Turdakov,

1963)6. PeAKKoLewyWilaTbIO Osman Diptychus The Kara-Darya river, all

ocMaH Cesep4oBa sewerowi Kessler tributaries, including the Narynriver

7. nonocaTa5 Bystryanka, Alburnoides The Kara-Darya up to Uzgen6bIcTpIHKa riffle minnow taeniatus town, the Syr-Darya river up to

(Kessler) Uchkuran town (Turdakov,1963)8. OcTpony-IKa Ostroluchka Capoetobrama Kara-Darya (see: ***Dementiev,

Kuschakewitschi 1935; Turdakov, 1963)typ. (Kessler)

9. Ca3aH, Kapn Sazan (carp) Cyprinus carpio L. Naryn (up to Uchkurgan), Kara-Darya, Kugart (below the VillageOktyabrskoe) (Turdakov, 1963)


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10 TW6eTCK14 roneLA Tibetan Noemacheilus Upper tributaries of Kara-DaryaLoach stoliczkai (Kara-Unkur, Kugart), and rivers

Steindacher of the south Fergana valley11 CepblO ronel, Grey Loach Noemacheilus Kara-Darya river, above the

dorsalis (Kessler) Khanabad town. Status: Rarespecies (Turdakov, 1963)

12AMygapbWHcKWO Amu-Darya Noemacheilus Kara-Darya (at the junction) withronei4 Loach oxianus Kessler Kyzyl-Unkur. Status: Rare

species (Turdakov, 1963)13 ByxapcKwO roneLA Bukhara Noemacheils Naryn river near Uchkurgan

Loach amudariensis town. Status: Rare species.Rass

14 FoneLA Loach Noemacheils Common throughout the wholeKywaKeBw4a Kuschakewitschi Naryn-Syr-Darya river systems

Herzen.15ApanbcKas Spiny loach Cobitis aurata Kara-Darya river. Status: Large

u4wnoBKa aralensis Kessler in number.16 COM Sheatfish, Silurus glanuis L. Kara-Darya river from the mouth

catfish of Kurshab-Darya, Naryn riverup to Uchkurgan town

17TypKecTaHcKtlO Turkestan Glyptosternum Karyn, Kara-Darya, Kugart,COMI4K somik reticulatum Kara-Unkur; frequent in vicinity

McClelland of Uzgen town. Status: Memberof the Red Data Book.

18 TypKecTaHcKAR Puffin grubby Cottus spiulosus Kurshab river (tributary of thenogKaMeHu4WK Kessler Kara-Darya river)

19 raM6y3WF Mosquito fish Gambusia affiis In all supplementary water(Cir.) reservoirs located in the flood

plains of the Syr-Darya andNaryn rivers

* Salikhov T.V., Vundzettel M.F. Composition of ichtyofauna of the Syr-Darya river basinunder anthropogenic impact. Biological basics of the fish industry in the water reservoirs ofCentral Asia and Kazakhstan. - Ashgabad. 1986.** Turdakov F.A. Fish in Kirghizia. Frunze, 1963.***Dementiev P.P. Preliminary list of fish species in Kirghizia./ Proceedings of the StateZoological Museum under the Lomonosov's Moscow State University. Moscow. 1935.

5.10.5 Summary

Despite extensive human exploitation, over-grazing and agricultural cultivation of thevalley areas, high species diversity is typical for the Mailuu-Suu area, as for otherparts of the foothills region of the Fergana valley, although with possibly lessindividual species represented here as in other similar areas.

The Mailuu-Suu area is situated in the foothills region and potentially containssignificant numbers of rare and endangered fauna and flora species listed in theKyrgyz Red Data Book. The Fergana valley to the south of the Project area isagriculturally well developed and less species-diverse as a result. The species inthis area succeed by virtue of their large colonies.

Interventions to mitigate the risk of natural disasters in the Mailuu-Suu area will needto be sensitive to local ecology and be planned to include measures to avoidsignificant adverse effects.


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5.11 Cultural Heritage and Archaeology

5.11.1 Introduction

The Kyrgyzstan National Academy of Sciences was contacted to obtain informationon historical and cultural heritage sites of national and international importancelocated in the south part of Kyrgyzstan, and specifically in the study area comprisingthe Mailuu-Suu valley and the adjoining north-eastern part of the Fergana Valley.

The summary of the cultural heritage sites in the Project area given below includesknown archaeological sites and historical monuments. Archaeological sites arenormally considered to be historical resources situated below ground and thereforenot visible unless excavated or otherwise disturbed. Monuments are visible extanthistorical structures situated above ground.

The value of an important historic monument is closely associated with its settingand location including the surrounding landscape. Architecture monuments of SouthKyrgyzstan have not only high artistic value, but also spiritual importance e.g. holymazaars are places frequented by numerous Moslem-pilgrims worshippers from theentire Fergana valley.

The cultural heritage and archaeological review was conducted by Dr AntoninaZakharova, Chief Department of Inter-Ethnic Relations, Institute of Social Sciences,South Division of National Academy of Sciences, based in Osh. The study drew onpublished work conducted by a large number of national and international scholars.

5.11.2 Historical and Cultural Heritage Context of the Fergana Valley

The south of Kyrgyzstan comprises three parts - Osh, Djalal-Abad, and BatkenOblasts - and occupies a significant part of the Fergana Valley and contiguousmountain areas. More than 2 million people live in this area, which constitutes abouthalf the country's population.

The history of the Fergana valley, including the south part of modern Kyrgyzstan,stretches back several thousands years. The population of the agricultural Ferganaregion and that of the mountain valleys of the country's southern part, experiencedthe same periods of historical development as the region was a part of the sameancient state.

Archaeological studies have demonstrated that this area has been a zone of humansettlement by primitive people from the early Paleolithic period about 500,000 yearsago. Mountain valleys of Southern Kyrgyzstan were widely developed by man in theMustier period (middle Paleolithic - 100,000-40,000 years ago).

Later, during the Mesolithic and Neolithic periods (7,000-4,000 years BC), theproductive economy and cultural development that arose in this area is welldemonstrated in the Chust and Shorobashat cultures which emerged during the lateBronze Age (end of the 2nd millennium BC). According to the archaeologist Yu.A.Zadneprovsky, there have been 80 ancient settlements of the Chust culture (lateBronze Age) discovered in this region. Half of these are located in the territory ofSouth Kyrgyzstan.


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During the 1st millennium BC, several caravanserai of the Great Silk Road traversedthrough the territory of this region. Close trade links with China, India and theEastern provinces of the Roman Empire promoted exchange and interrelationsbetween the various cultures. As a result, a new phase of cultural developmentemerged the zone centered within the Fergana Valley, including the southern part ofmodern Kyrgyzstan which occupies a significant part of this region.

The earliest written records of this ancient region come from the ChineseAmbassador Chzhan Tsyan (128 BC) who refers to about 70 small and large townsin the region. The vivid descriptions of the town centers of the Fergana area are alsocaptured by later Arabic writers and travelers of the 9th_1 oth centuries: IbnHordadbekh, Al istahri, lbn Haukal, Al Mukaddasi, lbn Fakikh and others. After theArabic conquest, Fergana was under the power of the Samanids, Karakhanids,Sheibanids and Timurids. In the 18 th_19 th centuries, Fergana was a part of KokanKhanate. In 1876 it was conquered by the Russian Empire.

Each epoch left its own layer of historical and cultural heritage, the study of whichhas been the subject of many scientific expeditions to Fergana and Eastern Sub-Fergana area by contemporary Kyrgyz and international ethnologists, archaeologistsand anthropologists. As a result, more than 350 archaeological sites andarchitectural monuments have been found in Southern Kyrgyzstan that reflect thehistory of the region since the Early Paleolithic period (about 500,000 years ago, e.g.Sol-Unkur cave) up to modern times (end of 1 gth and beginning of 20th centuries).

The total number of cultural heritage sites numbers more than 550. This includes allthe ancient town sites, petroglyphs, occupied houses of the 1gth century,architectural monuments of the first half of the 20th century, as well as sculptureserected in squares, streets and parks commemorating outstanding political andpublic figures of the Kyrgyz people.

This number refers only to the territory of Southern Kyrgyzstan. The list ofmonuments of historical and cultural heritage for the whole of the Fergana valley islikely to exceed several thousand. The majority of these monuments are unique andhave great international cultural and historical value.

5.11.3 Cultural Heritage Sites in the Vicinity of Mailuu-Suu

Table 5.7 lists the most significant cultural heritage resources (ancient monumentsand archaeological sites) located within 50 km of the Mailuu-Suu Project area. Thetable is based on available information, including studies conducted by national andinternational scholars.

Table 5.7 Major cultural heritage sites in the vicinity of Mailuu-Suu

Description LocationAncient MonumentsStone sculptured figure in the vicinity of 35 km from Mailuu-Suu town.Shamaldy-SayA Stone Age monument. 3 km from Tashkumyr tow, 32

km from Mailuu-Suu


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The ancient urban site of Hait-Debe of Shoro- Located several km from theBashat culture; it has a citadel and a fence Savay site.(wall) with towers.Town sites in Kurshab, Karadarya andKaravan of Chust and Shoro-Bashat cultures.Kasan - strongly fortified small fortress, with At Uzbekistan boundary, in Ala-remnants of the ancient town. Kasan is located Buka area, Djalal-Abad Oblast,north of the modern town of Kasansay. 95km north-west of Mailuu-Suu.Arstanbap (Arslanbob) mazaar (built on a At the center of Arstanbapgrave construction) is a historical and village, 32 km north-east ofarchitectural monument of the 16th century; it is Mailuu-Suu area.a mausoleum with arched overhead coversand has been restored several times.Uzgen architectural complex - three Uzgen townmausoleums and a tower (minaret) of the 11th-12th centuries, in the Karakhanids period.Uzgen formerly was a capital of theKarakhanids empire.Archaeological SitesSite of mediaeval settlement. 30 km south-west of Mailuu-Suu

town, on the right bank of theNaryn river.

A 5th century BC settlement. 28 km south of Mailuu-Suutown.

A 5th century BC settlement. 32 km south-east of Mailuu-Suutown.

Mediaeval settlement in Kochkor-Ata area. 25 km south of Mailuu-Suu.Shoro-Bashat - site of an ancient town from On right bank of Diazy river, 84th-i st century BC. km from Uzgen town.Ancient site of Savay of Shoro-Bashat culture 32 km from Djalal-Abad town.located in northern part of Kara-Suu oasis.

The nature and location of the currently known historical monuments andarchaeological sites is evidence that this part of the Fergana valley has beenintensively inhabited over at least the last few millennia. The large number of knownarchaeological finds in the vicinity of Mailuu-Suu demonstrates that the area was animportant area for human settlement. The recent 3rd Millennium anniversarycelebrations in Osh (the regional capital of southern Kyrgyzstan) are testament to theimportant historical cultural heritage of the region.

5.11.4 Cultural Heritage Sites at Risk within the Project Area

No evidence of significant cultural heritage sites has been identified within the upperpart of the Project area (villages and towns in the Mailuu-Suu valley withinKyrgyzstan). Available information is sparse as historically the area was a closedterritory and classified secret under former Soviet rule. Table 5.7 indicates that thereare also no known monuments or archaeological sites adjacent to the course of theMailuu-Suu River in the lower part of the Project area.

The area downstream of Mailuu-Suu is included in the Project area as this is at riskin the event of a major natural disaster such as a flood or major displacement of atailing site into the Mailuu-Suu River. In such a scenario, radionuclides and otherEIA February 2004.doc 56

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toxic components of the tailings could contaminate river sediments along the courseof the downstream river basin. The contamination would be reworked and dispersedover a wider area during subsequent spring flood events thus affecting the widerflood plain.

As is evident from Table 5.7, historical settlements tend to be located adjacent torivers or in islands within the flood plain. Consequently, archaeological resourcessituated along the banks of rivers downstream of Mailuu-Suu would be at greatestrisk of radiological contamination in the event of a major tailings spill. Such an eventwould render archaeological investigations of any future finds in the affected areadifficult and hazardous to perform.

The area most at risk from deposition of contaminated sediments is the Mailuu-Suuriver flood plain and irrigated areas immediately downstream of the Uzbek border inthe flat valley region north of Andijon. To a lesser extent (and depending on themagnitude of the spill), areas in the flood plain further downstream could also be atrisk e.g. along the banks of the Naryn and Syr-Darya rivers).

The review identified no known evidence of specific monuments or archaeologicalfinds along the banks of the Mailuu-Suu River within this part of the Fergana Valley.However, archaeological and historical research conducted in the territory of Mailuu-Suu has not been considered a priority. This may explain the rather limited list ofcurrently known archaeologically important sites downstream of Mailuu-Suu. Withproper archaeological and historical studies a number of new finds are likely befound.

In summary, no cultural heritage resources of regional or national importance havebeen identified within the Project area, possibly due to limited academic studies inthe area. However, based on the rich heritage of archaeological and cultural findswithin the Fergana region, there is a strong likelihood that undiscoveredarchaeological remains exist along the course of the Mailuu-Suu river in the FerganaValley. Thus there is potential for significant archaeological finds to be at risk from asevere flood/pollution event in the area of Mailuu-Suu involving uranium tailings andthe downstream dispersal of radiologically contaminated sediment.

5.12 Socio-Economic Baseline

This section has been prepared on the basis of official data2 from the NationalStatistics Committee of the Kyrgyz Republic (Bishkek, 2002) as well as statisticalinformation provided by the Mailuu-Suu town public sector. A detailed evaluation ofthe socioeconomic baseline for the Mailuu-Suu area is given in the World BankSocial Assessment Report3.

5.12.1 Regional Context

The Kyrgyz Republic is one of the poor countries in transition, where the averageGDP index is 400 USD per capita. In 1989 on the eve of independence andtransition to the market economy, about 33% of the local population had a monthlyincome lower than the minimum subsistence level. Since that time the poverty level

2 Demographic Year Book of the Kyrgyz Republic, 1997- 2001, Bishkek, 2002.Social Assessment for Mailuu-Suu Disaster Mitigation Project, H. Lemel, January 2004, World Bank


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has increased dramatically and now affects more than half of the country (Table 5.8).As a result, by 1994 the Kyrgyz Republic was placed within the group of poorestcountries according to the World Bank classification.

Table 5.8 Poverty Levels by Oblast and in Bishkek (% of population)4

Oblast Poor people Extremely poor_Bishkek 6.0 0.8

Issyk-Kul 64.5 23.8Djalal-Abad 73.5 58.7Naryn 90.5 58.7Osh 65.7 10.1Talas 67.0 23.0Chui Oblast 26.6 3.5Batken - -

An especially high level of poverty is typical for the rural population. More than 55 %of the country's population falls into the poverty category, 80 % of which live in ruralareas. The population within the mountainous regions of the Kyrgyz Republic reliesto a great extent on subsistence farming, and survives by growing crops (mainlypotato), stock farming, and collection of wild herbs from the forest.

5.12.2 Demographics and Population

The population density in Djalal-Abad Oblast is 27 persons/km2 , which is lower thanneighboring Osh (42 persons/kM2) and Chui Oblasts (77 persons/kM2), and slightlyabove the national average.

In 2002, the population of the Mailuu-Suu area was 22,858. In the town itself therewere 17,045 inhabitants with a working population of 13,417, of which 47.5 % aremales and 52.5 % females. The ethnic composition of the population of Mailuu-Suutown at the beginning of 2003 comprised Kyrgyz (12,761), Russians (3,542), Uzbeks(1,213) and Tatars (1,134).

Based on data for the start of 2003, the prevailing ethnic groups in Djalal-AbadOblast are Kyrgyz (70 %) and Uzbek (24.4 %) with less than 2 % Russians. Bycontrast, in Mailuu-Suu the Russian proportion (17.7 %) is second largest afterKyrgyz, and significantly exceeds the Uzbek (6.6 %) and Tatar (5.7 %) ethnicgroups.

