Iee Water Sector - Mar 29, 2008

Karachi Water and Sewerage Board City District Government Karachi

Karachi Mega City Sustainable Development Program

Initial Environmental Examination Water Sector Subprojects Water Treatment Plants and Water Distribution Mains

Document Stage: Final Report Document Date: March 29 2008

The initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary in nature.

Karachi Mega City Sustainable Development Program MFF Tranche 1 IEE Report for Water Treatment Plants and Water Distribution Mains Subprojects

CONTENTS

I. INTRODUCTION.......................................................................................6 II. DESCRIPTION OF WATER SECTOR SUBPROJECTS.........................9 Water Supply to Karachi......................................................... ........................9 Water Distribution................................................................. ..........................9 Operational Issues............................................................................. ...........10 Water Quality.............................................................................. ..................10 Filtration Plant Extensions ...................................................................... ......11 Pipeline Route........................................................................................... ....11 Filtration Plant Extensions at COD and NEK Plants........................... ...........11 New Transmission Mains from Pipri to Korangi and Malir Town....................12 Distribution Network Improvement Programs............................................. ...12

III. DESCRIPTION OF ENVIRONMENT....................................................14 Physical Environment.......................................................... .........................14 Biological Environment....................................................... ..........................15 Social and Cultural Environment............................................................ .......16 COD Filtration Plant.......................................................................... ............18 NEK Filtration Plant........................................................ ..............................18 Pipri-Landhi Pipeline......................................................................... ............21 Pipri-Malir Pipeline............................................................................. ...........21

IV. ENVIRONMENTAL IMPACTS AND MITIGATION................................25 Planning the Construction Works........................................................ ..........27 Replacement of Trees............................................................................. ......29 Dust Impacts during Construction................................................... ..............29 Noise During Construction............................................................ ................30 Asbestos Management............................................................. ....................31 Other Issues Related to Pipeline Construction.......................................... ....31 Public Safety.......................................................................................... .......32

V. STAKEHOLDERS CONSULTATION.....................................................35 Meetings with Residential Consumers........................................ ..................35 Landhi Association of Trade and Industry............................ .........................35 Korangi Association of Trade and Industry............................................ ........36 Urban Resource Centre.................................................................. ..............36

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VI. INSTITUTIONAL REQUIREMENTS AND ENVIRONMENTAL MANAGEMENT PLAN.......................................48 VII. FINDINGS AND RECOMMENDATIONS.............................................56 VIII. CONCLUSIONS.................................................................................58 Asbestos cement pipes shall be carefully excavated, lifted on to plastic sheets, wrapped in polythene and sealed with duct tape to be transported to the designated storage area or landfill.........................74 The procedure shall follow the measures indicated below:...........................74 1)The CONTRACTOR shall implement all the procedures in Appendix 2 of the AMF and make available all the materials in Appendix 3 of the AMF. 74 2)The CONTRACTOR shall agree to remove and transport all the wrapped asbestos (ACP) from the sites to secure temporary buffer store(s) designated by DOE - CDGK to await disposal........................ ............74 3)The CONTRACTOR shall provide approved protective clothing to all workers and DOE – CDGK inspector as and when requested............74 4)Workers handling the asbestos cement pipes shall wear the personal protective clothing provided.............................................. ..................74 5)The DOE - CDGK Asbestos Specialist inspector shall visually inspect the preparation before instructing the Contractor to proceed....................74 6)The DOE - CDGK Asbestos Specialist inspector shall monitor the works and carry out a visual inspection to certify that all the ACP have been removed to a satisfactory standard in line with Appendix 2 of the AMF. 74 7)The DOE - CDGK Asbestos Specialist inspector will check and record the number of packs of waste transferred to the lorries are the same as those that arrive at the temporary buffer or landfill using a trip ticket system............................................................................... .................74 8)The DOE - CDGK Asbestos Specialist inspector will monitor and periodically audit the buffer store and landfill security to ensure no pilfering or theft of the stockpiled waste. The Asbestos Specialist inspector will report on the progress of all the asbestos abatement works under the MFF twice per year to ADB.................................. .....74 Stage 87 Task / Progress.............................................................................. ...............87 Yes / no (comment).............................................................................. .........87 Date 87 1. Minimizing Asbestos Liabilities.......................................................... ........88 2. Preparation of Detailed Design............................................. ....................88 3. Preparation of Construction Contracts................................... ...................89 4 Monitoring During the Construction Period.................... ............................89

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FIGURES

Figure 1: Water Sector Subprojects.......................................................13 Figure 2: COD Filtration Plant.................................................................19 Figure 3: NEK Filtration Plant.................................................................20 Figure 4: Pipri to Landhi Pipeline...........................................................23 Figure 5: Pipri to Malir Pipeline..............................................................24 Figure 6: Location of Public Consultations...........................................37

TABLES

Table 1: Ambient Air Quality in Karachi (µg/m3)...................................15 Table 2: Population of Karachi................................................................18 Table 3: Land Use Distribution for Filtration Plants.............................21 Table 4: Land Use Distribution for Pipelines.........................................22 Table 5: Summary of Public Consultation.............................................38 Table 6: Environmental Monitoring Plan for Tranche 1 Water Sector Subprojects.......................................................................................54 Table 7: Summary of Estimated Costs for EMP Implementation.........54 Table 8: Operations Phase Environmental Monitoring Plan................55

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LIST OF ABBREVIATIONS ADB AMF CDGK CSC DCO DDC DOE EARF EDO EIA EMP EPA GER GoP IEE KMCSDP KMP KWSB MFF MMP NEQS NOX Pak-EPA REA RoW RRP SEPA SO2 SR TA

Asian Development Bank Asbestos Management Framework City District Government Karachi Construction Supervisory Consultant District Coordination Officer Detailed Design Consultants District Officer Environment Environmental Assessment and Review Framework Executive District Officer Environmental Impact Assessment Environmental Management Plan Environmental Protection Agency Gross Enrolment Rate Government of the Islamic Republic of Pakistan Initial Environmental Examination Karachi Mega City Sustainable Development Program Karachi Master Plan Karachi Water and Sewerage Board Multi-tranche Financing Facility Materials Management Plan National Environmental Quality Standards Oxides of Nitrogen Pakistan Environmental Protection Agency Rapid Environmental Assessment Right-of-Way Report and Recommendations to the President Sindh Environmental Protection Agency Sulphur Dioxide Sensitive Receiver Technical Assistance

WEIGHTS AND MEASURES dB(A) ft km km/h m m3 m2 mgd s

Decibel (A-weighted) Feet/Foot kilometre kilometre per hour meter cubic meter square meter million [imperial] gallons per day seconds

LAWS AND REGULATIONS IEE-EIA Regulations 2000

PEPA 1997 SLGO 2001

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Pakistan Environmental Protection Agency Review of Initial Environmental Examination and Environmental impact Assessment Regulations 2000 Pakistan Environmental Protection Act 1997 Sindh Local Government Ordinance 2001

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I.