The current ethnic distribution in Mailuu-Suu reflects the former Soviet practice ofestablishing a strong local presence of persons from the European part of the formerSoviet Union, especially in restricted areas such as Mailuu-Suu where uraniummining and processing required the influx of a specialized technical, industrial andmilitary workforce. With the disintegration of the USSR in the early 1990s, all localmining administration activities stopped, and many of the specialists as well asmilitary personnel were dismissed and consequently left Kyrgyzstan.

For economic reasons, there has been a net outward migration from the Mailuu-Suuarea and this continues, especially for the Russian population. Over the decade of

4 Poverty Monitoring in Kyrgyzstan (1996/97)


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1990-2000, Mailuu-Suu lost about a third of its population, with a major emigrationoccurring between 1993-5. In 1999-2000 alone, Mailuu-Suu's population dropped by13 %. Thus in 2001, the outward migration of the Kyrgyz population from Jalal-AbadOblast comprised 132 Uzbeks and 136 Tatars, while 550 Russians left the Oblastover the same period. This trend continues in the Mailuu-Suu area: out of a total of362 persons leaving in January-October 2003, 137 were Russian, 101 were Kyrgyzand 49 Tatar. The major part of the population leaves Kyrgyzstan for other CIScountries.

5.12.3 Employment and Land Use

Mailuu-Suu town was officially established in 1956 and is the main town in the area,acting as the commercial and industrial centre. A number of smaller villages arelocated up and down the valley, the main ones comprising Sarabiya and Kara-Agachto the north and Kok-Tash to the south of the town.

Employment in the Mailuu-Suu area is mainly restricted to services, agriculture andindustry. The major employer is the Mailuu-Suu Electric Lamp Plant, which employes4356 people and is the largest light bulb factory in the Kyrgyz Republic. This issupplemented by smaller organizations including "Isolit" plant, garment factory, JSV"Kulazyk", JSC "Bereke" and Vodokanal (Water Supply) system. There are also anumber of small industrial operations in Mailuu-Suu including a bakery, meatprocessing factory and clothing industry. Many people are employed in the servicesector, including small retail outlets, cafes and restaurants. The underlying oildeposits are exploited locally with oil pumped from small wells situated along thevalley and taken to a refinery in Jalal-Abad.

Some citizens are employed at the educational and health care sectors. As of 1stNovember 2003, the town has 9 secondary schools (with 5028 enrolled students), abranch of the Institute of Economy and Management, a college, a medical schooland a Lyceum with 330 teachers and 1619 students.

According to statistics from the Mailuu-Suu town sector, the official unemploymentlevel is relatively low and comprises 11.7% of the total population (or 1564 persons),but most likely the real unemployment level is higher. A social welfare systemproviding allowances for disabled adults and children and pensioners, is anotherimportant source of income for Mailuu-Suu residents.

A large part of the community relies on secondary income to support themselves.This comes from two sources - market gardening and subsistence farming (cropsand animal husbandry). The average Mailuu-Suu household owns 5-12 chickens, 1-2 cows and about 2-6 goats and sheep (ADB, 2003)5. Income is generated throughthe informal sale of agricultural produce from crops and livestock. Some householdsearn additional income from other private economic activity such as retailbusinesses, small clothing firms and informal jobs.

5.12.4 Public Health

National and Regional Level

5 Kyrgyz Republic Environmental Management Capacity Building Project, #3499-KGZ, December 2002, Vol 11 - TheMailuu-Suu Case Studies, Asian Development Bank


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In comparison with 1997, the general mortality rate in Kyrgyzstan decreased by 10%and in 2001 comprised 6.6 per 1000 persons. This represented the lowest indexsince 1997. According to official data, the morbidity rate in the republic for the lastfew years has not significantly changed. A similar picture has been observed inDjalal-Abad Oblast as well as Mailuu-Suu town.

For the country as a whole, diseases of the blood circulation system remain the mainreason for mortality (47 % of deaths in 2001), followed by respiratory diseases (11%), traumas, poisonings and related aspects (10 %), neoplasms (9 %), infectiousand parasitical diseases and digestive system ailments (5-6 %).

The above findings are also reflected in mortality data for Djalal-Abad Oblast.However, it is notable that the various kinds of tumors have increased significantly inthe Oblast from 269 in 1997 to 368 in 2001 (equivalent to 31.8 and 40.9 per 100,000,respectively). This is against a background of a static or slightly increasing tumor-related mortality rate for Kyrgyzstan as a whole.

An important characteristic of the population's health is infant mortality. InKyrgyzstan, between 2,100 and 2,900 newborn infants die annually in their first yeardue to various causes. Infant mortality is decreasing but remains comparatively high(22.7 per 1000 births in 2001 compared with 28.2 per 1000 in 1997). The mortalityrate of mothers also remains high (43.8 per 100,000 births in 2001). For Djalal-Abadoblast, the infant mortality rate per 100,000 during the last few years has shown adecrease from 27.8 (in 1997) to 18.3 (in 2001) and remains below the nationalaverage. In the Mailuu-Suu area, the rate has also steadily decreased.

Local Level

Information on health statistics for the Mailuu-Suu area was provided by ProfessorAbdukhalim Raimjanov, Professor of Hematology at the Centre of Hematology,Bishkek.

Based on a review of morbidity and mortality statistics, the Mailuu-Suu area ischaracterized by a variety of diseases, the most prevalent of which are congenitalabnormalities, goitre and diseases of the organs.

For example, 200 women out of 410 gave birth to children with congenital anemia.There have been 115 people treated at the in-patient department for cancer (dermal,breast, pulmonary, lung and stomach are the most frequent). Of the 4135 peopleworking at the Mailuu-Suu Electric Light Factory, 90 are registered by the Companyphysician as undergoing treatment for incipient cancer problems. In Sarabiya,because of the high radiological exposure, two children have died because ofleukemia, a further two have died from brain tumor, and a further 9 children aresuffering from blood clots in the brain.

There have been no epidemiological studies over the last 15 years neither has therebeen any blood testing of persons at risk from exposure to tailings. Lung X-rays(e.g. for early detection of malignant cancer tumors) have not been regularlyprovided and much of the equipment for radiological health screening is out-of-date.

A study by the Institute of Oncology revealed that out of 1246 children and 3266adults surveyed in Mailuu-Suu, about 600 are suffering from incipient cancer


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problems, 23 of which have a high likelihood of cancer. The most prevalent cancersare stomach followed by skin and lung. According to data from the Institute, theincidence of cancer in Mailuu-Suu is three times higher than in Jalal-Abad.

5.12.5 Infrastructure and Services

The road infrastructure leading into the Mailuu-Suu district is comparatively welldeveloped. The main road from Jalal-Abad intersects the main tarred road runningsouth from Mailuu-Suu to Madaniyat near the Uzbekistan border and onto Andijan.A dirt road runs through Kok-Tash and up the valley to Mailuu-Suu. Poor quality dirroads connect Mailuu-Suu town to the northern villages of Kara-Agach and Sary-Beya. These roads are frequently cut off by landslides and mudflows, particular inthe spring following heavy rains.

Mailuu-Suu town and Kara-Agach have a piped water supply from a water treatmentplant (largely non-functional) situated about 3 km upstream from Sara-Beya. Thewater is discharged downstream by gravity in 3 water pipes (diameter 350 mm)providing a daily production of about 40,000 m3 (maximum 60,000 m3). The waterpipes are partly buried along both sides of the Mailuu-Suu River valley andreportedly suffer intermittent damage due to landslide activity. Sara-Beya is supplieddirectly by good quality springs. Residents downstream from Kok-Tash continue totake domestic water directly from the river.

A coal-fired power station is situated just south of Sara-Beya. The facility dates fromSoviet time and is working at a fraction of its design capacity.

6 Scoping of Potential Impacts

6.1 Introduction

A high level scoping procedure identified potential impacts of the proposedinterventions. This involved defining the intervention location, the associated tasksand activities, and determining the likelihood of an impact (adverse or beneficial) thatcould occur under each of the relevant environmental parameters (air quality, waterquality etc) without any mitigation measures.

The impacts were grouped under three general categories - physical, biological andsocio-economic. Construction and operational phase impacts were consideredseparately. The review also addressed potential environmental enhancementmeasures and any additional considerations as warranted.

Potential impacts from the Project were considered under the following categories:

Direct Impacts - i.e., those directly due to the Project itself such as the conversionof land previously used for other purposes. The construction activities of the Projectwill largely be restricted to areas within the Mailuu-Suu valley, principally along orclose to the existing road alignment. Most of the direct impacts will take place inareas identified for landslide stabilization and riverbed strengthening measures.


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Indirect Impacts - i.e. those resulting from activities arising from the Project, but notdirectly attributable to it. The use of gravel for stabilizing tailing dams, for example,may cause indirect impacts from increased quarrying operations.

Cumulative Impacts - i.e., impacts which in combination exert an additive influence.A single intervention may not exert a significant environmental impact, but if severalinterventions are developed in the same area, or occur at the same time, thecumulative or additive effect could be large. Several simultaneous interventions ontailings next to a riverbank could, in conjunction with discharge of diverted surfacewater could, for example, result in a significant deterioration of river water quality.

Impacts in all three categories may be either:

Short-term - i.e., impacts which occur during construction and affect land use, waterquality and other factors. Many of these impacts will, however, be short-lived andwithout long-lasting effects. Even the effects of some relatively significant impactssuch as earth excavations, for example, may be eventually erased if appropriatemitigation actions are taken.

Long-term - i.e. intervention impacts that could, for example, affect regional landuse and development patterns or cause leakage of hazardous substances andflooding if interventions are poorly designed. Long-term negative impacts can alsoresult from the loss of agricultural land to other land uses; air and water pollution;problems associated with scattered earth works; and haphazard industrial growth.The fact that the NDMP involves the avoidance of existing disaster scenarios (e.g.tailings failure) reduces the potential for this type of impact.

Both short-term and long-term impacts may be either beneficial or adverse. Short-term positive impacts could include, for example, the generation of employmentopportunities during the construction period. Long-term benefits could includeenhanced development opportunities, better security in terms of natural hazards andimproved transport services.

It has been recognized that the most efficient and cost-effective way to ensure thatconstruction works are environmentally sound is to include these requirements in theconstruction contract provisions. The Project will follow the standard specificationand General Conditions of Contract for construction contract purposes, as will bedecided in the detailed design stage of the Project. Provisions for the protection ofthe environment are included in the EMP, which specifies the provision of mitigationmeasures and good management practice.

6.2 Do Nothing Option

In the Mailuu-Suu area there are several uranium tailings which contain materialsthat are radioactive and chemically toxic (radionuclides and heavy metals). Althoughthe tailings sites currently present only a low-level threat, the serious danger comesif their contents are dispersed into the environment.

The Mailuu-Suu area is prone to earthquakes, as well as landslides and floods.There are more than 200 places around Mailuu-Suu town which are prone tolandslides. Three of these, named Tectonic, Koi-Tash and Isolit, present the highestpotential for activation and sliding down the valley slopes, and impacting tailings.


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A major emergency situation occurred in the valley in 1958 when 60,000 m3 ofradioactive waste was washed away after flooding breached a protective dam onTailing 7. Since then, there have been several landslides caused by earthquakesresulting in wash-out, partial destruction of waste dumps and leakage of pollutedmaterials. Also floods have partly destroyed some of the tailings.

There are two tailings sites near the river, which contain "relatively high" levels ofuranium decay products. The hazardous substances include thorium, uranium,radium, selenium and lead, which have the potential to cause serious long-termpollution and health hazards. Sudden dispersion of pollution from some of thetailings could make river water in the Fergana Valley unfit to drink and use forirrigation purposes.

Downstream of Mailuu-Suu lies the Fergana Valley, with over 6 million people fromthree countries, as well as major rice and cotton plantations. The short-terminterventions seek to prevent leakage from the tailings and to stabilize the high-risklandslides. The only long-term solution for tailings that pose a risk to the river is tomove these to a safe disposal cell using modern hazardous waste technologies.

The Project aims at preventing leakage from tailings and waste rock dumps as wellas reducing the vulnerability of the area from landslides. Consequently, the Projecthas a positive impact on the environment if implemented properly. The "do nothing"alternative is not a sustainable option for problems in the area.

6.3 Scoping Environmental Impacts of Potential Interventions

Scoping environmental impacts of potential interventions were done using a matrix,where impacts were assessed considering different media - physical, biological andsocio-economic.

The scoping exercise showed that during the construction works the main negativeenvironmental impacts are related to:

* Surface water pollution (suspended sediments);* Erosion of slopes (run-off erosion and damaged vegetation cover);* Socio-economic impacts e.g. noise, dust and traffic interruption from bulldozers,

excavators and trucks on public roads and construction sites.

The overall aim of the Project is to reduce the risks from landslides and release ofdangerous substances (radionuclides, heavy metals) through failure or seepage fromtailings. Consequently, it is expected that when completed, the Project willsignificantly ameliorate the health and safety situation of the local population.

Results of the scoping exercise for the construction and operational phases areshown in Tables 6.1 and 6.2, respectively.

(See Tables 6.1 and 6.2 in Annex and separate files)


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Tailings Interventions

7.1 Approach and Rationale

7.1.1 Mine Tailings and Waste Dumps

Mine tailings are the residue of the milling process that is used to extract metals ofinterest from mined ores. During this process, ores are first milled, finely ground andthen leached. The leaching agent (usually sulphuric acid) not only extracts uraniumfrom the ore, but also many other toxic substances including heavy metals such asmolybdenum, vanadium, selenium, lead and arsenic. The tailings also contain thechemicals added during the milling process.

After chemical neutralization, the extremely fine slurry called 'tailings' is disposed ofin ponds behind dams or 'tailings impoundments'. The tailing material ischaracterized by poor mechanical stability due to its small grain size and usually highwater content.

Waste rock is the material removed from the mine in order to get to the ore. Thewaste rock is discarded in waste dumps. If these contain low-grade uranium ore,they give rise to environmental concerns from leaching of radionuclides and heavymetals by percolating surface water.

7.1.2 Potential Environmental Problems of Abandoned Uranium Tailings

The main short and long term environmental problems associated with formeruranium mine tailings are:

Dam safety and stability;Water pollution (surface and groundwater);Air pollution (radon and radioactive dust);Gamma radiation (direct exposure);Use for building material (radiological exposure); andLong-term reclamation and restoration.

Figure 7.1 illustrates the typical environmental hazards from uranium mill tailings.These hazards are discussed below as a basis for understanding the rationalebehind the specific interventions proposed at the Mailuu-Suu tailings.


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Uranium Mill Tailings Hazards

radon-exhalation gamma-radiation dust blowing(radium, arsenic-...)

44

7 ? K dam failure

lEings erosionflood

' 4/ 7 J \, earthquake/ / 4 T\ heavy rain

seepage.(uranium, arsenic-. 4

groundwater '

Fig. 7.1. Typical environmental hazards from uranium mill tailings. Source: UraniumMining and Milling Wastes: An Introduction, P. Diehl, March 2003.

Dam safety and stability

There are many documented cases of mine tailings dam failures worldwide, some ofwhich have had catastrophic consequences. The 'upstream' type embankment,where new parts of the dam are built on top of slurries impounded during theprevious stage, carries the highest risk, as this does not have a water-retentionstructure. This type has been used with most historical tailings dams (including mostof those at Mailuu-Suu).

The main risks to safety and stability for a tailings impoundment are as follows(WISE 2003):

Hazard from weak foundations - tailings dams are often not of stable construction. Inmost cases, they were made from sedimentation of the coarse fraction of the tailingssludge. Also, if the soil or rock at shallow depth below the dam is too weak to supportthe dam, movement along a failure plane will occur. This may result in partial orcomplete failure of the dam. This risk is accentuated in areas of high seismic activity.Strengthening the toe of the dam wall will reduce this risk.

Overtopping from flooding - if the water level rise is excessive this can result inovertopping of the dam crest, potentially resulting in complete breaching of theembankment. The overtopping water erodes the embankment within a very shorttime and can lead to failure of the overall impoundment within minutes.Consequently good drainage measures to prevent ingress of surface water duringspring floods are important.


* EJACOBSGIBB HCG Environment

Hazard from high groundwater pressure - the phreatic surface (watertable) is criticalfor stability of 'upstream' type embankments. If the beach width between the pondand the dam crest becomes too small, the phreatic surface within the embankmentrises and causes the toe of the dam to become unstable and collapse. Dam failurecan be triggered by an excessive rise in the level of pond water e.g. by flood inflow,even if no overtopping occurs. Likewise, good control of stormwater drainage isessential.

Hazards from liquefaction of saturated tailings (e.g. during seismic activity) -upstream tailings dams are known to have very poor stability during seismic events.During repeated mechanical stress, the tailings slurries (including the material usedfor the dam) may liquefy. Where the dam stability is marginal, liquefaction even mayoccur from vibrations caused by heavy equipment (for example scrapers travellingalong the dyke crest or the dam toe).

Hazard from piping - this process is the generation of a preferential flow path causedby erosion from water seepage within or beneath the embankment. Excessive pipingmay result in local or general failure of the embankment.

Water pollution

Local water bodies can be adversely impacted by tailings due to discharges (e.g.from base drainage pipes), from seepage through the embankment or by inadequateprovision for control of surface water runoff, especially during periods of heavy rainor flooding. Loss of tailings material through surface water erosion can also dispersecontaminated material into receiving waters.

Dispersion of radionuclides through groundwater systems is widely considered oneof the most important pathways for potential impact from uranium mining activities,particularly over the long-term. Due to the slow rates of contaminant migration, onlyradionuclides with relatively long half-lives are of importance in the transportprocess. The radionuclides of primary concern are uranium-238, uranium-234 andradium-226. Seepage from tailings is a major contamination risk to groundwater asthe impoundments are generally formed from waste material that is notimpermeable. Seepage poses a risk to both ground and surface water e.g. riverrecharge. Local fauna and flora as well as aquifers which may provide potable watersupplies are at risk from migration of radionuclides and other toxic substances suchas heavy metals.

Mitigation of this risk is difficult other than by limiting water ingress to theimpoundment (drainage control of surface water runoff) and by capping/ contouringthe surface to reduce infiltration. A detailed understanding of the hydrogeological andgeochemical regimes together with groundwater monitoring up and down hydraulicgradient of the tailings is necessary to determine the effectiveness of remediationand the long-term health risk of a migrating contaminant plume.

Air pollution

Tailings generally contain a high proportion of fines and present exposed surfacesthat may be prone to wind erosion. While the tailings remain wet, there is little


T

*W *t F3 IA0P'ARF GIBB tt L HCG Environment* ., *

likelihood of dust problems occurring. Should the exposed surfaces of tailings dryout, however, wind erosion is likely to become a significant problem.

The dry surfaces of uranium tailings will produce toxic dust containing radionuclidesand heavy metals, which can be dispersed by the wind over adjacent areas.Likewise, radon emanating from the surface of the tailings will be similarly dispersed.Elevated levels of gamma radiation present an additional risk.

Current practice during decommissioning of mine tailings is to place a compositecover system with infiltration barrier and vegetation. However, care is needed ifrevegetated uranium tailings are to be used as pasture for livestock due to theuptake of toxic elements (e.g. uranium, radium, arsenic, selenium) in the plants.

Most of the uranium tailings at Mailuu-Suu now have a cover of vegetation andtherefore are not at risk from wind erosion. The exception is Tailing 3 which hasbeen subject to some recent rehabilitation works and has not yet been revegetated.There is potential concern that the old tailings continue to be used for grazinglivestock with the risk of radionuclides and other toxic components entering the foodchain. However, Tacis (2003) identified that the ingestion dose from this source islikely to be low for most tailings.

Use of tailings for building material

Tailings and rock waste have in some parts of the world been used for constructionof buildings. In homes built on or from such material, high levels of gamma radiationand radon have been found. This has also been the case in Mailuu-Suu for somedwellings in the village of Kara-Agach (Tacis, 2003). The U.S. EnvironmentalProtection Agency estimates the lifetime excess lung cancer risk of residents of suchhomes in the USA at 4 cases per 100. Proper capping of uranium tailings or burial ofwaste dump material together with public awareness of the risks will eliminate thishazard.

Rehabilitation of uranium mill tailing deposits

Table 7.1 outlines the various issues, environmental impacts and possible solutions(interventions) associated with rehabilitation of uranium mine tailings. The major riskfrom these types of tailings is their radiological content. If the tailings pile presents animmediate hazard, then intermediate protective measures should be taken, such asinstallation of fencing to prevent access, placement of a cover or revegetation toprevent windblown dust, or collection of seepage waters. These measures, however,should not conflict with long-term measures to be taken later.

Table 7.1 Issues, environmental impacts and possible interventions forrehabilitation of uranium mine tailings

Potential Issue / Impact | Possible InterventionErosion and Structural Instability


* "" JACOBSGIBB IHCG Environment

* Overtopping from flood waters . Geotechnical risk assessment on* High phreatic (water table) closure

surfaces . Integrity from construction phase* Piping of materials during * High quality operational management

seepage . Rock armouring* Sedimentation * Buttressing* Surface flooding erosion of . Drainage control

batters . Erosion resistant cover* Integration of cover into environment

Dustfradon emanation* Health effects * Surface capping to limit radon emanation* Offsite pollution effects and prevent wind erosion (e.g. gravel

Flora and fauna mulching)* Revegetation

Wind breaks. Hydromulch

GroundwaterAquifer contamination . Reduce hydraulic head by water sheddingLimitation of beneficial use * Integrate capture release systemsRecharge impact . Utilise evapo-transpiration

* Cap and cover with capillary breakDrainage diversionsDetoxification of tails seepage

* Wetland filtrationHealth & Safety* Potential injury or death . Effective landform and cover design* Radon and gamma radiation . Restrict access (e.g. fencing)Long-tenn Viability of Rehabilitation

* Livestock and feral animal control. Environmental monitoring

Source: based on Environment Australia 2003, Sustainable Minerals Program

7.2 Uranium Mine Tailings and Waste Dumps at Mailuu-Suu

Uranium mining in Mailuu-Suu was active from 1946 until 1968. The legacy of thisactivity includes 23 tailings and 13 waste dumps (Figure 5.1). The tailings aresituated close to the former mill plants and are mostly within the flood plain of theMailuu-Suu River between the northern end of Mailuu-Suu town and the village ofKara-Agach.

Of particular concern is Tailing 3, located on the left bank of the Mailuu-Suu River, ina small depression opposite the Isolit factory. The deposit (some 110,000 m3 ) wasproduced largely from the leaching of high-grade uranium ore (> 0.5 %) from theformer German Democratic Republic. It is considered to present the highest riskbecause of its intrinsic instability and the real threat of the landslide ("Tectonic southtriangle") which overhangs it (Fig. 7.2). For this reason, Tailing 3 has beenextensively studied (see Tacis 2003 for a summary of historical and recent siteinvestigations).


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Fig. 7.2. The tailings 3, 8 and 9 are located close to the river and their stability isthreatened by the Tectonic and Isolit landslides. Some of the buildings of the factory(in the right) were damaged by a recent Tectonic landslide.

The waste rock dumps contain lowgrade uranium ore and are scattered around thearea mainly in the Mailuu-Suu, Aylampasay, Kulmensay and Kara-Agach rivervalleys. They are frequently cut by streams (e.g. in the Kulmensay river) whichtransport and disperse low radioactive materials downstream. In most cases thesedumps are not stabilized or revegetated.

The total tailings volume is 1.9 million m3 with individual tailings ranging from 1,000m3 (Tailing 17) to 600,000 m3 (Tailing 7). The total waste dump volume is 0.8 millionm3 making in aggregate about 3 million m3 of uranium waste. The total radioactivityof this material has been estimated as 1.86 x 101 Bq (Torgoev and Aleyshin, 2000).Tables 2.9 and 2.10 of Tacis (2003) contain a detailed inventory of mill tailings andmine waste rock dumps in the Mailuu-Suu District.

Staff of the mining industrial complex conducted supervision and maintenance of thetailings areas. This involved inspection of the sites, controlled security access to theindustrial area, along with maintenance of the site fencing, tailings integritycontainment structures and the surface drainage system. This work was stopped in1991 with the collapse of the Soviet Union.

The general environmental problems described above for uranium tailings aretherefore compounded in the case of tailings at Mailuu-Suu by the absence of anysubstantive engineering design, the lack of maintenance in more than a decade,heavy spring floods, the presence of landslides and high seismic activity in the area.Other concerns with the uranium mining legacy in Mailuu-Suu are as follows:


-k * JA COBSGIBB L HCG Environment

* The ore-mining, ore-processing and waste-disposal facilities have been sitedand installed without any consideration of environmental consequences orimpact on the health of the local population.

* Most dams are unstable and their structural engineering is not adequate forthe amount and physical properties of the material stored behind them.

* Most tailings are not equipped with a base lining to prevent leaching ofhazardous substances into surface or groundwater.

* There are no warning signs or fences - free access is possible to all dumpsand tailings and to some of the mine adits. Many of the tailings are being usedfor grazing livestock with the result that radionuclides enter the food chain.

* Plans of the mine workings and shafts/adits (required to assess risks of sub-surface tunnels and other interventions) have not yet been declassified.

* The local Kyrgyz population downstream of Mailuu-Suu (about 5000 persons- Tacis 2003) are at risk from contaminated well/river water for drinking andirrigation purposes (Mailuu-Suu residents have a piped water supply from theupper catchment).

* There is no regular monitoring of environmental media (air, water, foodstuffs)for radioactive or other toxic substances.

Two worst-case natural disaster scenarios have been considered for the situation inMailuu-Suu:

1 . The unstable south portion of Tectonic landslide (varying from 30,000 up to400,000 m3) mobilising the contents of Tailing 3 (and possibly Tailing 9) intothe Mailuu-Suu River, and potentially causing extensive and irreversibleradiological contamination downstream within the Fergana Valley andneighbouring Uzbekistan.

2. The unstable part of Koe-Tash landslide blocking the valley flood plain justnorth of Kara-Agach forming a natural dam which floods the upstreamTailings 5 and 7. Subsequently collapse of the dam generates a flood wavethat washes out tailings downstream (Nos. 3, 8, 9, 10, 19, 20, 21, and 22),flooding Mailuu-Suu and other settlements, and causing extensivedownstream damage and potential radiological contamination within theFergana Valley.

A precedent for both scenarios has occurred. In April 1958, after an earthquake anda week of heavy rains, a breach of the Tailing 7 dam caused the loss of an estimated60,000 t of radioactive tailings material, which reportedly contaminated the floodplainalong a 40-km stretch (Tacis 2003). This incident resulted in many fatalities and theradiological clean-up of agricultural areas lasted many years.

More recently in 1992, a massive part (about 1 million m3) of Tectonic collapsedcausing substantial damage to the Isolit factory. The landslide obstructed the riverand the resulting mudflows and floods caused destruction of houses, roads,communication and electricity lines, water supply facilities and heating and sewagesystems. Two further activations occurred in 1994 and 1998 resulting in moredamage to the road and water facilities. Figure 7.2 also shows the new road and thedamage to the abandoned factory currently being washed away by the realignedriver course. A more recent activation in May 2003 again partially blocked the river.


* 1914 IA("¢BS G~IBB L HCG Environment

The World Bank technical team have proposed a number of short-term interventionsto reduce the risks posed by the tailings at Mailuu-Suu (see Section 4.3). The likelyeffects and the mitigating measures needed to limit adverse impacts on theenvironment and local communities from these interventions are discussed below.

It is noted that appropriate health and safety precautions, including radiologicalmonitoring, would need to be implemented for Contractor and supervisory staff forany work associated with radioactive materials associated with tailings, seepage oruranium waste dumps.

7.3 Restricting Access

The tailings are currently unfenced and open to both local inhabitants and theirlivestock. Restricting physical access to these areas has been proposed as a priorityshort-term measure to reduce the radiological health risks, both immediate andindirect as a result of radiological contamination of meat and dairy products.

The Tacis report (Tacis 2003) recommended the fencing of tailings and provision ofsafety warning signs. The tailings of immediate concern were reported to be Nos. 3,4, 5, 7 and 13. It is understood that provision of funds for fencing has already beenmade available and that procurement of these materials is in progress.

However there is concern based on previous experience in the area that any fencingwill in time be stolen. Many of the tailings were previously fenced and guarded underthe Soviet regime. With the abandonment of these controls the fencing has graduallydisappeared.

An alternative intervention to restrict access is to cover the tailings surface with alayer of gravel and large rocks. This will discourage plant growth and provide aphysical barrier to local herders and their livestock.

The disadvantage of fencing or a rock cover is that these interventions effectivelyprevent alternative land use for generations. Many of the old tailings have beencovered with soil and are now vegetated, and used extensively as pasture, currentlywith potential health risks. An alternative strategy could include restoration of sometailings with a suitable capping system to allow safe use as pasture (see below).

Potential Impacts and Mitigation Measures

Activity: Erection of secure fencing with safety signs around the perimeter of high-risk tailings.

Potential impacts:* Beneficial effect in terms of radiological risk - reduction of human exposure to

gamma radiation, radon and contaminated soil, and preventing radionuclidesentering the food chain through grazing by livestock (although the latter dose islikely to be small);

* Fence does not prevent most natural animals (small mammals, birds, insects,etc.) to enter the area and be exposed to pollution;

* Effect is likely to be only short term as fencing is at risk of being stolen;* Loss of traditional grazing land.


* * ~I4UJACOBS GIBB -L HCG Environment**

Mitigation:The fencing of tailings areas should include a program of public awareness toexplain the radiological risks and need for closure. The program will need to includeprovision for ongoing periodic inspection and maintenance - responsibility for thisshould rest with the community to ensure the program is locally supported andeffective. It will be difficult to prevent native animals from entering the area.Consideration should be given to capping rather than fencing some tailings (seebelow).

Activity: Placing ballast and a layer of large rocks on the tailings to discourage plantgrowth and access by humans/livestock.

Potential impacts:* Beneficial effect in terms of radiological risk - reduction of human exposure to

gamma radiation, radon and contaminated soil, and preventing radionuclidesentering the food chain through grazing by livestock;

• Permanent loss of traditional grazing land (although this currently presents ahealth risk);

* Rock waste is taken from unsuitable sources (e.g. waste dumps);* Ground disturbance from machinery needed to place heavy rocks.

Mitigation:Source gravel and rock cover locally e.g. washed gravel from suitable terraces onthe Mailuu-Suu flood plain and rock from local landslide material. Use local labor andresources for moving gravel and rock. Consider combined program of unloadinglandslide with reuse of material for covering tailings. Include provision for ongoingperiodic inspection and maintenance by the local community. Consideration shouldbe given to capping some tailings rather than fencing or rock cover (see below).

7.4 Capping and Revegetation

An alternative strategy to restricting access could entail rehabilitation of sometailings, which are in poor condition or which present a risk from exposed tailingsmaterial, with a suitable vegetative capping system to allow safe use as pasture.This could be applied to Tailing 13 and possibly Tailing 11. (It is noted that themajority of tailings do not present a serious health risk from grazing livestock).

A wide variety of such capping systems have been developed for restoration offormer uranium tailing sites. These include measures to promote erosion resistance,control radon/infiltration control, and limit bio-intrusion. Experience developed inoverseas uranium mining restoration programs (e.g. the US UMTRA program,Australian Ranger Mine) could be used to develop suitable vegetative restorationcover for selected tailings at Mailuu-Suu.

A typical rehabilitated tailing would comprise the following sequence:

* Vegetation cover (native uranium and heavy metal tolerant grass species);* Topsoil with rooting medium (15-30 cm);* Gravel drainage layer (30-40 cm - acting as the capillary break layer);* Clay layer (barrier for rainfall infiltration and radon diffusion);• Tailings.