INTRODUCTION

1.Government of Pakistan (GoP) has requested the Asian Development Bank (ADB) to provide a multi-tranche financing facility (MFF) to facilitate investments to support the proposed Karachi Mega City Sustainable Development Program (KMCSDP, the Program). The KMCSDP will implement a number of subprojects within seven components including: support to institutional reform and development; waste supply and wastewater management; urban roads, traffic and transportation; improvement of katchi abadi (squatter settlements) and assistance in housing for the poor; public awareness and outreach; investment program management and engineering support. 2.This Initial Environmental Examination (IEE) presents the environmental assessments of the water sector subprojects in Tranche 1 of the MFF. This IEE has been carried out to ensure that the potential adverse environmental impacts are appropriately addressed in line with ADB’s Environmental Policy (2002) and Environmental Assessment Guidelines (2003). This IEE has also been prepared to meet the requirements of the GoP for environmental assessment. 3.This IEE is submitted to ADB by the Government of Sindh on behalf of City District Government Karachi (CDGK) and this report will be submitted for review and approval by the Sindh Environmental Protection Agency (SEPA) as required by the Pakistan Environmental Protection Act, 1997, as regulated. A

Overview

4.The ultimate objective of the water sector subprojects of the KMCSDP MFF is to improve the supply of potable water to the residents of Karachi. It is intended that by supporting the development goals defined in the Karachi Master Plan 2020, the quality of water supplied will be improved and additional supplies will be provided. 5.To achieve these objectives, an integrated, long-term package of investments and support programs have been developed. These initiatives include governance, financial, and institutional reforms; developing new sources of water; improved transmission and distribution systems and minimizing system losses. Tranche 1 subprojects include expansions of NEK and COD Hills filtration plants, and construction of two water transmission mains from Pipri to Korangi and Pipri to Malir Town. If there are more water sector distribution line projects included in later Tranches the KMCSDP MFF it they may have a similar conceptual design to Tranche 1 subprojects or sector may involve more complex environmental assessments. and therefore the potential of the later stages of the MFF to adversely affect the environment. The construction of Tranche 1 subprojects project within the existing rights-of-way (RoWs) for water supply infrastructure is unlikely to have any major significant impacts but will create some disruption in the construction stages. An IEE is required for all MFF subprojects under ADB and the EMP of the IEE aims to mitigate all the reasonably foreseeable impacts. The EMP must be updated later before construction starts and reviewed periodically as the project proceeds in order to take account of any unanticipated impacts for the Tranche 1 subprojects. A detailed environmental assessment and review framework (EARF) procedure has been prepared that must be followed as required by ADB for all the subprojects in future tranches.

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B

Environmental Regulatory Compliance

6.Section 12(1) of the Pakistan Environmental Protection Act 1997 requires that “No proponent of a project1 shall commence construction or operation unless he has filed with the Federal Agency2 an initial environmental examination or, where the project is likely to cause an adverse environmental effect, an environmental impact assessment, and has obtained from the Federal Agency approval in respect thereof.” 7.The Pakistan Environmental Protection Agency Review of Initial Environmental Examination and Environmental Impact Assessment Regulations, 2000 (IEE-EIA Regulations 2000) provide the necessary details on the preparation, submission, and review of the IEE and the environmental impact assessment (EIA). The regulation categorizes the projects on the basis of anticipated degree of environmental impact. Project types that are likely to have significant adverse impact are listed in Schedule II of the regulations and require an EIA. Projects that are not likely to have significant adverse impact, are listed in Schedule I and require an IEE, provided that the project is not located in an environmentally sensitive area3. Water supply schemes and treatment plants are included in both schedules, those with investment smaller than PKR 25 million (about US$ 0.4 million) require an IEE and larger projects require EIA. As the cost of individual subprojects exceeds PKR 25 million, an EIA should be required to meet the regulatory requirement of GoP. 8.The National Environmental Quality Standards is applicable to any process emission or effluent from the site. Whereas no such emission or effluent is envisaged from the water transmission pipes some emissions and effluents ca result from the operation of the water treatment facilities. C

Environmental Category of Water Sector Subproject

9.Under ADB’s Environmental Assessment Guidelines (2003) the Tranche 1 subprojects are Category “B” and require IEE. D

Objectives and Scope of IEE

10.The objectives of this IEE were to: i)

Assess the existing environmental conditions in the areas where the water sector subprojects are located including the identification of environmentally sensitive areas;

ii) Assess the proposed activities, identify and evaluate the potential impacts and determine their significance; iii) Propose appropriate mitigation measures that can be incorporated into the proposed activities to minimize any adverse impacts, ensure that residual im-

1

Defined as “any activity, plan, scheme, proposal or undertaking involving any change in the environment and includes-(a) construction or use of buildings or other works; (b) construction or use of roads or other transport systems; (c) construction or operation of factories or other installations; (d) mineral prospecting, mining, quarrying, stone-crushing, drilling and the like; (e) any change of land use or water use; and (f) alteration, expansion, repair, decommissioning or abandonment of existing buildings or other work roads or other transport systems, factories or other installations.

2

The Ministry of Environment, Government of Pakistan has delegated the power of the Federal Agency for EIA and IEE reviews for projects falling in different provinces to the environmental protection agencies of the respective provinces. Federal Agency in this case is the sindh Environmental Protection Agency.

3

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Sensitive areas are listed on the Federal EPA website and periodically updated.

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pacts are acceptable and propose monitoring and planning of future projects in this sector in Karachi. 11.This IEE is based mainly on secondary sources of information and field reconnaissance surveys. Public consultation was also undertaken. E

Report Structure

12.Following this introduction this report contains seven more sections including (ii) description of water sector subprojects; (iii) description of the environment; (iv) environmental impacts and mitigation; (v) public consultation; (vi) institutional requirements and environmental management plan; (vii) findings and recommendations; and (viii) conclusions. 13.Photographs of the project area are in Appendix A. The environmental management plan matrix is presented in Appendix B. The Asbestos Management Framework is included as Appendix C.