*t EL! JACOBS GIBB l HCG Environment

The objective of the surface vegetation cover is to establish a plant community onthe tailings that is self-sustaining and tolerant of the local geochemistry and localclimatic conditions. A vigorous plant community will transpire most of the moisturethat enters the soil and will resist erosion of the underlying material. The purpose ofthe rooting medium is to promote evapo-transpiration of water, to reduce rainfallinfiltration into the tailings and contain the root zone of the grassy vegetated surface.

The purpose of the gravel capillary layer is to break the connection between theupper soil and lower cover layers - this impedes root penetration to the contaminatedtailings and retards capillary drawdown of seepage into the cell. A compacted claylayer is used to limit infiltration of rainwater and diffusion of radon gas to atmosphere.Figure 7.3 illustrates a typical multilayered cover with infiltration barrier (Source: BestPractice Environmental Management in Mining, Tailings Containment, AustralianFederal Environmental Department 1995).

. v" .S.:

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71Pp s a 4. . -

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will be redrawn>Fig. 7.3. Schematic of multilayered tailings cover with infiltration barrier.

7.4.1 Potential Impacts and Mitigation Measures

Activity:Capping and revegetating the tailings include the following activities:1. Planning of the capping system;2. Preparation works at tailings site (access, earthworks);3. Sourcing and placement of clay, gravel and soil layers;4. Revegetation of surface with tolerant species.

Potential impacts:Significant benefits will be possible with this intervention:* Reduced human radiological risk from exposure to gamma radiation, radon and

contaminated soil;* Restoration of pasture for safe grazing by livestock - preventing radionuclides

entering food chain;* Opportunity to reduce groundwater contamination from tailings seepage

following reduced surface water infiltration;* Benefit to local fauna and flora by removing direct access to biogeochemical

contaminants.

The following adverse impacts could potentially arise during construction:* Poor planning may result in accentuated soil erosion and surface water

contamination during earthworks;* Disturbance to local fauna and flora established on existing tailings areas;


E] JACOBS GIBB L I HCG Environment

* Poor germination and establishment of new vegetation;* Introduction of unsuitable alien plant species;* Disturbance to local community from construction traffic, noise etc.

Mitigation:Planning should be based on detailed field studies as well as understanding of waterflows, surficial deposits and erosion in the area. Planning should also consider apossible need for erosion control structures. The works should take place during thedry season in order to avoid uncontrolled erosion.

A survey of fauna and flora should be undertaken to establish any rare orendangered species. Native grasses and other vegetation with a low coefficient ofdiscrimination that are tolerant of uranium and heavy metals should be selectedbased on research on plant tolerant species for uranium mine tailings in Kyrgyzstan(Bykovchenko et al 2002). A seedbed should be provided to promote germinationand early growth, as well as resist erosion until the vegetation becomes established.

The Contractor will be required to follow environmentally sound constructionpractices to minimize local pollution, damage to natural resources and communitydisturbance.

7.4.2 Site-Specific Considerations

Tailings that are currently used by the local community for grazing livestock andwhich could benefit from a restoration program are Nos. 1, 2, 4, 13 (close to Mailuu-Suu on the west side) and Nos. 5, 6 and 7 just north of Kara-Agach.

Other tailings are threatened by landslides (e.g. Tailings 3 and 9), or are at risk ofbeing washed into the river (e.g. Tailings 8, 20 and 21). An alternative long-term riskmanagement strategy for these tailings may be removal to a dedicated safe disposalfacility (see Chapter 10).

7.5 Stormwater Drainage

Adequate stormwater diversion and drainage at the inflow of tailings is essential toprevent runoff entering the tailings area and causing surface erosion, outwash ofcontaminated sediment during heavy rains and contributing to seepage and risk ofdam failure.

Stormwater drainage generally follows a "horseshoe" outline with water inflowsdiverted around the sides of the tailings and discharging through pipes or channelsto nearby watercourses.

Stormwater drainage structures at a number of the Mailuu-Suu tailings are in a poorstate of repair or have not been adequately engineered. This intervention is intendedto rehabilitate existing tailings drainage structures or implement additional drainagewhere there is insufficient capacity to meet peak flows.


Activity:


4JACUSS GIBB o HCG Environment

Rehabilitation of existing structures will require clearance of debris, and patch repairsto the infrastructure. New drainage will require planning, excavation of side trenchesand installation of the drainage culverts.

Potential impacts:* Poorly planned intervention may result in accentuated soil erosion, excavation of

tailings material and local sedimentation of rivers;* Excavated surfaces may trigger gully erosion, especially during heavy rains;* Excavators and haul/dump vehicles may destroy vegetation cover thereby

increasing erosion;* Spillage of diesel/oils used in plant and machinery;* Drainage water may contain tailings sediment that will pollute the local river.

Mitigation:Planning of drainage gully design should allow for topography, local groundinstability, peak water flows, the need for erosion control structures and field studiesto ensure drainage channels lie outside the perimeter of tailings deposits. The worksshould take place during the dry season in order to avoid uncontrolled erosion.

Drainage channels should be excavated so that erosion can be avoided. Channelsshould be strengthened against erosion and preferably constructed with concretechannel elements. Drainage water should be discharged to river valleys alongstrengthened channels or pipelines large enough for peak flows. In order to avoidleakage, the channel elements should be such that they will not be displaced orbroken by minor slope movement. The work should be done using light excavatorsor manual labor. Donkeys can be used for transporting materials on steep slopes.



The following site-specific considerations are based on the Tailings Report (DecO3 v1.0) prepared by the tailings specialist within the technical team:

Tailings No 3 - this has recently been subject to some recent rehabilitation worksincluding reinforcement of the base of the empoundment and replacement of the topdam, and the provision of some drainage features in the upper part of the dam.However there is a major problem with lack of space for side drainage because ofthe steep confining valley walls. The Tailings Report recommended improveddrainage channels to minimize water entering the upper portion of the tailings andimproved drainage down the outer side of the dam.

From an environmental risk perspective, given the intrinsic instability, saturatedcondition and high radioactivity of this tailings, it is recommended that specialprecautions be incorporated into the design of any drainage interventions to preventphysical vibration or disturbance, loss or off-site migration of contaminated material.This would include avoidance of tracked vehicles or other machinery on the tailingssurface, minimizing excavation of trenches near the contaminated area, andradiological monitoring of soil and drainage discharge during excavation. In addition,


'* I2JAC03S GIB13 itIHCG Environment

all outfall pipes discharging into the Mailuu-Suu River below Tailings No 3 should besealed in case they remain a conduit for tailings seepage.

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Fig. 7.4. Drainage channel between the tailings 5 and 7 discharging snow melt andstorm water.

Tailing No 9 - drainage is relatively poor and needs repairs to prevent the generationof polluted runoff being channeled across the surface and discharging into thedownstream channel.

Tailings No 1, 2, 4, 12, 13, 14 and 10, 19 - the drainage structures are generallyoperational but need repairs to make them fully functional.

Tailings No 5, 8, 20, 21, 22 - the drainage structures are in relatively good conditionand in the short term need only minor maintenance work (clean and repair drainagechannels).

7.6 River Bank Strengthening

The integrity of tailings can be severely affected by river erosion. Flooding andmudflows are frequent in the river. Many of the tailings in the Mailuu-Suu valley aresituated within the flood plain or are otherwise at risk from erosion by the riverchannel. This can result in loss of retaining structures and wash out of material,particularly following period of heavy rain or flash flooding.

The east bank of the Tailings 8 lies adjacent to the Mailuu-Suu River and haspreviously been protected by rock gabions (Fig. 7.5). However the protection willeventually fail resulting in slow release of contaminated sediment into the river.


* * rE JACOBS AIRR tL E'HCG Environment

4 ~ -J4

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Fig. 7.5. Tailings 8 lie adjacent to the river and has been protected by rock gabionsnot adequate to prevent stream erosion.

Tailings situated close to the Aylampasay River flood plain are also at risk. Normalriver flows are greatly swelled in spring by heavy rain and melting snow resulting inflash flooding and severe riverbank erosion (Fig. 7.6). This will in time progress tothe tailings. Some constructions against riverbank erosion have previously beenmade, but they have partially been washed away.

Riverbank strengthening has therefore been proposed at selected tailings at Mailuu-Suu to provide short and medium-term protection.

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Fig. 7.6. The Aylampasay River flows between several tailings and there is a riskthat riverbank erosion may result in collapse of the dumps.


Activity:Excavation and associated trenching earthworks, and provision of reinforcementstructures such as concrete retaining walls or rock gabions to stabilize existing riverembankments.

Potential impacts• Poorly planned intervention may result in, loss of tailings material, accentuated

soil erosion and local sedimentation of rivers;* Excavators and other plant may weaken existing riverbanks;* Disturbance to local fauna and flora along existing riverbanks;* Spillage of diesel/oils used in plant and machinery;* Disturbance to local community from construction traffic, noise etc.

MitigationPlanning of riverbank strengthening works should allow for topography, local groundinstability, peak water flows and the need for erosion control structures.

The works should take place outside the wet season (March-May) in order to avoiduncontrolled erosion. A survey of fauna and flora should be undertaken to establishany rare or endangered species. The work should be done using light excavators ormanual labor using locally resourced materials. Donkeys can be used fortransporting materials on rough terrain.



The following site-specific considerations are based on the Tailings Report (DecO3 v1.0) prepared by the tailings specialist within the World Bank technical team:

* The tailings at risk from river erosion alongside the Mailuu-Suu river are Nos18, 8, 20, 21 and 22;

* A second group susceptible to river erosion comprises Nos 1, 2, 4, 12, 13and 14 situated close to the Aylampasay river flood plain.

8 Landslide Interventions


Landslides are frequent on steep slopes which tend to get over-steepened due toerosion (denudation surfaces). Major landslides are often related to earthquakes and


* * 1D1 JACOF.4 5 GIBB HCG Environment

such seismically triggered landslides are widespread phenomena within tectonicallyactive mountain ranges of the region. Historically, numerous landslides, sometimescausing extensive damage, casualties and loss of property, have accompaniedstrong earthquakes in the Mailuu-Suu area. Most of these slope failures are reportedto be of small size, and only a few of them affect large volumes of soil or rockmaterial. The latter, however, represent the highest risk to the environment,infrastructure and life. Figures 8.1 and 8.2 show the potential problems and physicalfeatures related to landslides.

The flow and behavior of a landslide is dependent on both solid and liquid matter.The two primary forces are gravity and the shear strength of the slope. The force ofgravity acts on the earth mass trying to pull it to the bottom of the slope. The shearforce resists movement and is basically a function of a number of slope variables,including soil geology and the amount of vegetation and tree roots. The slope shearforces must be high enough to withstand all transient forces in order to avoid earthmovement.

The major cause of landslides is the absorption of large amounts of precipitation.When the slope absorbs large amounts of water, an increase in water content willincrease the pore water pressure. It can be seen that as pore water pressure rises,the soil particles will in effect be 'pushed' apart, which will result in a loss of frictionbetween the particles. Water pressure will especially build up between voids andfault cracks. Water can also act as a lubricant aiding in the sliding action. Similarly,the surface of a frozen soil layer (ground frost) beneath a thawed soil layer may actas a slip-plane.

Increased water content will affect the weight of the slope. Changes in weightimposed on the slope will affect the stability. Increased weight will result in increasedshear stresses. Soils that have a high cohesion, such as clay, are particularlysusceptible to decreased strength by water content. It can be seen that the watercontent is the major factor. Once the water content is near 17%, the angle of reposestarts to decrease. The angle of repose increases up to that point; this is becausewater is needed to give soils its cohesive characteristic, but too much will decreasethe shear strength.

A second factor that can affect slope stability is the amount of vibration e.g. createdby traffic, machinery or explosives. The removal of underlying support is also acause of landslides. This can be caused by natural processes such as erosion or byman-made processes like landscaping and earthworks.


*i I:3JACOBS GIBB _ HCG Environment

Figure 8.1. Potential problems related to a landslide (Slope Conservation Division,Ministry of Land, Infrastructure and Transport, Japan).

Figure 8.2. Sketch of a landslide.

Possible Solutions

Trees, ground cover or other vegetation may be planted (preferably fast-growingvegetation with sturdy root systems) to stabilize exposed near-surface soil.However, this method is often insufficient. Retaining walls or other stabilizationstructures can be built against the slope to try to hold it in place. Given thedistribution of stresses acting on retaining walls, the greatest success of this kind hasgenerally been low, thick walls placed at the toe of a fairly coherent slide to stop itsmovement. High, thin walls have been less successful.


T

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* ,,*

Since water can play such a major role in mass movements, the other principalstrategy for reducing landslide hazards is to decrease the water content or porepressure of the rock or soil. Covering the surface completely with an impermeablematerial and diverting surface runoff above the slope might do this. In addition,subsurface drainage might be undertaken. Systems of underground boreholes canbe drilled to increase drainage through pipelines. All such moisture-reducingtechniques naturally have the greatest impact where the rocks or soils are relativelypermeable. Such moisture reduction reduces pore pressure and increases frictionalresistance to sliding.

Other stabilization techniques that have been tried include the driving of vertical pilesinto the foot of a shallow slide to hold the sliding block in place. The procedure worksonly where the slide is comparatively solid (loose soils may simply flow betweenpiles), with thin slides (so that the piles can be driven deep into stable material belowthe sliding mass), and on low angle slopes (otherwise the shearing stresses maysimply snap the piles). So far, this technique has not been very effective.

The use of rock bolts to stabilize rocky slopes and, occasionally, rockslides has hadgreater success. Rock bolts have been used in tunneling and mining to stabilize rockwalls. It is sometimes also possible to anchor a rockslide with giant steel bolts driveninto stable rocks below the slip plane. However, this works best on thin slide blocksof very coherent rocks on low-angle slopes.

By far the most common strategies, however, are modification of slope geometry andload, dewatering, or a combination of these techniques. The more ambitiousengineering efforts are correspondingly expensive and usually reserved for largeconstruction projects (e.g. tunnels, mines, road cuttings, etc.).

Avoiding recognized landslide-prone areas altogether would greatly limit damage. Inthe Mailuu-Suu area this would mean that the tailings and settlements threatened bylandslides should be relocated.

As a summary, the following steps can be taken to reduce the amount of mass-movement and limit resulting damages (see Figures 8.3-8.5). If a slope is too steepto support the load it carries, any of the following steps will reduce the slide potential:

* Reduce the slope angle;* Place additional supporting material at the foot of the slope to prevent a slide or

flow at the base of the slope;* Reduce the load (weight, shearing stress) on the slope by removing some of the

rock or soil high on the slope. Depending on how unstable is the slope, this mayneed to be executed cautiously. If earthmoving equipment is being used toremove soil at the top of a slope, for example, the added weight of the equipmentand vibrations from it could possibly trigger a landslide;

* Construct mechanical barriers as walls and tamper piles to stabilize the slope;* Decrease the volume of water from the earth of potential landslides. Run-off from

the adjacent areas can be diverted away from the vulnerable area. Groundwaterlevel can be lowered through boreholes as well as by digging wells and pumpingwater out from the landmass;

* Revegetation and afforestation of the slopes will produce a firm surface layerwhich prevents erosion and mass movements in the long-term. This method isinadequate for steep slopes.


** II§JACOBS GIBB HCG Environment

* -4 *~~~~~~~~~~~~~~~~

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Figure 8.3. Sketch showing methods reducing landslide hazards on a landslideprone slope (Slope Conservation Division, Ministry of Land, Infrastructure andTransport, Japan).

Figure 8.4. Sketch showing drainage works on a landslide prone area (SlopeConservation Division, Ministry of Land, Infrastructure and Transport, Japan).


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Retaining wal I works /(Prevention of smaIlI colIapse) _ , _

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Figure 8.5. Sketch showing construction works on a landslide prone area (SlopeConservation Division, Ministry of Land, Infrastructure and Transport, Japan)

Recommendations

Stabilization measures under study in Mailuu-Suu are drainage measures consistingof horizontal drains, drainage trenches, anchored / soil-nailed I tieback walls,unloading or a combination of them. In selecting the most appropriate remediationworks, the key factor to consider is how to mitigate the movements in an economicalmatter considering the potential damage they may cause. Other factors such asconstruction scheduling, availability of materials, site accessibility, equipmentavailability, aesthetics, environmental impact of the landslide remediation works,socio-economic issues and labor considerations must also be kept in mind.