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II. DESCRIPTION OF WATER SECTOR SUBPROJECTS

A

Background

14.The National Water Policy provides the overall context for the development of water supply schemes. The vision of the national water policy is that: “By the year 2025, Pakistan should have adequate quantity as well as quality of water, equitably distributed to meet the needs of all users through an efficient management, institutional and legal system that would ensure sustainable utilization of its water resources. Water has to support economic and social development with due consideration to the environment, quality of life, economic value of resources, ability to pay and the participation of all stakeholders.” 15.The National Drinking Water Policy aims at ensuring “safe drinking water to the entire population at an affordable cost in an equitable, efficient, and sustainable manner”, and “reduction in the incidence of mortality and morbidity caused by water borne diseases”. Water Supply to Karachi 16.According to the Karachi Master Plan 2020 (KMP), the current water supply for Karachi comes from two sources: 646 million gallons per day (mgd) from Indus River and 60 mgd from Hub River. 17.The supply is not sufficient to meet the requirements of the city which is estimated at 820 mgd4. It is therefore not possible to have water supplied for 24-hours, 7-days a week, at a pressure that is sufficient to raise water to taps at a normal height at the ground level of a building. Due to this shortfall, water is supplied to various localities on ‘schedule’ for a fixed duration every day. 18.The filtration plants in Karachi have the capacity to filter only about 60% of the total supply. The existing filtration plants and their capacities are as follows: i)

COD Filter Plant (115 mgd)

ii) Pipri (New) Filter Plant (50 mgd) iii) Pipri (Old) Filter Plant (50 mgd) iv) NEK (Old) Filter Plant (25 mgd) v) NEK (New) Filter Plant (100 mgd) vi) Hub Filter Plant (80 mgd) vii) Gharo Filter Plant (25 mgd) 19.The 100 mgd additional water from K-III project which was commissioned in March 2006 is not being filtered; it is only chlorinated and disinfected. Thus there is a 184 mgd shortfall in treatment capacity. Water Distribution 20.According to the KMP, Karachi has a water distribution system that is on average 40years old. A large part of it is in an advance state of disrepair due to corrosion, leaking, blockages, and breaking down of distribution pipes. As the system is in many places buried several feet below the ground surface due to repeated construction of 4

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Calculated from the data provided in the KMP

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Karachi Mega City Sustainable Development Program MFF Tranche 1 IEE Report for Water Treatment Plants and Water Distribution Mains Subprojects

roads and streets, repairing the dilapidated system is not possible or at least technically very difficult. 21.The piped delivery system is buried and often located near underground sewers. The system is pressurized for short periods (not more than few hours) every day. The repeated pressurization and depressurization creates stress on the pipes and accelerates the wear and tear. It also draws contamination into the pipeline system from the surrounding ground. 22.The losses in the water supply and distribution system are estimated to be 40% by the KMP. This includes 25% technical losses and 15% unaccounted water loss. Some sources have estimated the losses to be even much higher. 23.Water is also distributed in Karachi from water tankers, operated by private owners and government agencies. These tankers obtain water from hydrants operated by Karachi Water and Sewerage Board (KWSB) and from groundwater supplies. Operational Issues 24.KWSB is an integral department of CDGK responsible for providing water to Karachi. KWSB operates a large water supply system that lags behind, similar systems in other modern world-class cites, in every respect. It is therefore relevant to appreciate the key issues in water supply management for Karachi. 25.There is no metering of water at the source or at the consumer. This has resulted in a severe lack of reliable data for planning purposes. The figures for water supply, distribution, and losses are based on indirect estimates. Thus there are numerous inconsistencies that make it difficult to undertake an accurate assessment. 26.There is a large gap between the water that is supplied to the city and the water for which consumers pay. The gap is explained to a large extent by: i)

Operational losses (leakages, evaporation, seepages);

ii) Theft and pilferage through illegal connections; iii) Inaccurate estimates of water supply and distribution; and iv) Inefficient billing and collection (collection represents only 60% of the billing). 27.As the paying consumers, make payment on a flat rate irrespective of the actual consumption of water there is no incentive for water conservation. 28.There is no concerted effort or program to recycle water. Even in the few places where it is recycled, there are no guidelines on the quality of water that can be used for various purposes. E.g. the safety of vegetables grown on the treated water from the SITE wastewater treatment plant has been questioned on many occasions. Water Quality 29.Many studies have been undertaken on the quality of water provided to the citizens of Karachi. Studies repeatedly conclude that the quality of water does not meet the water quality standards of the World Health Organization. In one such study undertaken by the Aga Khan University, faecal contamination, as indicated by coliform bacteria, was found in 335 out of 338 samples5.

5

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Reported in the KMP.

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B

Criteria for Site and Route Selection

Filtration Plant Extensions 30.There are obvious operational and financial advantages in locating the new filtration plants within the boundaries of the existing plants. Apart from convenience in interconnection with the existing system, the availability of land at these sites that has been designated for this purpose is a major advantage. Pipeline Route 31.In selecting routes for the water transmission mains the overall aim was to identify the shortest route that avoids land acquisition and resettlement. Internationally recognized criteria were used to guide the selection of the pipeline route. i)

Government agencies and local communities were consulted.

ii) The route was selected that follows existing pipeline corridors and conduits of KWSB or passes under government-owned and maintained roads that are not occupied by the community for any other purpose. 32.The selected locations of the filtration plants and transmission main’s pipeline route are shown in Figure 1. C

Description of Components

33.The water sector subprojects include the following components: i)

Filtration Plant Extensions at COD Plant.

ii) Filtration Plant Extensions at NEK Plant. iii) New Transmission Mains from Pipri to Korangi. iv) New Transmission Mains from Pipri to Malir Town v) Development of a rolling program of Network Improvement Programs in specific supply zones to provide 24/7 (24-hours-a-day, 7-days-a-week) supply. 34.The four water sector subprojects are described in the following sections. Selected photographs of the project area are included as Appendix A. Filtration Plant Extensions at COD and NEK Plants 35.The subprojects address the problems of the lack of treatment capacity which means that currently water supplied through the K-III raw water delivery system enters the distribution network untreated. Increased treatment plant capacity is an immediate investment need and the subprojects will (a) assist the KWSB to build a new 100 mgd filtration plant at the Old NEK site, and (b) to expand the capacity of the existing COD Hills filtration plant by 84 MGD. 36.The proposed treatment systems at both locations will involve the construction of clarifiers and rapid sand filtration units. Treatment processes include: i)

Water clarifying

ii) Rapid gravity filtration with inline coagulation, and iii) Disinfection by chlorination. 37.The filters will be accommodated in two blocks of 90 m x 40 m in the case of both the COD plant and NEK plants, with a central galley of 6 m width housing a control building. The arrangements and design will be similar to those of the existing plants. Following

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chlorination the treated water will gravitate to treated water reservoirs and from there via transmission mains to the distribution network. New Transmission Mains from Pipri to Korangi and Malir Town 38.In order to provide more equitable distribution of treated water from the Pipri treatment plant to areas of the city which are currently poorly served, it is proposed to provide transmission mains from Pipri to (i) Korangi Industrial Estate and (ii) Malir Town. The proposed investments are: i)

Provision of approximately 20 km of water transmission main from Pipri Treatment Plant to Korangi Industrial Area.

ii) Provision of approximately 25 km of 36" diameter water transmission main from Pipri Treatment Plant to Malir Town. Distribution Network Improvement Programs 39.Investment in Distribution Network Improvement Programs will initially involve data gathering and pilot implementation of technical solutions, replacement and rehabilitation of distribution mains and service connections, implementation of District Metering Areas (DMAs), and customer metering to monitor the situation. The first tranche “distribution network improvement program” (DNIP) subproject will identify and isolate a zone where the water supply can progressively be improved by zonal and individual metering combined with distribution network optimization and targeted leak detection and correction, progressively raising the pressure in the system and thus improving the quality and reliability of service offered. D

Projects Implementation Schedule

40.The planning, design and construction of the filtration plants is scheduled to be completed within 36 months. 41.The distribution main from Pipri to Korangi will be completed within 12 months. This period includes project planning, design and construction. 42.The preparation and approval of PC-1 for new distribution main from Pipri to Malir Town is in progress. The pipeline will take 12 months to install after approval of the PC-1. 43.Improving the water distribution system is an immediate investment need. Distribution System Data Gathering and Pilot Improvements projects would lay the basis for future distribution improvement projects. This project could be implemented as an extension of the current “System Strengthening Project” and would commence immediately after the commencement of Tranche 1 subprojects.

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Figure 1: Water Sector Subprojects

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III. DESCRIPTION OF ENVIRONMENT

A

Environmental Profile of Karachi

Physical Environment 44.Topographically ridges, plains, and the coastal belt are the dominant topographic features of the Karachi. The main features include ridge and runnel upland in Sindh Kohistan, piedmont colluvial fans and peneplains, north of Karachi, moidan and Gadap Plains, plains and Plateau of Malir-Lyari Interflous, plains and Hills of the Coastal Belt. 45.Pakistan has 15 seismo-tectonic regions.6 The proposed project is located in the seismo-tectonic region of the Southern Kirthar Ranges, where a moderate level of activity is believed to exist, but large magnitude earthquakes are rare. The Building Code of Pakistan7 places Karachi in Zone 2 corresponding approximately to Intensity VII of the Modified Mercalli Scale of 1931.8 The peak ground acceleration values in the Zone 2 according to the Building Code of Pakistan ranges from 0.08 to 0.16 g. Thus every construction in this zone should be designed to withstand the load corresponding to ground acceleration value of about 0.2 g. 46.There are no significant natural freshwater sources in Karachi. Almost the entire freshwater needs are met by surface waste sources located outside Karachi, i.e. the Indus River (about 120 km to the east of the city) and the Hub River (a perennial stream that originates in Balochistan) that marks the boundary between Karachi and Balochistan. 47.The Lyari and Malir Rivers that pass through the city do not have any natural flow, except during the monsoons. Lyari River that passes through the western Karachi, rises in the northeastern part of the Karachi district and is joined by smaller natural drains within the city limits. The Malir River rises in the northeast of the city and flows through the eastern part of the city. Outside the monsoon season flows in these rivers are more or less completely formed by municipal sewage and industrial effluent discharges that flow into the rivers and tributaries as they traverse the city. 48.Groundwater resources in the Karachi area are limited. The aquifers close to the coastal belt are mostly saline and unusable for domestic purposes. The aquifers near the Hub River bed, estimated to lie at depths of 50-100 m, are well developed and are source of water for agriculture and other domestic purposes. The main potential sources of groundwater pollution in Karachi are the unlined drains carrying contaminated waste from the industries. Similarly, the drains and the domestic and industrial waste in the Malir and Lyari rivers can also potentially seep through the river beds and reach the groundwater aquifers. 6

Quittmeyer, R. C. 1979. The Seismicity of Pakistan and Its Relation to Surface Faults in Geodynamics of Pakistan. Quetta: Geological Survey of Pakistan.

7

Government of Pakistan. 1986. Building Code of Pakistan. Islamabad: Ministry of Housing and Works, Environment and Urban Affairs Division. A revised version of this document is under development and is likely to be available soon, however, a draft could not be reviewed at the time of writing of this report.

8

Unlike earthquake magnitude, which indicates the energy a quake expends, the Modified Mercalli Intensity Scale of 1931 is designed to describe the effects of an earthquake, at a given place, on natural features, on installations and on human beings. It has 12 divisions, using Roman numerals from I to XII. I is the mildest—described as: ‘Not felt except by a very few under especially favorable circumstances’— and XII is the most severe—‘Damage total. Waves seen on ground surfaces. Lines of sight and level distorted. Objects thrown upward into the air.

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49.The climate of the Karachi can be broadly classified as moderate and which lies in ‘Subtropical Double Season Coastland zone’9. The characteristic features of this climatic zone are moderate temperatures, afternoon sea breezes in the hot season, and higher temperatures in the period from July to January than January to July, in spite of the monsoon-rain. 50.At present, monitoring of urban air pollution in Pakistan is limited to isolated studies and instances where air pollutants are measured for brief periods at selected locations. Urban locality, city, region, or countrywide continuous or repeated air quality monitoring data has not been collected. Similarly, there is no formal system of air quality data storage and reporting. Whatever air quality data is available is with the public and private organizations and agencies that conducted the studies. The integrity of air quality as well as the availability of ambient air quality data are important concerns. 51.A   study   on   emissions   of   vehicular   traffic   was   conducted   by  Transport   and  Communication Department (TCD), of the CDGK to evaluate the impact of operation of  vehicular traffic on physical, living and social environment of Karachi10.   The study was  based on sampling undertaken at 28 different locations throughout Karachi. The results  are presented in Table 1. Table 1: Ambient Air Quality in Karachi (µg/m3) Maximum

Minimum

Average

WHO Guidelines and Targets11

Sulfur Dioxide

110

16

57

500 (10-minute) 20-125 (annual)

Nitrogen Oxides

489

17

199

40 annual 200 1-hr

Particulate Matter Less than 10 micron

490

40

243

20-70 annual 50-150 24-hr mean

92

10

35

100-250 8-hr mean

Ozone Source: TCD CDGK

All units ugm-3

52.The air quality study also included measurement of roadside noise. The study suggested that the average noise level at the 28 locations was 77dB(A). The maximum was recorded as high as 99dB(A), the minimum level was 52dB(A). By comparison with the World Bank Guidelines the measured levels are much above guideline acceptable limits of 55dB(A) during the day for residential areas and 70dB(A) for industrial and commercial areas. Biological Environment 53.Pakistan can be divided into four phytogeographical regions based on similarity of floral diversity. Karachi falls in the Saharo-Sindian region. This region covers almost 80% 9

Shamshad, K.M. 1988. The Meteorology of Pakistan. Karachi: Royal Book Company.