The urgency of landslide prevention measures should be defined for each site sothat those which need immediate attention will be done first. There are measuresthat provide a quick response (e.g. dewatering, unloading, piling, wall construction)and ones which only have a long-term effect (e.g. afforestation, controlling over-grazing).

8.2 Unloading

One of the measures proposed by the technical team is unloading landmasses fromthe head of the landslide prone sectors. If the unloading will be implementedsuccessfully, the intervention may prevent landslides above the tailings (e.g Tectonictriangle) and reduce the possibility for landslides damming the river (Koi-Tash).

The unloading requires extensive landmasses to be excavated, transported anddisposed. The work is likely to be done using excavators and heavy trucks. Thefollowing working phases have environmental consequences:EIA February 2004.doc 83

l- liJACOBS GIBB*L HCG Environment

1. Preparation works for excavation including terraces and access roads;2. Site selection and preparation earthworks for the dumpsite;3. Construction of main connection roads;4. Excavation of the head of the potential landslide;5. Transportation of landmasses;6. Landscaping of the dumpsite.


Activity:Preparation works for excavation including the construction of terraces, access roadsand drainage channels in order to make it possible for excavators and trucks tooperate on the slope.

Potential impacts:* The barren and excavated land surfaces may trigger mudflows and gully erosion,

especially during heavy rains and snowmelt.* Machinery traffic may destroy vegetation cover from far more extensive areas

than required during the site preparations.* Poorly planned earthworks may trigger smaller or major landslides, which may

also be a safety risk for workers.

Mitigation:The works should take place during the dry season. Where earthworks may createditches or structures blocking run-off, drainage channels should be excavated so thaterosion can be avoided (e.g. using concrete channel elements where necessary).The excavation works should be planned so that major collapses of pit walls can beavoided and the safety of workers is carefully considered.

Activity:Site selection and preparation earthworks for the dumpsite.

Potential impacts:* The landfill may damage valuable natural areas, pastures and block cattle tracks.* On a steep slope, dumped landmasses may trigger gully erosion, mudflows or

landslides and cause sedimentation of rivers.

Mitigation:The dumpsite should be located in areas which are not important for natureprotection, pathway connections and livestock management. The site should belocated in a stable plain or gentle slope far from a river valley.

Activity:Construction of main connection roads.

Potential impacts:* Poorly planned and constructed roads may trigger gully erosion, mudflows or

landslides and cause sedimentation of rivers.* A dense road network and traffic outside the roads may destroy vegetation and

cause erosion.


** * I *JACO:DBS GIBBntR E HCG Environment* * ,

Mitigation:Roads should be designed so that major cuttings can be avoided in steep slopes oferodible deposits. The road network should be minimal and traffic outside of theroads strictly controlled.Wherever the road blocks run-off, ditches should be built and strengthened withstones and concrete elements where necessary. Major ditches should be divertedand led to river valleys along strengthened channels so that gully erosion can beprevented.Roads should have a firm coarse-grained surface which allows heavy traffic. Roadsshould also have passing extensions as well as planned maintenance and parkingplaces.

Activity:Excavation of the head of the potential landslide.

Potential impacts:* Excavation may cause vibration or slumps of the pit wall, which again may

trigger landslides;* Excavation may expose large areas of water-saturated deposits, which may

cause mudflows.

Mitigation:Excavations should be carried out with care so that heavy machinery will not be usedclose to the edges of the cliff. Excavation should be implemented so that high pitwalls are not created in order to avoid possible slumping.If groundwater or water-saturated deposits emerge from the pit walls or bottom,temporary drainage channels should be constructed so that mud will not accumulateto the pit.Discharge zones from drainage structures shall be furnished with rip-rap to reduceerosion when required, particularly in instances where drainage structures areinstalled and bare slopes are created that require stabilization.

Activity: Transportation of landmasses.

Potential impacts:* Heavy trucks may destroy poorly constructed roads and new roadways will be

generated elsewhere, increasing erosion and destruction of pastures.* The refueling and maintenance of the trucks may cause gasoline and oil leaks.* Operation of machinery generates noise and exhaust.

Mitigation:Road surfaces should be properly maintained and traffic outside of the main roadcontrolled. Maintenance and refueling should take place only in the special siteswhere leakages can be controlled (preferably paved with a concrete platformenabling collection of spillage).Generation of noise and exhaust is unlikely to be significant in the upper slopes, butcan be minimized by using modern machinery.

Activity:


c I*IJACOB8G,BB L I ~HCG Environment

Landscaping of the dumpsite.

Potential impacts:Large pasture areas may be lost because of dump heaps and erosion caused bytrucks.

Mitigation:The dump site should have gentle slopes and a flat surface to avoid erosion. Theedges of the dump should be strengthened using coarse-grained material. Thesurface should be even and allow grass growth. Ground surface must be seededwith a fast growing crop and potential native seed mix immediately after fillplacement to prevent scour and to encourage stabilization. Embankment slopes andcuts shall be stabilized by re-vegetation with grazing resistant plant species,placement of fiber mats, rip-rap, rock gabions, or other appropriate technologies.Traffic outside the access roads should be avoided and temporary road surfacesmust be seeded with grass.

Site-Specific Issues

The head of the Tectonic landslide (Fig. 8.6) threatening the most dangerous tailings(No 3 and 9) and the Isolit factory is easily accessible, and there is already a roadnearby (maintenance road for electric transmission line). Also the location for thedump can easily be found in the area south-east from the landslide head. This areais comparatively flat and the dump will not increase the threat of landslide or majorerosion. It will be straightforward to solve any environmental problems related to thisintervention. Estimates indicate that not more than 100,000 m3 of earth must beremoved. This intervention was concluded to be a Category B project in terms ofEIA. However, good construction practices should be adopted.

The Koi-Tash landslide (which may dam the river if activated) is not so easilyaccessible without damaging the slope facing the Mailuu-Suu River and increasingthe risk for triggering landslides and erosion. The morphology of this slope is morecomplicated and unloading the head would not solve the major problems. It has beenproposed that no unloading works will be done here.

The Isolit landslide - rather a rock fall - is on a very steep mountainside and abovethe Isolit factory. All the slopes are landslide prone and construction of accessionroad, working terraces and dumpsite are problematic.


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Fig. 8.6. Landmass of the Tectonic landslide area could be removed from above theTailings 3 and 9.

8.3 Storm-water Drainage

In this intervention, snowmelt and storm water falling onto landslide areas areremoved in order to prevent water from infiltrating into the soil. If implementedsuccessfully, the water drainage systems will help to dry the earth in a potentiallandslide and thereby to stabilize the slope. The purpose is to canalize run-off anddivert it away from the vulnerable area. If water is collected with due consideration toerosion, it will not contain excessive suspended sediments. Water is also likely to beclean of other polluting substances.

Mudflows and turbid water are frequent during snowmelt and heavy rains and thisproblem has been accentuated by soil erosion caused by extensive tree cutting andovergrazing in the area. Consequently, the river ecosystem has had toaccommodate seasonal high suspension loads.

The channeling work can be done using manual labor or light excavators if this ispossible on steep slopes. Donkeys can be used for transporting the materials onsteep slopes. The interventions include the following activities:

5. Planning of the drainage system;6. Excavating the drainage channels and setting up pipelines;7. Leading gathered water to a river.


Activity:Planning of the drainage system.

Potential impacts:dvPoorly planned intervention may result in accentuated erosion, mass movements

and sedimentation of rivers.

Mitigation:


* *XJACOBSGIBB L I HCG Environment*

Planning should be based on detailed field studies as well as understanding of waterflows, surficial deposits and erosion in the area. Planning should also consider apossible need for erosion control structures and sedimentation basins.

Activity:Excavating the drainage channels and setting up pipelines.

Potential impacts:* The barren and excavated land surfaces may trigger mudflows and gully erosion,

especially during heavy rains and snowmelt.* Excavators and transport vehicles may destroy vegetation cover thereby

increasing erosion.

Mitigation:The works should take place during the dry season in order to avoid uncontrollederosion. Drainage channels should be excavated so that erosion can be avoided.Channels should be strengthened against erosion with stones and preferablyconcrete channel elements and pipelines should be used.

Activity:Leading gathered water to a river.

Potential impacts:* Flooding or leakage of drainage channels may lead to gully erosion and

mudflows.* Drainage water may contain sediment and harmful substances, which could end

up polluting the river.

Mitigation:Drainage water should be led down to river valleys along strengthened channels orpipelines big enough for peak flows. In order to avoid leakages, the channelelements should be such that they will not get displaced or broken by minor massmovements on the slope.

Drainage channels should be constructed so that transportation of mud together withwater can be minimized. Water should be collected from vegetated or coarse-grained surfaces. In cases where this is not possible, a sedimentation basin must beconstructed before releasing the drainage water to a river.


This method can be used to stabilize the Koi-Tash landslide. During snowmelt, theamount of water collected may rise by up to 2-3 m3/s, which could be smallpercentage of the river discharge. The volume of water annually generated in theKoi-Tash landslide area is about 300,000 m3. An effective drainage system for thesite would require the removal of about two thirds of this volume. Consequently,about 200,000 m3 could be discharged annually from this site. The intervention is notexpected to have any negative impacts on the water quality of the river.


* t* Ei JACOBSR~ G~IBB( Q HCG Environment

8.4 Dewatering

Removing of shallow groundwater from a potential landslide area can be done bydigging open ditches or by boring horizontal conduits to the site. Deep groundwatercan be pumped from wells dug through the deposits. A water catchment well isinstalled in a place where groundwater pools or in a groundwater passage.

Groundwater is gathered through a borehole drilled from inside and drained into adrainage tunnel. A horizontal drainage tunnel is connected to a water catchmentwell, and boring is done from inside the tunnel, mainly to remove groundwater indeeper layers. The amount of water discharged from the drainage system of anaverage size intervention site could be about 1000 m3/day. This amount is negligible(< 1 %) considering the water discharge of the river.

Some groundwater in sedimentary rocks (especially Jurassic) may have increaseduranium content and salinity. However, the quality of water is within the range ofdrinking water requirements. In general, dewatering will have a positiveenvironmental impact in stabilizing the potential landslide area. The works includethe following stages:

1. Planning of the wells, tunnels and other drainage system;2. Excavating the wells, tunnels and drainage channels and setting up conduits,

pipelines and wall elements for tunnel;3. Pumping and leading gathered water to a river.


Activity:Planning of the wells, tunnels and other drainage systems.

Potential impacts:Poorly planned intervention may result in accentuated erosion, mass movementsand sedimentation of rivers.

Mitigation:Planning should be based on detailed field surveys as well as understanding ofgroundwater depths, surficial deposits and erosion in the area. Planning should alsoconsider a possible need for access roads, erosion control structures andsedimentation basins.

Activity:Excavating the wells, tunnels and drainage channels and setting up conduits,pipelines and wall elements for the tunnel.

Potential impacts:* Moving machinery, excavation and boring works as well as dumped landmasses

on a slope may result in erosion and mass movements.

Mitigation:Movement of machinery should be minimized and restricted to roads prepared forthe intervention. The dump site for the landmass should be selected so that thematerial will not slide down.


E * ~II JACOBSR~ G~IBB LL1 I HCG Environment

Activity:Pumping and leading gathered water to a river.

Potential impacts:* Usually the pumped groundwater is of good quality and can even be used for

drinking water. Leaking drainage channels may cause erosion andsedimentation of the river.

* Pumps generate continuous noise and diesel powered generators also emitexhaust.

Mitigation:Water should be led to the river along well-established pipelines or concreteconduits. Close to residential areas, the pumps and generators should be in a cabinwhich has good capacity for absorbing noise. An exhaust smoke stack and forcedventilation will keep the air of the cabin clean. The location of the cabin should be asfar from residential areas as possible.


This method is not included in the short-term intervention plan.

8.5 Other Landslide Prevention Interventions

Other landslide prevention interventions, which may be applied in the Mailuu-Suuarea include:

1. Pile works2. Anchor works3. Retaining walls4. Counterweight fills

All these interventions could have a positive impact on the environment as they mayhelp to stabilize potential landslides as well as prevent collapse of mine tailings andwaste rock dumps.


Activity:Tapering piles to landslide prone areas. Piles are driven until they reach a layerunder the sliding surface layer. Piles directly resist landslide power and for thispurpose steel pipes or reinforced concrete piles can be used. Caisson pile work isdone when common piles are inapplicable due to too large landslide impulse or toodeep a sliding surface layer. Reinforced concrete caisson piles few meters indiameter and usually 30 - 60 m long can be driven into the ground.

Potential impacts:* The machinery used for pile works requires access roads and transportation of

machinery and materials may cause erosion.* The piling work generates noise and exhaust smoke.* Installation of caisson piles requires excavation and dumping of major

landmasses.


** FIJACOBS fIRB LL iHCG Environment

Mitigation:For the road works and dumping, see descriptions above and the EMP.

Activity:Constructing anchored walls: anchor works prevent movement of land with a heavyconcrete frame anchored to bedrock. The method is used at the foot of majorlandslides. This technology could be used to stabilize some of the tailings againstoverrunning landslides (e.g. for Tailing 3, if it will not be relocated).

Potential impacts:* An extensive landslide could break the construction and hazardous substances

could be dispersed to the river valley.

Mitigation:Application of this method requires careful calculation of the strength of constructionsand energy of expected landslide. The method should be rejected for tailings if theacceptable standards cannot be met. Engineering work must have tight qualitycontrol.

Activity:Loading the foot of a potential landslide: counterweight fills are usually coarse-grained gravel masses put onto the foot of a potential landslide. Such a fill works likea dam preventing mass movement.

Potential impacts:* A gravel pit is required for producing the fill. Such a pit may cause harm to

landscape, destroy pastures and pollute surface water and groundwater;* Fills must be located close to the river and such landmasses may block roads.

Mitigation:The siting of the gravel pit should be properly planned so that damage to theenvironment can be minimized. Fills can only be used in places where there isenough place in the valley and wherever they do not block roads or otherinfrastructure.

Activity:Construction of retaining walls. Retaining walls are smaller concrete frames whichare not anchored to the ground. They can only be used against minor collapse.

Potential impacts:N/A

Mitigation:N/A


These methods may be applied in the short-term intervention plans. In particular, theIsolit rockfall and some of the tailings could be stabilized with this construction. Suchwalls have already been constructed to protect the Isolit factory (see Fig. 7.2.)Detailed plans will be prepared as part of the feasibility studies.


* * ~J4 14c0BS Gl |HCG Environment* ~~~~JACOBS GIBBD

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Fig. 8.7. One reason for the increased occurrence of landslides and mudflows is therapid deforestation (firewood collection) and over-grazing, which are intensiveespecially close to settlements. Land-use planning and control is also necessary inorder to avoid desertification of slopes.


* * 1] JACOBS GIBB 4t : HCG EnvironmentJACBSGIBB* ,,*

8.6 Early Warning System

Landslides in the Mailuu-Suu region pose the greatest risk to people, infrastructureand the environment.

One intervention proposed is to install a real-time (and near-real-time) landslidemonitoring and early warning system (EWS) to the most critical sites. The monitoringsystem proposed is based on the measurement of surficial displacements andgroundwater level in boreholes. The real-time field monitoring equipment andinstrumentation usually includes data loggers, rainfall pluviometers, piezometers andin-place inclinometers powered by solar energy, connected via a phone, radio orsatellite data transmission system to a computer and to authorities responsible foremergency situations. In the real-time decision-support system, data will beautomatically compared with alert threshold values, related to pre-established riskscenarios performed for each unstable area, making it possible to automaticallyidentify emergency situations.