10 Feasibility Study and Development of Transportation Control Plan of Karachi. Prepared by Pakistnn

Space and Upper Atmosphere Research Commission for Transport and Communication Department, City District Government Karachi. 2007. 11 For severla parameters, WHO now sets guidelines and also interim targets. Wherever a range is

provided, the first number is the guideline value whereas the second is first interim target value.

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of the country including all of Sindh, central and southern Punjab, most of Balochistan and the plains of Northwest Frontier Province. Floristically the Saharo-Sindian region is considered very poor because despite the large area only 9.1% of the known 5,640 floral species of Pakistan are found in this region12. The natural flora is sparse and mostly xerophytes in the west and northwest areas of the city. However, marine phytoplankton and mangrove forests are in relative abundance at the coast. 54.Several species of reptiles, birds, and terrestrial mammals are found in the city, wherever suitable refuges and habitats are found. The beaches and coast of Karachi are home to an abundance of marine fauna, such as birds, rare reptiles, fish, and marine mammals. Karachi also falls in the Indus Flyway, one of the major migration routes for birds. Karachi coast becomes the winter home and even breeding ground for many species of birds. There are 26 mammal species reported from the region, in which 2 species musk shrew and pigmy shrew are considered to be the rare species. 55.The reptiles and amphibians found in the Karachi include 4 species of land snake, 8 species of marine snake, 10 species of gecko, the Indian sand swimmer, the Indian monitor lizard and 5 species of frogs. All these species are widely distributed across the region13. Social and Cultural Environment 56.Karachi is the capital of the province of Sindh, and the largest city in Pakistan. The metropolitan area along with its suburbs comprises one of the world's most populated areas that spreads over 1,000 square kilometers14. The city credits its growth to the mixed populations of economic and political migrants and refugees with different national, provincial, linguistic and religious origins, many of whom have come to settle permanently. 57.The population of Karachi in the 1998 census was reported as 9.86 million, an increase of 80% from the 1981 census (see Table 2). The present estimate of Karachi population in the Master Plan is 16.4 million.15 This demonstrates that the population growth rate has increased from 3.6% per annum in the 1981-98 period to 5.8% since 1998. Part of this phenomenal growth can be explained if the population of Karachi was under-reported in 1998. The Master Plan estimates that the population in 1998 was actually 11.335 million. This gives an annual growth rate of 4.42% in the 1981-1998 period and 4.2% since then. According to the Karachi Master Plan, the population of the city is expected to reach 27.6 million by 2020, almost double that of 2005. 58.The female-to-male ratio in the Karachi population 100:117, as compared to the national figure of 100:109. Of the total population 37.6% are under the age of 15 years and 58% are between 15 to 50 years of age. In comparison, the national figures are 42.4% and 44.6%, respectively. These numbers are reflective of the high migrant population in the city who come here often leaving their families behind in order to earn their living. 59.Approximately 22% of the present day population consists of migrants. The ethnic configuration of the metropolis shows that 48% people are Urdu speaking. 14% of 12 Nasir, Y. J. and A.R. Rubina. 1995. Wild Flowers of Pakistan. Karachi: Oxford University Press. 13

Hafiz Ur Rehman and I. Fehmida. 1997. A Revised checklist of Reptiles of Pakistan. Records Zool. Sur. of Pak. Vol. XIII. Zoological Survey Department of Pakistan.

14

The Karachi is divided into 18 towns. The total areas of these towns is 3,530 square kilometers. This includes the urban areas, as well as the rural areas.

15 The estimates of current population of Karachi vary by a large margin. Even the website of CDGK,

report three different figures ranging from 14.7 million to 20 million.

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Karachites are Punjabi speaking, 11% speak Pashto, 7.2% speak Sindhi, 4.3% speak Balochi and Seraiki is spoken by 2.11% of the population.

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Table 2: Population of Karachi Source

Year

Population Census Organization

1981

5,438

4.96%

1998

9,856

3.56%

1998

11,335

4.42%

2007

16,401

4.19%

Karachi Master Plan

Population (‘000)

Annual Growth Rate

Sources: 1981 District Census Report of Karachi Division, 1981 District Census Reports of five districts of Karachi, Karachi Master Plan 2020

60.Literacy rates have constantly increased in Karachi, with substantial reduction in male-female literacy gap. The overall literacy rate in 1998 was 67.4%, including 62.3% literacy for women. The Pakistan Economic Survey 2005-06 reports that the gross enrolment rate (GER) in Karachi for the primary schools (age 5-9) is almost 100%. Furthermore, the GER at the metric level in Karachi is at 79% during the period 2004-05, and the overall literacy rate of the population (10 years and above) in 2004-05 was 78%. There will thus be a large population ready to enter the work force in a decade or so requiring employment opportunities. B

Environmental Conditions of Proposed Sites

COD Filtration Plant 61.The COD Filtration Plant site is located on a low hill within 1km of the National Stadium. The proposed site is located within the existing plant boundary of COD Hill filtration plant. No new land will be required. The COD plant boundary is surrounded by the residential area. The site can be accessed from three different main roads and is shown in Figure 2. NEK Filtration Plant 62.The NEK Filtration plant is located in suburbs of Karachi, about 5km from the newly built bulk fruit and vegetable market on the Karachi-Hyderabad Highway (the Super Highway). The proposed site for the new plan is located within the existing plant boundary of NEK filtration plant. No new land will be acquired. There are no residential settlements within 1km of the existing plant. The site can be accessed from the KarachiHyderabad Highway and Karachi Northern Bypass. There are a few farm houses and human settlements along the access road to the proposed site which is shown in Figure 3.

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Figure 2: COD Filtration Plant

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Figure 3: NEK Filtration Plant

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Pipri-Landhi Pipeline 63.The proposed main will be laid parallel to the existing KWSB main distribution main a and installed in the existing RoW. No new land will be acquired. The RoW from the Pipri plant to the National Highway passes through sparsely occupied agricultural farms in otherwise barren land. After crossing the National Highway (the crossing will be via horizontal boring (trenchless technology) to avoid damage to the road surface and interference with the traffic flow). The proposed route will then run parallel to the highway towards Quidabad. Leaving the highway at Nagaria Chowrangi, it will be routed towards Landhi industrial area. Here it will be laid under the existing road due to non availability of space on either side of the road and the absence of a median. The last few hundred meters of the pipeline will pass underneath a narrow street. The proposed pipeline route is shown in Figure 4. Pipri-Malir Pipeline 64.The proposed main will be laid parallel to KWSB’s existing pipeline route therefore there will be no new land acquired. Most of the proposed RoW is located away from residential areas. After crossing the Malir River the main will be laid under the existing roads through Damlotte, and Khokhrapar to the Saudabad pumping station. The proposed pipeline route is shown in Figure 5. C

Land Use around the Proposed Filtration Plant Sites and Pipeline Routes

65.The land use bordering the WTP sites within a 200 m circle around the centre of the filtration plant facilities is shown in Table 3. All the lands nearby the NEK plant are not occupied. The majority of the nearby land uses to the COD plant are occupied and are potentially noise sensitive receivers or have human population that could be at risk from chlorine release. Table 3: Land Use Distribution for Filtration Plants Land Use

COD Plant

Residential and Commercial

62%

CDGK Facilities

30%

Public Buildings

3%

Parks

3%

Roads, tracks, others

2%

Empty plots

NEK Plant

100%

66.The land use bordering the distribution mains is shown in Table 4. The land nearby the Pipri Malir distribution main is mainly agricultural, river bed or empty lots and therefore not occupied by a human population.  About 20% of the land has residential  and commercial occupants along the existing roads through Damlotte, and Khokhrapar to the Saudabad pumping station along which the new WDM will be installed. This area  is therefore potentially sensitive.  67.The land nearby the Pipri Landhi distribution main is more mixed with mainly industrial uses, open land or empty lots that would not be considered sensitive. The

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remaining 20% of land uses are mixed industrial/residential or residential/commercial and those areas are also therefore potentially sensitive.

Table 4: Land Use Distribution for Pipelines Land Use Residential and Commercial

Pipri-Landhi Pipeline 6%

Agricultural 39%

Open plots/mix use

20%

Residential/industrial

14%

River bed or banks

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19% 44%

Industrial

Empty plots

Pipri-Malir Pipeline

19% 21%

18%

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Figure 4: Pipri to Landhi Pipeline

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Figure 5: Pipri to Malir Pipeline

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IV. ENVIRONMENTAL IMPACTS AND MITIGATION 68.This section discusses the potential environmental impacts of the proposed subprojects and identifies mitigation measures to minimize the impacts in the design, construction and operational phases. The main issues relate to impacts such as noise dust and traffic during construction and operation. A

Design Related Impacts and Design Principles

69.The proposed filtration plants at the two sites are expected to adopt a standard design. However the detailed layout for the sites is not yet available therefore a review of this IEE must be undertaken at the detailed design stage. As described in Section II, the sites have been selected within the boundaries of existing water treatment plants thus avoiding any land acquisition. 70.For the transmission mains, the key design-related environmental impact relates to the selection of the pipeline route and the removal and disposal of the old transmission pipes. 71.As described in Section II, the alignments will adopt the routes used by the existing water mains that will be replaced. This route selection will avoid land acquisition and resettlement. 72.The following design principles will be presented to the design engineers by CDGK at the commencement of their design commission. 73.The specific design mitigation measures for the treatment plants are as follows: i)

Wherever possible the design concept shall permit the maximum use of prefabricated materials in order to minimize construction impacts.

ii) The ground surfaces within the perimeter of the filtration plants will be sealed or landscaped and planted in order to minimize dust emissions. iii) The design will be reviewed by the DOE and environmental cell prior to the finalization of the design to ensure that all environmental requirements are being met and the layout option will allow mitigation of environmental impacts to an acceptable level. This will include sufficient set backs from the potentially noisy or hazardous installations to the nearest sensitive receivers. iv) Create and retain an adequate buffer zone of non development around the pumping and treatment plants as needed to alleviate noise and other possible nuisances to neighboring properties and to protect the water treatment facilities from damage by outsiders. v) Create and an adequate buffer zone of non development around the pumping and treatment plants and design all facilities to accommodate requirements of best practice design standards and codes of practice to protect against accidental leakage of chlorine gas. The design of the chlorine storage and distribution system which must meet international standards in line with ADB policy on should follow strict design standards and codes of practice. vi) The IEE and EMP (Appendix B) will be revised and updated at implementation to take account of any new, modified, increased or unexpected impacts. vii) Noise and dust mitigation measures will be reviewed once the detailed layout has been finalized and the mitigation measures will be revised and the EMP

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updated to take account of any new, modified, increased or unexpected impacts. viii) Trees will be planted along the boundaries of the filtration plant outside the perimeter wall to create an enhancement and minimize the visual impact of the facilities. 74.The specific design mitigation measures for the pipelines are as follows: i)

The pipeline route will adhere to existing pipeline RoW. If the RoW of existing water transmission pipe lines cannot be followed for some unforeseen reason this IEE and the accompanying EMP (Appendix B) and mitigation measures will be reviewed and revised accordingly to take account of any unforeseen impacts and minimize them to acceptable levels.

ii) A survey of all existing services and other utilities — power, gas, telephone, sewerage, and fiber optic cables — will be undertaken during the detailed design stage for the pipelines and if there is a conflict, the pipeline will be rerouted and appropriate revisions to the IEE and EMP will be made. iii) The detailed designs and costing will make provisions for the realignment and re-provisioning of other utilities where necessary and work together with and obtain approval from the authority for all utilities on the routing and construction methods for the new pipelines. The aim will be to reduce disruption of services to the absolute minimum. iv) Where water supply has to be interrupted, for justifiable technical reasons, provisions will be made for temporary supply by tanker or other suitable means. The alternative supply shall be substantial and regular and sufficient to provide for the population it must serve for the duration of the loss of piped supply. The contractor will be required to reinstate the water supply as soon as practicable. v) Wherever possible the design should be conceptualized to permit the maximum use of prefabricated materials in order to minimize construction impacts and speed up the installation and re-commissioning process. Non-asbestos cement pipes shall be installed for the new water distribution main and old asbestos cement pipes shall be removed and disposed of under controlled conditions in line with asbestos management framework (Appendix C). vi) The ground surfaces excavated for the installation shall be resealed in order to minimize dust emission. Surplus excavated earth will be stockpiled and reused for landscaping or disposed of as required by the construction supervision consultant. vii) The design will be reviewed by the DOE and environmental cell prior to the finalization of the design and disclosed to SEPA to ensure that all environmental requirements are being met and the layout option will allow mitigation of environmental impacts to an acceptable level. The IEE and EMP will be revised and updated to take account of any new, modified, increased or unexpected impacts. viii) Noise, dust and odor mitigation measures will be reviewed once the detailed layout has been finalized and the mitigation measures will be revised and updated to take account of any new, modified, increased or unexpected impacts. 75.A key design issue for the transmission mains is that the old asbestos cement pipes (ACP, that are estimated to be present in more than 35% of the distribution system) may in some cases need to be repaired in which case they shall be replaced with nonasbestos materials such as UPVC or other synthetic non-asbestos materials. Retaining