Automatic tools may include e.g. extensometers, tiltmeters, inclinometers, a rainfallgage, and rockfall warning devices connected to data collection stations.Instrumentation includes GPS topographical surveys, both manual and automatic, fora 3D control of surface movements. In the event of a significant movement and/orrockfall event, the respective dataloggers are programmed to send an alarm. TheEWS provides the following information:

* Remote long-term monitoring that generates a nearly continuous record ofinfiltration and soil-moisture conditions. Most slope movements and landslidesare triggered by rising pore water pressure, which is typically affected by rainfall;

* Continuous monitoring and acquisition of movement data on the unstableheadscarp of a landslide that provided local officials with current movementstatus and produced a record of headscarp response to seasonal precipitationpatterns;

* Rapid response monitoring of part of a major landslide;* Remote monitoring that is aiding officials to track movement of a large landslide

without the necessity of frequent site visits.

The EWS is specially configured to automatically read any combination of in-placedevices. The computerized system compares current readings with baseline values,and can be programmed to issue alarms if readings exceed threshold values.Through remote control in real-time and rapid geographical data processing, it ispossible to store long-term data accurately and effectively and would provide anearly warning of slide activity, thereby reducing landslide hazard. Consequently, thesystem also helps in the prediction and forecasting of landslide failure. In addition,the system can be used to assess the effectiveness of landslide control works.

The instrument set-up in the field has been designed for easy installation, and isweatherproof, durable, maintenance-friendly and cost-effective (compared withmanual data collection).



*J 'JACOBS GIBB I HCGEnvironment* a

The instruments of EWS are light and the installation and maintenance does notrequire major access roads or earthworks. Electricity is obtained through solarpanels. Consequently, no significant negative environmental impacts are expected.The stations need to be fenced and all other measures should be made against theft.

A well functioning EWS provides a number of positive assets for the population andindirectly to the environment as well. Authorities should prepare an emergencyresponse plan describing the responsibilities of all the stakeholders in the event of ahazard. The meaning of an alarm and the importance of early evacuation should bemade known to everybody in the region.

Site-Specific Interventions

The Early Warning System will be installed on the Tectonic triangle and Koi-Tashlandslide slopes.

9 Pipe Bypass for Mailuu-Suu River


One of the worst case scenarios presented in the Mailuu-Suu valley is that the Koi-Tash landslide may dam the river at the Kara-Agach settlement and give rise to amajor lake, which may submerge Tailings 5 and 7 as well as some industrial andresidential areas of the Sarybiya settlement. Hazardous substances from the tailingsmay then be washed into the river. Break-up of the dam may then result in floodsand pollution of the riverside along Mailuu-Suu town and further downstream.

A proposed intervention against this threat could be the construction of a major pipebypass, which could discharge the river water through such a dam. This 450 m longpipe should be capable of draining not only the annual river discharge of 9 m3/s butalso a major part of its maximum discharge (180 m3/s). The maximum water flowvelocity in the pipe is expected to be about 7 m/s. Therefore, it would be necessaryto install two pipes about 3 m in diameter in order to obtain the required drainagecapacity. The steel pipes need to be protected against landslides with a firmconcrete casing.

At this site, the pipes could be located a few meters above the present level of theriver and thus remain dry in normal situations. The river itself would remainuntouched. Also the major drinking water pipeline from the Sarybiya water treatmentplant to the Mailuu-Suu town could run in the same protective casing. This couldsecure the provision of drinking water even in a case of a landslide.

A similar pipe bypass could also partly solve problems related to Tailings 3, 8, 9 and10 south of the Kara-Agach settlement. In this case, the pipes could be at the bottomof the river so that the entire river flow could all the time be discharged through thepipes. This intervention would immediately diminish the risk of river erosion at thetailings (especially for Tailing 8, which is partly cut by the river). In the event thatTailings 3, 9 or 10 were overrun by a landslide, the pipe could prevent the river from


** ** E JACOBSGIBB LL | HCG EnvironmentJACBSGIBB* *

dispersing hazardous substances from collapsed tailings. In the same area, thereare also hazardous chemicals stored at the Isolit industrial plant.

Construction of pipe bypasses is a long-term and rather expensive solution aimed atincreasing preparedness from a potential landslide-generated threat - the dammingof the river. If successful, the intervention could prevent submergence of tailings andsome settlements, river contamination as well as flooding possibly caused by abreak-up of the dam. Prior to making a decision to implement the construction, moresophisticated analysis on the likelihood of the occurrence of such a damming eventwould be required.

9.2 Potential Impacts and Mitigation Measures

The construction work would require an EIA of Category B. At this stage of pre-design, it is expected that the following working phases could have environmentalconsequences:

1. Planning the lay-out of the pipes, casing, access roads and earthworks;2. Earthworks at the line of the pipes;3. Transporting and installing of the heavy steel pipes;4. Laying concrete casing onto the pipes;

Activity:Planning the lay-out of the pipes, cement plant, casing, access roads and otherearthworks.

Potential impacts:* Poor planning may result in unfavorable outcomes e.g. in terms of the location of

the pipes, disturbance caused to road connections and nuisance for settlements.* Poor planning may result in landslides, erosion, degradation of the environment

at the riverbanks and deterioration of water quality in the river.

Mitigation:The design of the constructions should take place in harmony with regional planningand other land-use patterns (infrastructure, settlements, landscape, grazing areas,etc.) should be considered.

The siting of the pipes should be such that earthworks do not cause excessivedamage to the riverbanks. The locations of storage facilities, cement plant, gravelpits and excavation dump sites should be planned beforehand so that damage to theenvironment and settlements can be minimized. Steep cuttings in landslide proneslopes and excavation close to the river should be avoided.

Activity:Earthworks at the line of the pipes.

Potential impacts:* Earthworks may mobilize hazardous substances from mine tailings, waste rock

dumps and sites of polluted soils.* Excavation may result in landslides, gully erosion and washing of sediments into

the river.* Blasting of rock may trigger landslides.


A* Y1JJA;OSS GIBB EL HCG Environment

* * *

Mitigation:Special attention should be given to earthworks in the areas of tailings, miningdumps and polluted soils. Such locations should be mapped and excavated earthfrom polluted sites should safely be dumped and buried. Location of excavationdumps should be designed so that erosion and damage to landscape can beminimized.

Where the earthworks may block run-off, drainage channels strengthened withconcrete elements or stones should be constructed. Blasting of rock should takeplace in small quantities and landslide prone sites should be avoided.

Activity:Transporting and installing of the heavy steel pipes.

Potential impacts:* Transportation of heavy pipes may destroy and block local roads (there is no

alternative road for the settlements upstream).

Mitigation:At the moment, the roads are muddy and accessible only by four-wheel-drive carsduring heavy rains. Roads should be maintained before and during the transportationof heavy loads. Access roads and unloading sites should be organized so that publicroad connections remain open during the works.

Activity:Laying concrete casing onto the pipes.

Potential impacts:* The extensive and well grounded casing (4 x 7 m in diameter) may dam run-off

from the slopes and extensive water-filled basins may be formed.

Mitigation:Pipelines draining water beneath the casing should be installed in all the low-lyingterrains.

10 Relocation of Tailings


Relocation of former uranium tailings is a major undertaking with potentially seriousenvironmental problems and worker/public health risks, primarily from escape of orexposure to radioactive materials. The process requires a high degree of planning,detailed design and technological control, and the use of experienced contractorsduring operations to minimise the risks. The attendant risks of this operation aremagnified considerably in a remote part of Kyrgyzstan with limited equipment,infrastructure and specialist skills.

Relocating uranium tailings from the vicinity of urban areas has been undertaken inother parts of the world, for example, in the City of Cordoba (Argentina) and at Grand


T

4 .9

4 r'J'I JACOBS GIBB LL HCG Environment* . *. -

Junction, Colorado, USA (under the UMTRA project). Typically, in such cases thetailings were created many years ago and now reside within or close to a heavilypopulated community. In these circumstances, the long-term health, safety andenvironmental benefits of moving the tailings to a secure location have outweighedthe short-tem risks attendant to the removal process. Nevertheless, relocation isgenerally considered to be the last resort where other alternatives (e.g. in-situstabilisation or encapsulation) are not feasible.

10.2 Relocation of Tailings at Mailuu-Suu

In the case of Mailuu-Suu, there are exceptional circumstances whereby the risks ofleaving certain tailings in situ are so severe as to potentially require transfer to asafer location. This is notably the case for Tailing No 3, which is at risk of beingdestroyed and displaced into the Mailuu-Suu River by reactivation of the southernpart of the Tectonic landslide, thereby causing widespread downstream radiologicalcontamination. Should the precedent be made for removal of Tailing No 3, othertailing deposits may be relocated at the same time or at a later date.

A number of mine waste dumps also present a serious radiological and heavy metalpollution risk, notably in riverbeds or streams in the Aylampasay and Kulmensayriver valleys, and will need to be remediated and relocated.

10.2.1 Previous Studies

Relocation of tailings from the Mailuu-Suu valley as a long-term solution has beenproposed in a number of previous studies. The recommendations from theseinvestigations are briefly summarised below.

World Bank Study (1998)

The World Bank funded a study6 on risks from uranium tailings in Kyrgyzstan in1998. The study report recommended that nine tailings of greatest risk of failure ordamage be reclaimed and the contents relocated to a secure location. Theestimated cost was US$12 million based on experience of costs in Kyrgyzstan at thetime. The tailings with highest priority for removal were Nos. 5, 6 and 7. The nextpriority sites were Nos. 3, 9, 10, 17, 18 and 19.

Tacis Study (2003)

The Tacis investigation7 included a study of risks from tailings with Tailing No 3 givenpriority attention. One of the study's two long-term options provided for Tailing No 3to be transferred to an alternative location. A selected number of other tailingdeposits (Nos. 5, 7 and 8 in order of priority) were also recommended to be movedbased on a risk assessment.

The study screened a number of candidate sites proposed by the Kyrgyzstanauthorities for receiving the relocated tailings. Tailing No 15 (situated in an adjoiningvalley approximately 15 km to the east of Mailuu-Suu) was selected for further

6 Hazard Ranking and Remedial Action Plan for the Uranium Tailings Impoundments in Kyrgyzstan,Clifton Associates Ltd., December 19987 Remediation of Uranium Mining and Milling Tailings in Mailuu-Suu District of Kyrgyzstan, TacisProject No SCRE1/No38, May 2003EIA February 2004.doc 97

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intrusive investigation and hydrogeological modelling. This site was the mostpromising based on remoteness from human habitation and available capacity,although the disadvantage of extensive new road construction was acknowledged.

Tailing No 15 was proposed by the Tacis study to be the new disposal site, subjectto confirmation by more detailed investigations. It was assumed that the relocationof Tailing No 3 to this site would take 18 months and cost about US$4.4 million withradiological monitoring and radiation protection costing an extra US$0.5 million. Thecost for transferring Tailings 3, 5, 7 and 8 to the new location (Tailing No 15) wasabout US$33 million (Euro 23 million). All costs assume western standards andtechnology.

World Bank Study (2002)

A more recent World Bank study 8 developed preliminary options for improving safetyof landslides and tailings at Mailuu-Suu. Option 3 comprised tailingsrelocation/refurbishment (as set out in the Clifton Associates study) with a costestimate of US$21.7 million, which included a feasibility study, design and workssupervision and emergency works for landslide mitigation. This figure is based onthe Clifton Associates study which used local prices, and is likely to be considerablyhigher with international contractors.

10.2.2 Current Proposals

The current World Bank preparation study has considered the issue of tailingrelocation from a number of perspectives, including risk management, tailingsmanagement and social considerations.

The social assessment study9 identified the views of the local community to remedialactions and interventions based on a questionnaire and focus group meetings. Thestudy identified general concern in the local community about moving tailings,particularly aspects concerning routing and final destination. Concern wasexpressed by the local authorities on the risks, costs and technical difficulties of thisoperation. Local concerns also included potential loss of land for grazing and grasscutting, and the need for compensation.

The tailings study'° concluded that priority options for a long-term solution at Mailuu-Suu should focus on the critical tailings or the landslides, or both. Tailings Nos.3 and18 (next to the river) were considered to be of highest priority for relocation. TailingNo 9 (close to No 3) was not considered to be at risk from Tectonic but may be atrisk from the smaller Technikum landslide further to the south. The option forrelocation of this tailing was left open. However, tailing No 7 (included in the Tacisrecommendation for relocation) was regarded as an acceptable tailings location (inthe framework of Mailuu-Suu) and was considered to be a potential candidate for thenew disposal site.

8 Technical Review of Mailuu-Suu Landslides and Tailings Problems and Options forRemediation, Mission Report

Social Assessment for Mailuu-Suu Disaster Mitigation Project, January 2004, Dr H Lemel10 Tailings Specialist Technical Study, December 2003, F. HarrisEIA February 2004.doc 98

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The risk assessment study" gave similar recommendations to the Tacis 2003 study.The feasibility study for the option of transferring Tailing 3 was costed at aroundUS$1 million and estimated to take 2 years.

During the second mission in January 2004, the World Bank technical team reviewedprevious options for alleviating risks from tailings at Mailuu-Suu. In connection withrelocation of tailings, the consensus view was to proceed with a feasibility study fortransferring Tailing 3 (and the adjacent No 18) to a safe site. Candidate disposalsites comprised Tailings 6 and 15.

The feasibility study will evaluate a number of aspects including the physical andchemical characterisation of the tailings, the need to dewater the tailings beforeremoval (for Tailing No 3), technical, safety and cost effectiveness considerations inexcavation and transport, and the selection of the disposal site. An environmentalrisk assessment is to be an integral part of this study. Major environmental aspectsthat should be included in this assessment are discussed below.

10.3 Environmental Considerations

10.3.1 Outline of Relocation Process

The procedures and methodology to be followed in a tailings relocation programmeat Mailuu-Suu have not been developed in any detail. However the process ofrelocating tailings from their current location to a new disposal site can in simpleterms be considered a three-staged operation:

* Excavation* Transport* Disposal

Excavation of Existing Tailings

Excavation of Tailing 3 poses a number of technological problems due to thesaturated nature of parts of the tailings, general instability and restricted location.

Tacis (2003) envisage that excavation of the material (consisting of mud or paste)will require a dragline or large cableway excavator in order to avoid machinesmoving on top of the excavated material. Provision will be made for waste to partiallydrain on the edge of the tailings before being loaded into steel containers.Alternatively, an option for partial dewatering the tailings could be undertaken beforeexcavation using the above method, although the feasibility of this was uncertain.This will require provision of a secure facility for temporarily storing tailings effluentas well as on-site wastewater treatment facility.

Excavation of other tailings was considered to be less problematic by Tacis (2003)as these are drier and less radioactive, hence traditional methods could be used (i.e.excavator and dump trucks).

Transport of Tailings to New Site

" Risk Assessment Mailuu-Suu, Detailed Working Paper, December 2003, Dr H. Quarch etalEIA February 2004.doc 99

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Tacis (2003) considered two options for transport of highly radioactive material fromTailing 3. The first option comprised hydraulic transport (as slurry) in a reinforcedsteel pipeline from the tailings to the disposal site. This was discounted due totechnical difficulties.

The second and preferred transport option was shipping the material from Tailing 3in reinforced sealed containers, with sealed lockable covers, that are loaded ontotrucks. Transport of drier tailings from other deposits could be done by dump trucksequipped with sealed and lockable bodies.

Based on the quality of material in Tailing 3 (about 60,000 tonnes), Tacis (2003)estimated that the relocation would need approximately 4000 x 15-tonne truckmovements and could take up to 18 months. The removal of material from T3, 5, 7etc could take up to 5 years.

Disposal of Tailings at New Site

The new disposal site and the haul road will need to be prepared and constructedahead of excavations. The sealed waste containers will be loaded aboard trucks thatcannot drive on waste in the new disposal cell. In this case, the Tacis (2003) reportenvisages a crane with a large boom will be used to transfer the contents ofcontainers to the storage cells. Adequate inert material will be needed to providecover for the completed cells.