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or replacing the old ACP with new ACP would not be an environmentally responsible procurement option and not be consistent with ADB Environmental Policy 2002. As a special feature of this MFF an asbestos management framework (Appendix C) has been developed in tandem with this IEE to provide guidance to CDGK and KWSB on how to manage the excavation, handling, transport, storage and disposal of ACP from the water subprojects and any other subprojects in Tranche 1 and future tranches which may involve asbestos containing materials. 76.In some jurisdictions it has been noted that contractors may seek to pay money for nuisances rather than control impacts at source. This practice should not be allowed and financial compensation shall not be allowed as mitigation for environmental impacts or environmental nuisance. 77.Based on professional experience and the linear nature and likely narrow working spaces that will be available in some areas for the WDM it can be expected that the contractor(s) will claim that there is insufficient space to set up mitigation measures anywhere along the working construction route. Based upon observation it is not credible that there is no space for any mitigation on the whole of Tranche 1 WDMs. It is not acceptable that there are no opportunities to use the recommended forms of mitigation, albeit that there may be some places where modifications to the mitigation measures proposed in the EMP may be needed to minimize impacts within the available space. 78.During the preparation for the WTP and WDM construction phase the future contractors must be prepared and primed to co-operate with the implementing agency, project management, supervising consultants and local population in the mitigation of impacts. Furthermore the contractor must be primed by including the EMP and environmental assessments in the tenders and contract documentation. The requirements must fully implement the EMP and the contractor must be ready to engage capable and trained environmental management staff to audit the effectiveness and review mitigation measures as the project proceeds. The effective implementation of the EMP should be audited as part of the loan and payment conditions and the executing agency must be prepared for this. In this regard the CDGK (the Implementing Agency) must also prepare resources to fulfill the requirements of the law and guidance prepared by federal and provincial EPAs on the environmental aspects of water sector project16 B

Construction Related Impacts

Planning the Construction Works 79.Contractual clauses should be included to require each contractor to produce draft management plans at least one month before construction commences. Contractors tenders shall be required to separate clearly the resources and funds to be applied to the mitigation measures for environmental impacts and to have written plan. Contractors tenders shall identify named staff to supervise and plan the following: i)

Drainage and utilities re-provisioning;

ii) Temporary traffic management; iii) Noise and dust control; iv) Waste management; v) Tree removal and compensatory planting; and vi) Compliance with asbestos management framework. 16

Pakistan Environmental Assessment Procedures: Sectoral Guidelines Water Supply Schemes, 1997.

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80.Contractual clauses shall be included to tie the implementation of environmental mitigation measures in the above plans to milestone payments. Contractual clauses shall also require Contractors to conduct special induction briefing and / or on-site training for the contractors management, contractors staff, subcontractors and workers to cover the environmental requirement of the project. Contractors shall record and report regularly on attendance and achievement for all staff and managers. 81.Contractual clauses shall be included to require contractors to employ dedicated environmental management staff to conduct/oversee the environmental orientation sessions and the implementation of environmental mitigation measures so as to facilitate checking for milestone payments. 82.Contractual clauses shall emphasize that financial compensation shall not be allowed as mitigation for environmental impacts or environmental nuisance without written and environmentally justifiable agreement from the relevant environmental authorities. 83.Engineering controls shall be proposed in the firat place by the construction contractors and shall be designed as mitigation measures to control the impacts at source in the first place. The CSC shall be responsible to approve the measures and report the update of EMP. Cut and Fill 84.The completion of the WDP will require extensive shallow cutting and filling all along the RoW to excavate the trenches in which to lay the distribution mains. At this stage the removal of about 1m deep trenches will require at least 40,000 m3 to be cut. A reuse plan for these materials needs to be identified in the detailed design phases and included in the amended EMP in due course. 85.Balancing cut and fill requirements can be a major contribution to the minimization of impacts. If surplus materials arise from the removal of the existing surfaces these may be used elsewhere on the project for fill before additional rock, gravel or sand extraction is considered. The use of this immediately available material will minimize the need for additional rock based materials extraction and this also needs to be identified in the detailed design phases and included in the amended EMP in due course. 86.The detailed designers will need to estimate the additional materials that will be required. Works should be planned and scheduled to facilitate the timely production of rock, gravel and sand materials for construction and to avoid the need for excessive stockpiling and importing from elsewhere in the districts that will be affected by this subproject. 87.The detailed design engineers should produce a materials management plan for the materials needed for the construction works. The mass haulage requirements can later be modified to good effect by the contractor to produce a materials management plan (MMP) including mitigation for the extraction of materials, to specify (i) the methods to be employed prior to and during construction, (ii) all other measures to be employed to mitigate nuisances to local residents, and (iii) any additional measures such as compensatory planting; if trees have to be removed. The MMP should be updated regularly and reported monthly as a contract requirement for each contractor to monitor the production and use of materials. The construction supervising consultant (CSC) shall be made responsible for updating and reporting the cut and fill estimates in the MMP. The MMP can then be used to plan for bitumen and aggregates management and to facilitate materials exchange between the subcontractors in different areas along the WDM routes, and to provide an overall balance for bitumen and cut and filled materials and also to minimize impacts on other local resources outside the RoW.

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Replacement of Trees 88.Trees should be retained and maintained wherever possible, but there are several locations where trees may need to be removed or roots trimmed. Wherever possible the detailed designs should position the works to avoid and keep these trees in place and intact. The detailed designers should conduct a detailed tree survey in order to identify tree locations and position the new distribution mains well away from trees. There may be a need to remove some trees but only as a last resort, which should be justified in writing and sanctioned by the CRC before felling. Where trees have to be felled, mitigation will be required in the form of reinstatement and compensatory planting. Soft landscaping should be installed to improve the appearance of the completed works. Other opportunity spaces should be sought by CDGK to plant trees as near the locations of the WTP and as near the felled tree as possible. The contracts drawn up by CDGK for the WTP and WDM should require that wherever possible the trees are transplanted for use elsewhere in the project (e.g. amenity areas / parks). After removing the existing trees and top soil (down to 0.5 m), the topsoil shall be retained for elsewhere in the project. The cut wood shall not be burned on site. All stumps and surplus vegetation shall be disposed of at landfill via routes or other destinations as designated and instructed by CDGK or the CSC. 89.Recent international practice suggests that replacement at a minimum rate of 3:1 for trees would be appropriate given possible difficulties with establishing trees and low survival rate of young trees. This would probably be affordable. However most recent international guidelines indicate a replacement rate of at least 7:1. Also in some countries that rely on forestry resources for livelihood replacements rates have recently been increased to 25:1. Therefore it is important to recognize that some significant part of the replacement ratio should allow for a high mortality rate among the newly planted trees based on observation, international expectations, and advice from the CDGK parks authority. Dust Impacts during Construction 90.Among the variety of options to control dust emissions from construction sites the most effective is wet suppression. Sprinkling water on exposed surfaces and soil with adequate frequency to keep soil moist at all times can reduce the total dust emission from the project by as much as 75%. 17 The following mitigation measures will be implemented at each site during construction to control emission of particulate matter: i)