Each of the three relocation stages has particular environmental (including healthand safety) risks and these in turn will depend on other factors such as the nature ofthe material being moved, the sensitivity of the transit route and the suitability of thefinal destination.

A brief summary of the main environmental risks and proposed mitigation measuresfor the main activities in each of the above stages is given below. Disposal siterequirements are discussed in Section 10.4.

Potential major impacts

Relocation of uranium tailings at Mailuu-Suu will be problematic and raise potentiallyserious environmental and health and safety impacts. The major aspects that willneed addressing are as follows:

* Spillage of tailings material outside excavation area;* Accidental spillage of container contents during transport;* Release of contaminated tailings effluent into river/groundwater;* Release and downwind dispersal of radon and radioactive dust;* Radiological exposure of workforce;* Public health concerns from dispersal of radioactivity (radon, dust);* Restricted public access on the road next to the remediation site;* Concerns over residual radioactivity at the reclaimed site.

Mitigation Measures


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In order to manage the above risks, the following measures will need to beincorporated into the design and operation of the relocation program:

* The design should include a safety risk assessment to ensure the specificationfor the works has adequate safeguards to protect the environment andworker/public safety.

* An atmospheric dispersion modelling study should be completed to determinethe likely health impact of radon and dust emissions at nearby receptors.

* The Contractor will be required to follow an Environmental Management Plandeveloped as part of the Environmental Impact Assessment (EIA).

* An Environmental Monitoring Plan (baseline, during operation and post clean-up) will be required to ensure that mitigation measures are effective. This willinclude radiological monitoring for environmental media.

* A Spill Pollution and Prevention Plan should be developed by the Contractor tominimize risk of spillage and address emergency response measures.

* A Safety Management Plan will be required to address risks to the workforceand public. This should include safety training, personal protective equipmentand radiological dosimetry.

* A Community Liaison Plan is needed to address concerns of the localcommunity. A public awareness program to explain the need for andimplications of tailings relocation should precede operations.

* Measures should be taken to prevent generation and dispersion of fugitive duste.g. by preventing the tailings from drying out, by limited application of watersprays and avoiding the use of stockpiles.

A clean-up standard is not necessary for the excavated site as the objective is toreduce risk rather than provide remediation. However, the excavated area will needto be covered with a suitable layer of clean inert fill to reduce radiological exposure.

The proposed feasibility study of relocating tailings will determine the impacts andmitigation measures in greater detail and lead to proposals for the best practicalenvironmental option. The preferred option will subsequently require a detailed EIAto address the actual environmental and social effects based on the detailed designof the Project.

10.4 Disposal Site Considerations

10.4.1 Design Criteria

The main objectives of the new tailings disposal site should be to:

* Provide stable long-term storage of uranium tailings;* Reduce radon emanations to acceptable levels;* Protect groundwater from surface water infiltration through the tailings.

Design criteria to meet these objectives will need to be set. Based on US EPAstandards, these could include the following:

* The disposal site shall be designed to control tailings for at least 200 years;


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Atmospheric release of radon-222 shall not increase the annual averageconcentration at any location outside of the disposal site by more than 0.5picocuries per liter.

The new disposal site should be designed in accordance with western standards forhazardous waste disposal sites suitable for uranium tailings. These incorporate animpermeable basal geotextile liner, separate engineered cells and a composite coverto reduce radon emanation and infiltration of surface water. A further requirementshould be that safe disposal for the prescribed period of time must be assuredwithout active maintenance.

10.4.2 Site Selection Criteria

A key aspect in the tailings relocation process is the selection of the disposal site.This needs careful analysis to ensure the new site provides secure long-term tailingsstorage and is capable of meeting the design criteria. A screening process isrequired to evaluate candidate sites, with a selection taken forward for detailedevaluation.

Screening criteria must include environmental, geophysical, geotechnical andhydrogeological attributes as well as socio-economic considerations. The followingenvironmental criteria represent ideal attributes for a hazardous waste disposal site:

* Seismically stable;* Not at risk from landslides;* Not located on a geologic fault;* Level topography;* Not in vicinity of river/flood plain;* Have naturally impermeable sub-strata;* No shallow groundwater;* Abundance of clay material for lining and covering the deposit;* No conflict in existing/planned land use;* Low ecological sensitivity;* Remote from human habitation;* Ease of access (for transport).

It is recognised that no site will meet all these criteria and that a compromise willneed to be found. This is particularly the case in Mailuu-Suu where there is alreadylimited availability of suitable sites. Nevertheless, the chosen site must guarantee aminimum level of environmental protection.

10.4.3 Preliminary Evaluation of Candidate Sites

During the first mission a preliminary evaluation was made of the suitability of fourpotential sites for tailings disposal. The sites were chosen on the basis ofrecommendations from previous studies and suggestions from members of thetechnical team, based on the area reconnaissance. The four sites are as follows(see Figure 5.1 for location):

* T1/T4 - the existing tailings situated close to the Aylampasay River andabout 2 km north-west of Mailuu-Suu town.


* * ~I4 JAfOBSGIBB7 II R ½ HCG Environment

* T6 - an existing tailings site situated midway between Kara-Agach and Sary-Biya about 300 m up-slope from the right bank of the Mailuu-Suu river.

* T15 - an existing tailings site situated approximately 15-20 km east ofMailuu-Suu town along the dirt access road just north of the Kulmensay Rivervalley (this site was not visited and is not shown on the Figure - informationcomes from the Tacis 2003 report).

* W3 - a greenfield site situated on a level area of ground about 5 km east ofMailuu-Suu along the above dirt road and just south of the junction leading towaste rock dump No 3.

It is recognized that there may be other tailings disposal sites that are appropriate forscreening and evaluation (e.g. Tailing No 16 mentioned in the Tacis 2003 study).

Table 10.1 provides a comparison of selected environmental criteria for the fouralternative disposal sites, assuming material will be taken from Tailing No 3. Theassessment is qualitative with a "+" indicating that the criteria is met and an "O"signifying that the site is unsuitable. The magnitude is denoted by multiple symbols.

Tailing No 15 is likely to be the best site on environmental grounds. The socialsurvey also gave a favorable response to this site as it is remote, uninhabited andseldom used for livestock. However, the existing dirt road is in poor condition. It willrequire extensive refurbishment and possible realignment (for passing points andoptimal grading) before use as a haul road for heavy trucks (although it wasoriginally used for this purpose in Soviet times). There are also safety concerns asthe road is steep with a number of hairpin bends, the surrounding terrain is veryrugged and the return haul distance is about 30km. An accident involving a 15-tonneloaded truck leaving the road would have serious consequences for driver safety andtailings recovery. Rehabilitation of this road will therefore require high capital outlayand generate significant disposal costs.


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Table 10.1 Environmental Screening of Four Disposal Sites

Alternative Disposal Sites for T3 TailingsEnvironmental Criteria

T1/T4 T6 T15 W3Seismically stable 0 0 + 0Absence of landslides + 0 +++ +Level topography + 0 ? +Existing tailings site + + + 00No conflict in land use 0 0 ++ 0Not close to river/floodplain 0 0 ++ +Remote from habitation 000 0 +++ ++Low ecological sensitivity + + ++ 00No shallow groundwater 0 0 ++ +

Local construction material + + + +

Low visual impact + + + 0Established road/access + + 000 00

TTailing Nos 1 and 4, despite being suitable on a number of criteria and havingadequate capacity, are effectively ruled out on grounds of public acceptability andsafety (they will require transit of radioactive material through Mailuu-Suu town andpast a school); and because their reuse as an active site will result in loss of scarcegrazing land. Both these aspects were identified as major issues of concern by thesocial survey.

The level greenfield site (W3) has a number of advantages as the haul road wouldbe much shorter than for Tailing No 15 while still offering a route that does not transitresidential areas. Disadvantages include the greenfield status and loss of grazingland. This area has also been earmarked as a potential site for the storage ofmaterial offloaded from the top of Tectonic landslide.

Tailing No 6 has a less favorable environmental profile than Tailing No 15. Howeverit offers a good compromise for a disposal site for material from Tailing No 3 as it hasa short haul route over an established road that does not go through residentialareas (although haul trucks would travel past the Koe-Tash landslide zone). It maybe possible to separate community traffic (on a new road alignment along the rightbank north of Kara-Agach) from site trucks on the left bank. This site is also not atserious risk from flooding and could be protected from minor landslide damage.


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11 Infrastructure Interventions

Infrastructure interventions of the Project will be of secondary nature and they willeither support other interventions or be related to the possible natural disastersconsidered in the Project. Some interventions may also have potential impacts to theinfrastructure of the valley.

Existing Road Network. It is anticipated that the Mailuu-Suu - Sarybiya road will beextensively used within the Project and therefore needs to be at least partlyrehabilitated and maintained. Some impact to road transport will occur during theconstruction period in rehabilitation areas due to detours and traffic inconveniences.Subsequently, the primary transport impact of the Project will be to improve theperformance of roads and facilitate the flow of traffic, goods, and travelers. At thisstage of pre-design, it is expected that the following working phases could haveenvironmental consequences:

Activity:Transportation of machinery, rock materials, maintenance goods, fuel and labor tothe Project sites as well as working with heavy machinery on the area of publicroads.Potential impacts:* Surface of the road may be destroyed and during wet periods roads may

become inaccessible for ordinary cars;* Working with heavy machinery in public roads may occasionally block roads.Mitigation:It is recommended that contracts specify that care must be taken during theconstruction period to ensure that traffic disruptions to road transport are minimized.

New roads. Intervention stabilizing landslide prone slopes may use some existingroads (e.g. road to the tailing 15) and also new roads must be constructed to theexcavation and dumping sites. Best practices of road construction should be applied.In the construction, the following measures should be considered:

Activity:Planning and constructing of new roads to the Project working sites.Potential impacts:* New roads may disturb settlements and spoil landscape;* Roads may accelerate erosion and destroy pasture areas.Mitigation:The design of the constructions should take place in harmony with regional planningand other land-use patterns (infrastructure, settlements, landscape, grazing areas,etc.) should be considered.The siting of roads should be such that earthworks do not cause excessive damageto the riverbanks, slopes and settlements. Steep cuttings in landslide prone slopesand excavation close to the river should be avoided. Storm water drainage systemsshould be constructed in areas sensitive to erosion.


* JACOBS GIBB iL | HCG Environment

Fig. 1. 1. Earth works of the Project may damage public roads and they need to berepaired and maintained in order to avoid disruption for people.

Water Supply Systems. Most of drinking water to villages is ied in a pipeline fromthe reservoir upstream of the Project area. Major landslide could potentially destroythe pipeline. This has happened several times in the past and it has been necessaryto construct a new pipeline. Therefore, the settlements must have alternativesources for water supply. Any appropriate aquifer suitable for such purpose shouldbe protected. Downstream, in Kok-Tash, people are using river water for drinkingpurposes and this sets tight water quality requirements for the river.

Project contract documents will contain provisions requiring pre-construction monitorof existing water quality to provide a baseline for the measurement of impacts duringthe construction period. Routine water quality monitoring will also be required inareas of high potential impact (intervention sites, construction of new dumping sitesand other areas of potentially contaminating runoff) during the life of the Project. TheProject will have no direct impact on area water supply systems as long as bestpractices of works are applied. Run-off from construction activities could affect rawwater supplies and even dangerous substances can be mobilized if interventions arenot carefully done.

Waste Disposal. Contacts for the Project will include enforceable provisions for theproper disposal of waste. Implementation and enforcement of the provisions will bethe responsibility of the Construction Supervision Consultant. Potential wastedisposal impacts could occur to the improper disposal of construction waste, wasteoil and solvents, and human waste from construction camps. Other issues includeremoval of potentially polluting substances from the landslide or flood prone areas aswell as management of industrial waste land-fills and contaminated soils.

Closure of mine tunnels in order to prevent people to enter these and to receiveradiation. People are collecting scrap metal and this is a very important source ofincomes in the villages (especially in Kara-Agach; see Socio-economic Analysis).

EIA February 2004 doc 106

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Sewerage Systems. The Project will have no direct impact on area seweragesystems.

Energy Systems. The Project will have no direct impact on area energy systems.However, some electrical distribution systems and oil pipelines are within thepotentially landslide impacted area.

12 Generic Environmental Impacts and Mitigation Measures

12.1 Introduction

This chapter is describing environmental, socio-economic and cultural issues relatedto all the interventions proposed. Also cumulative and residual impacts will becovered. The chapter also describes the compliance of the environmentalconsideration with World Bank policies.

12.2 Noise and vibration

Noise and vibration may become a problem in interventions, which involveexcavations, blasting, heavy transportation, piling work, pumping as well asproduction of concrete and asphalt. After the construction phase, only pumping noisewill continue in the landslide stabilization sites. Noise may disturb nearby populationof the residential areas and vibration may damage lightly constructed buildings notdesigned to withstand such vibrations. Strong vibration may also trigger landslides insensitive slopes.

The magnitude of impact will depend upon the specific types of equipment to beused, the construction methods employed and the scheduling of the work and noiseattenuates quickly with distance. General conclusions can be based on the types ofconstruction work anticipated, the types of equipment required and their associatedrange of noise levels.

Vibration during the construction period will also be a significant consideration,particularly during pile driving and blasting operations. It is recommended that thatnoise and vibration impacts during the construction phase will be mitigated throughthe following means:

* Machinery (excavators, bulldozers, trucks, aggregates, etc.) provided withproperly designed exhaust systems, engine enclosures and intake silencers mustbe employed and regular equipment maintenance will be undertaken;

* Silent pumps should be used and when located close to settlements they shouldbe located in cabins effectively attenuating noise.

* Stationary equipment must be placed as far from sensitive land-uses as practicalin places selected to minimize objectionable noise impacts and provided withshielding mechanisms where possible. Concrete and asphalt plants shall belocated at least 500 m away from the nearest sensitive receptor (e.g., schoolsand hospitals).

* Construction activities will be strictly prohibited between 22 and 6 a clock in theresidential areas.


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Routine monitoring of noise and vibration will be required in areas of high potentialimpact (pile driving and blasting sites and areas of intensive noise-generatingactivities) during the life of the Project.

12.3 Air Quality

During the construction phase of the Project, air pollution in a form of dust mayoriginate from excavation and dumping sites as well as from truck traffic. If tailingswill be exposed, also dangerous dust containing e.g. radionucleids may be blown up.Site inspections and routine monitoring of air pollution by environmental authoritiesshould be carried out. In addition, contract provisions should also ensure that:

* Dust-generating items will be conveyed under cover and trucks carrying earth,sand or stone will be covered with tarps to avoid spilling.

* Exposed surfaces, excavation and construction sites will be water sprayed tokeep them moist for dust control.

* Blasting is carried out using small charges.* Solvents and volatile materials shall be used and stored properly;* Open burning of waste, oil, etc. is prohibited.

12.4 Socio-Economic Issues

The overall planning of the Project must consider its potential socio-economicimpacts on settlement patterns, communities, employment and income trends andresettlement issues. Details of impacts and mitigation actions related to socio-economic issues of the Project are provided in the accompanying Social Analysis.Potential impacts on individuals should be assessed together with the communityimpacts likely to affect communities as economic and social entities.

No significant changes in settlement patterns are anticipated as a result of theproposed interventions. The government has already resettled people who used tolive in dangerous areas. Few housing displacements are likely to occur due to theProject activities. However, it is advised that some houses could be moved to saferplace because of radiation (radon) problems and threat of landslides. If displacementwere to result in the loss of a house or shelter, every effort shall be made to ensurethat new housing is available before occupants are required to relocate. Relocationdistances and disruptions of local support networks shall be minimized. Relocationhousing shall be provided within the same general area.

One of the primary objectives of the Project is to improve environmental conditionsand safety of life in the area. Local residents will benefit from improved safetyconcerning radiation, pollution and reduced risk of landslides. Farmers and dealersof food products will benefit from decreased contamination in the products and betterimago of the area as a producer of clean foodstuff. Consumers, in turn, will obtaincleaner agricultural products. Many agricultural households cultivate fruits andvegetables for sale in local markets. The Project will help alleviate poverty throughthese benefits.

Land-use issues will probably be the most important reasons for conflicts. Somepasture areas may be lost due to earth works and some tailings may be fenced inorder to prevent harmful radiation and chemical contamination of entering peopleand livestock (see Chapter 7). According to socio-economic surveys local farmers


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highly value all the land in the valley as pastures. There are few job opportunitiesand people are dependent much on livestock. Therefore, as much as possible thetailings, waste rock dumps and excavated areas should be turned to pastureswhenever the pollution problems have been solved.

A potential landslide may block the road connections in the valley and isolatecommunities upstream. Prevention of landslides will help to maintain the roadconnections and to provide services to the villages there. The earth works in theintervention may occasionally disturb traffic on the roads, but later on roads will berepaired to a better condition what they are now.

Conversion to higher value land uses occurs when the value of land in a particulararea is increased by infrastructure improvements leading to higher rental values,occupancy turnover and a replacement of previous tenants and residents by thosewho can afford higher rents. No significant adverse impacts of this type are expectedas a result of the proposed road rehabilitation and interventions of the Project.

Major construction activities (e.g. pipe bypass) present potential impacts to land-uses that could have long-term effects in certain circumstances. No significantchanges in existing regional land-use patterns are expected as a result of theinterventions. The majority of the land is devoted to agricultural uses, mostlypastures. The current ratio of agricultural land-use to other land-uses is unlikely tochange significantly due the interventions. The potential land-use impacts are likelyto be minimal and those localized impacts that do occur are likely to be beneficial.Proper planning and coordination can mitigate the negative impacts on land-use.

It is recommended that contracts for the Project activities require constructionoperators to attend to the health and safety of their workers, maintain and cleanupcampsites, and respect the rights of local landowners. Written agreements with locallandowners for temporary use of the property should be required and specify thatsites must be restored to a level acceptable to the owner within a predetermined timeperiod.

Some disruption of existing economic activities could occur in the constructionperiod. However, the construction budgets and expenditures will have a majorbeneficial impact on the Project area's income and employment characteristics.Following construction, the increased safety and road improvements themselvesmay contribute to the development potential of some areas, including increases inincome and employment.

With the possible exception of the land-use restrictions of the Project, no adverseimpacts are anticipated under the heading of population and communities.

12.5 Cultural Heritage and Landscape

As described in the baseline studies, there are no archaeological and historicdesignated objects in the vicinity of the proposed Project sites. Interventions, roadconstruction, quarries and gravel pits may damage traditional village patterns andaesthetic values. No designated cultural resources are known to exist within oradjacent to any of the sites. Visual observations during field investigations of thearea revealed no architectural or cultural potential objects within the potential impactarea.


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However, based on the rich heritage of archaeological and cultural finds within theFergana region, there is a strong likelihood that undiscovered archaeologicalremains exist along the course of the Mailuu-Suu river in the north-east part of theFergana Valley. Thus there is potential for significant archaeological finds to be atrisk from a severe.flood/pollution event in the area of Mailuu-Suu involving uraniumtailings and the downstream dispersal of radiologically contaminated sediment.

Landscape of the area is very sensitive for disturbances, because of the steep andnon-forested slopes of the valley. Excavations, road constructions and dumping onthe mountain slopes may detract the aesthetic values of the valley. Whereverpossible, these issues should be considered in the planning. Revegetation ofexcavated areas as soon as possible would solve the major part of the problem.

The Project will therefore have no adverse impact on cultural heritage. On thecontrary, a long-term benefit of the Project will be to significantly reduce the risk of asevere radiological pollution incident and assist in safeguarding undiscoveredcultural property that potentially lies within the flood plain downstream of Mailuu-Suu.

12.6 Cumulative and Residual Impacts

Several interventions requiring earth works and taking place simultaneously maycumulatively decrease water quality in the river. Construction of roads, ditches anddams and unloading heads of potential landslides may generate murky water. Onemethod to stabilize landslides is the construction of drainage systems to the slopesand they may lead silty water to the river. During heavy rains erosion may occuralong the drainage systems and increase suspensions. This may cause also residualimpacts on the river.

There is a risk that multiple interventions that result in discharging of sediment-ladenwater into the Mailuu-Suu River will increase total suspended solids. This couldadversely affect fish species (e.g. blanketing of spawning areas during low flowconditions). There is a need to ensure water recovered from dewatering landslides isdischarged to a settling basin before disposal in the river.

Avoiding earth works during snowmelt and rainy season can prevent siltation of riverwater. Sedimentation basins should be constructed to the drainage systems. Areasof excavations should be minimized and erosion control measures applied wheneverwide areas are exposed to run-off.

Increased traffic (workers, trucks, bulldozers, etc) may occasionally block roads,damage road surfaces and heavy traffic may generate muddy water ponds to theroads. Traffic must be organized so that other traffic will not be disturbed and roadmaintenance should take place all the time during the Project works. At the end ofthe Project, roads should be repaired.

Cumulative and residual environmental impacts may be generated in sites wheretailings are excavated. In such interventions, special care should be taken that all thepoisonous deposits are well covered and that there will be no leaks to theenvironment.


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12.7 Compliance with World Bank Safeguard Policies

The Project is not expected to result in any potential large scale, significant and/or irreversible impacts. Projectcompliance with Bank Safeguard Policy requirements is discussed below.

Environmental Assessment (OP 4.01)

The Project triggers OP 4.01 and is rated B, thus an Environmental Impact Assessment (EIA) is being undertaken.The EIA is being undertaken by a team of local and international experts under the EU JEPII programme, andincludes preparation of an Environmental Management Plan (EMP) and a programme of public consultation, both inBishkek and Mailuu-Suu. The EIA will be submitted to and reviewed by the Bank to ensure full compliance with Bankguidelines (including public consultation and disclosure).

Oversight of the implementation of the EMP will be the responsibility of the Borrower. Implementation of mitigationmeasures (e.g. covering pollution prevention, protection of natural resources practice, and worker and public safety)will be passed on to the Contractor who will be required to follow guidelines for environmentally sound constructionpractice. These requirements will be included in bidding documents and meeting them will be a contractualrequirement of the works. The EMP will also cover monitoring requirements during the ongoing operational phase ofthe Project.

Natural Habitats (OP 4.04)

The Project will not have a significant impact on natural habitats. The majority ofareas subject to the proposed interventions are currently degraded, either by currentand historical anthropogenic activity e.g. industrial waste, mine tailings and wasterock dumps, or by natural processes e.g. landslides, mudslides and large scaleslumping. Measures will be taken during construction to mitigate adverse effects onlocal fauna and flora. Proposed short-term interventions to be financed by the Projectwill reduce the risk of landslides and radiological pollution of natural habitats, notablythe Mailuu-Suu river system. The measures may include the rehabilitation of anumber of uranium tailings areas so that they may be returned to the localcommunity as safe grazing pasture. The Project will therefore support the Bank'spolicy of promoting improved land use and the rehabilitation of degraded naturalhabitats.

Cultural Property (OP 4. 11)

This safeguard policy is not triggered as cultural property including archaeologicalsites, ancient monuments and unique natural features have not been identified withinthe Mailuu-Suu valley where these may be affected by the interventions. There is,nevertheless, potential for archaeological sites to exist within the flood plain of theupper Fergana valley within the Project's broader area of influence. A long-termbenefit of the Project will be to significantly reduce the risk of a major disasterinvolving the release and downstream transport of radiologically contaminatedtailings material into the river system of the upper Ferghana valley. The Project willtherefore assist in safeguarding undiscovered cultural property that potentially liewithin the flood plain downstream of Mailuu-Suu, and which could otherwise beblighted by contaminated sediment.

Involuntary Resettlement (P 4.12)

The Project will not require involuntary resettlement of communities or individuals.Interventions will take place on landslides and tailings, which are non-populated.Construction works associated with the Project will include rehabilitation andrealignment of the existing road within the Mailuu-Suu valley so as to avoid areasprone to landslides. The local authorities own the land and associated rights of way


L s C] JACOBS CIBB HCG Environment

in these areas and other parts affected by the interventions, hence there will be norequirement for land acquisition. Temporary disturbance to the local communityduring construction works (e.g. traffic diversion, dust, noise) will be mitigated throughimplementation of measures set out in the Environmental Management Plan.

However, Project interventions associated with tailings have the potential to result inloss of grazing pasture that is of major importance to the livelihood of certain localcommunities, hence the resettlement safeguard will apply to the Project. A ProcessFramework will be prepared before appraisal to address this issue. There is a criticalshortage of suitable grazing land in the area. Hence measures are proposed toensure (where feasible on grounds of engineering and radiological health) that anumber of tailings areas are rehabilitated so that they may be returned to the localcommunity for safe grazing. In other cases, compensation will be considered whereloss of grazing land is otherwise unavoidable.

A number of dwellings are directly at risk from landslides (e.g. in Sara Beya) whileothers (e.g. in Kara Agach) have been constructed from radiological waste andtherefore place the occupiers at unacceptable health risk. The Project envisages thatthese properties are subject to compulsory purchase and the affected personsrelocated to an area that provides them with an equivalent livelihood. A LandAcquisition/Resettlement Policy Framework is being prepared to address this issueand will be cleared before appraisal.

Safety of Dams (OP 4.37)

The World Bank distinguishes small dams (less than 15 m in height) from largedams. Small dams within the Project are confined to tailings embankments. Theproposed tailings interventions programme includes provision for ensuring thatexisting small dam structures that are at risk are strengthened.

There are two large dams in the Project area. The headworks dam on the Mailuu-Suu river lies a few kilometres below Mailuu-Suu town. It is used for irrigationpurposes but silting has diminished its effectiveness for flood control. None of theproposed interventions will affect this structure.

The Project area includes a large dam situated at Kutman Kul ('Holy Lake')approximately 30 km upstream of the town. The reservoir was formed by a rock falland the dam has a thickness of approximately 35-40 m. This reservoir feeds theMailuu-Suu river and provides the water supply for Mailuu-Suu town. The dam wasinspected annually in Soviet times by helicopter but the last inspection was in1966/67. Although the integrity of this rock fall dam is not believed to be at risk, theremay have been continued degradation through natural erosion. The Project thereforeincludes a monitoring program to study the stability of the structure.

Intemational Waterways (OP 7.50)

The Project triggers OP 7.50 as the Mailuu-Suu river flows into the Naryn and SyrDarya rivers which are international waterways as defined by Paragraph 1(a) of OP7.50. The Project interventions are designed to reduce the risk of landslides andconsequent flooding and pollution of the Mailuu-Suu river system.


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Potential changes in water flow or deterioration in water quality during theconstruction works will be mitigated through implementation of the EnvironmentalManagement Plan. It is considered that the Project interventions will not materiallyaffect the quality or quantity of water flows to downstream riparians.

A notification letter was sent in January 2004 to Uzbekistan, Tajikistan andKazakhstan to inform these riparian states about the proposed interventions and torequest comments and possible support for the proposed Project.

13 Environmental Management and Monitoring

An Environmental Management Plan (EMP) has been prepared for the Project. TheEMP establishes a framework for the identification and implementation ofenvironmental protection, mitigation, monitoring and institutional strengtheningmeasures to be taken during Project implementation to avoid or eliminate negativeenvironmental and social impacts.

The EMP includes the following elements:

* Environmental mitigation and monitoring plan (EMMP)* Monitoring measures to be taken during Project implementation* Institutional arrangements for implementing the EMP* Implementation schedule and cost estimate* Contractor requirements for EMP implementation* Guidelines for environmentally sound construction practice

The EMP has been prepared as a separate stand-alone document to the frameworkEIA.

14 Public C=ltation

Two public hearings, one in Bishkek and another in Mailuu-Suu, were organizedjointly in early February 2004 by the environmental and socio-economic teams. Thisfollowed an initial public presentation of the Project outline by World Bank andtechnical team representatives in Mailuu-Suu in November 2003.

The public consultations were chaired by the Director of the Department ofEmergencies Monitoring and Forecasting and Mining Tailings Management of theMinistry of Environment and Emergencies. The hearings were attended byrepresentatives of the World Bank and the technical team, and were led by local andinternational consultants representing the environmental and social teams.


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A record was taken of the names of participants, meeting minutes, and verbal andwritten comments received during the sessions. The Chairman noted that accountwould be taken of the issues raised by the attendees and requested persons tomake a written submission of any aspects they wish to be considered duringsubsequent Project planning.

A summary of the main findings from each session is given below.

Mailuu-Suu

Approximately 300 persons attended the Mailuu-Suu public hearing held onSaturday 7 th February 2004. There were 34 written responses from the participants.Of these, 12 were comments on environmental and socio-economic issues. Themain issue raised was the need by the local community for improved infrastructure(clean water, sewage, better roads) and concern about ill-health.

Concern was also expressed on the lack of information on radiation levels and theireffects. Several people were concerned about radiation exposure from the tailingsand abandoned mines (a case was cited of children playing football on the tailings).Two comments were made about the need to monitor radiation levels of local dairyproduce and other products. Several comments were also received on the need forlocal people to be employed during the intervention works.

Bishkek

Approximately 60 people attended the Bishkek public hearing held on Tuesday 1 0th

February 2004. Attendees represented governmental officials, NGOs, academia andmembers of the public. Discussion took place on a range of issues connected withthe interventions, including the EIA process, reprocessing of tailings, priority ofinterventions, the reliability of the social survey data, and exposure to radon and theprevalence of cancer in the local community.

There were 5 written responses from the participants covering mainly socio-economic issues. The main issues raised were the need to prevent radiological-related diseases in the local community and to work closely with the local populationto raise awareness of risks from radiation. Priorities associated with the interventionswere also discussed. Attendees generally acknowledged the poor quality of healthdata and the need for a better understanding of the causes of ill-health in the Mailuu-Suu area.

A clear message from the session was to ensure that other studies being conductedin Kyrgyzstan which complement the proposed interventions should be taken intoaccount by the World Bank Project. In particular, the need was expressed to uselocal specialists from Kyrgyzstan to assist in Project implementation.

'Ministry of Environment and Emergencies, Ekologiceskaya Bezopasnost' Kyrgyzstana (EcologicalSecurity of Kyrgyzstan, 1998, page 46.


Table 6.1a Scoping of Potential Environmental Impacts from Proposed Interventions at Mailuu-Suu (Construction Phase)

Physical Biological Socio-EconomicCommunity

Intervention Soils Landscape Surface Ground Fauna Flora Protected Noise Air Traffic Land Health & Visual Cultural(erosion) Water Water Areas Quality Use Safety Impact Heritage

Landslide Interventions

Unloading

Dewatering - - - -

Stormwaterdrainage - - -

Early warningsystemDam prevention(pipe bypass) - - -- - - - -

Tailings InterventionsRestrictedaccess (fencing) - - -

Capping &revegetation - - - - - - - - -

Stormwaterdrainage - - -

Riverbankstrengthening - - - - - -

Toestrengthening - - - -

Infrastructure Construction/RehabilitationRoad works and I l lupgrades I - I - I - I - -_I - I - I -

Note: - denotes adverse impact; + denotes beneficial impact; no entry denotes an insignificant or neutral impact

Table 6.1b Scoping of Potential Environmental Impacts from Proposed Interventions at Mailuu-Suu (Management Phase)

Physical Biological Socio-EconomicCommunity

Intervention Soils Landscape Surface Ground Fauna Flora Protected Noise Air Traffic Land Health & Visual Cultural(erosion) Water Water Areas Quality Use Safety Impact Heritage

Landslide Interventions

Unloading +

Dewatering + _

Stormwaterdrainage +Early warning ++systemDam prevention(pipe bypass) +

Tailings InterventionsRestrictedaccess ++Capping & + ++revegetation + + + + +Stormwater X+drainage + + +Riverbankstrengthening + + +Toestrengthening + +Infrastructure RehabilitationValley road |

upgrade I o + +

Note: - denotes adverse impact; + denotes beneficial impact; no entry denotes an insignificant or neutral impact

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