Water will be sprinkled daily on all exposed surfaces sufficient to suppress emissions of dust. The frequency of sprinkling will be increased as necessary but controlled such that the surface remains just moist at all times, particularly when wind is blowing towards any nearby sensitive receivers.

ii) Dust emission from soil and aggregate storage stockpiles will be reduced by appropriate measures. These will include: (a) covering the pile with tarpaulin or thick plastic sheets when not in use and at the end of the working day; (b) erecting windshields / walls on three sides of the piles such that the walls project 0.5m above the top of the pile and (c) keeping the material moist by sprinkling of water at appropriate intervals, to prevent emissions. iii) All roads within the pipeline routes that are to be excavated will be reinstated and repaved as early as possible after the completion of construction work. Until the roads are paved, they will be sprinkled regularly to prevent dust emission. 17

El Dorado County Air Pollution Control District. 2002. Guide to Air Quality Assessment: Determining Significance of Air Quality Impacts Under the California Environmental Quality Act. First Edition. http://co.el-dorado.ca.us/emd/apcd

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iv) The construction vehicles will maintain a speed limit of 20km/h or less on all unpaved areas within the construction route and the access route for the duration of the construction. Speed limit signposts will be erected in highly visible positions along the access road and within the route and maintained for the duration of the construction. v) Construction materials will be transported to the route and around the route in trucks securely covered with tarpaulins or equivalent to prevent dust emission during transportation. Noise During Construction 91.Noise nuisances can be minimized by various measures. Outside schools or hospitals construction timetable shall be discussed with the occupiers and work should be avoided at sensitive times. As fall back option to control noise hoardings using heavy thick ply-board or corrugated metal sheet to achieve a mass of >10kg/m2. Design and works layout must allow pedestrians to cross roads or pass around or over sites and avoid community severance. The installation of such measures should be discussed with the local population and serve as a means for further public consultation during implementation and assist in public relations. 92. All heavy equipment and machinery shall be well maintained and fitted in full compliance with the national and local regulations. As a rule, the operation of heavy equipment shall be conducted in daylight hours unless agreed otherwise with local residents. 93.Construction equipment, which generates excessive noise, such as compressors, jack-hammers shall be enclosed to prevent noise release. Well-maintained haulage trucks will be used. The contractor shall also maintain and service all equipment to minimize noise levels. 94.Performance criteria during nighttime (10 pm to 7 am) shall be the measured impact noise at the residential or hospital sensitive receiver shall not be more than 3dB above background noise levels measured at the nearest sensitive receiver (Leq15minutes) two weeks prior to the commencement of works. The contractor shall also maintain and service all equipment to minimize noise levels. 95.Near places of worship and schools the contractor shall discuss with the CSC and the school and mosque principals the agreed time for operating the noisy machines and completely avoid machine use near schools during examination times and near mosques during religiously sensitive times. Large concrete building components shall be prefabricated near the concrete batching plants or in controlled dedicated areas away from SRs to minimize impacts. 96.Noise will be reduced in the construction by a) preventing as far as possible construction work during night time 21:00hrs to 06:00hrs within 300m of sensitive receivers; b) prevention of blowing of horns by the project vehicles except in emergencies; c) use of powered mechanical equipment that is acoustically insulated to reduce noise impacts; d) tuning and proper maintenance of construction equipment and vehicles. 97.The contractor shall be allowed to take other acoustic measures to minimize noise nuisance in the vicinity of construction sites to achieved the necessary noise attenuation to keep within the noise criteria. The contractor may obtain guidelines for noise reduction from ISO/TR11688-1:1995(e), which enumerates methods by which air-borne, ground– borne and structure-borne noise sources may be curtailed with suitable design criteria.

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Asbestos Management 98.The old pipelines will be exposed during the detailed design phase and samples taken to determine if they contain asbestos cement sections. If the old pipeline material or parts of it are made from asbestos containing cement, the waste materials will be handled under controlled conditions removed and prepared for disposal as required under the asbestos management framework (Appendix C) in conformance to the ADB’s Environmental Policy (2003) and the Environmental Guidelines (2003). The AMF (Appendix C) is a special feature of this MFF. The AMF will guide CDGK in the preparation of the asbestos abatement practices that will mitigate environmental liabilities associated with asbestos. The AMF is an integral part of the IEE and EMP that will facilitate contractor’s compliance of asbestos-related measures in the implementation stage. CDGK will employ and Asbestos Specialist to supervise the selection of capable contractors and prepare the necessary contractual requirements and monitor the implementation of the asbestos abatement mitigation measures as specified in the AMF and report to ADB for all Tranches of the MFF. Other Issues Related to Pipeline Construction 99.The proposed pipeline will be within the existing RoW and government lands. Therefore, no acquisition of private land is anticipated. Temporary impacts are however, anticipated. Temporary disruption to hawkers and vendors is possible during laying of water pipelines. However, this is not considered significant, as there is ample space at the side of the roads where the hawkers and vendors can temporarily move back off the construction line. 100.The potential issues of pipeline construction include traffic congestion and a temporary traffic management plan shall be submitted by the contractor at least one month before construction commences and approved and properly resourced by CDGK before construction commences. 101.The WDM routes are mainly major of traffic corridors. Construction activities along these routes are likely to cause hindrance in traffic flow if not mitigated properly. A temporary traffic management plan will be developed and submitted by the contractor at least one month before commencement of construction. The main objectives of the plan shall be to maximize the safety of the workforce and the traveling public. The main secondary objective will be to keep traffic flowing as freely as possible. 102.The Temporary Transport Management Plan will include consideration of the following i)

Lane availability and minimize traffic flows past the works site.

ii) Establish acceptable working hours and constraints. iii) Agree the time scale for the works and establish traffic flow/delay requirements. iv) Programming issues including the time of year and available resources. v) Acceptability of diversion routes where necessary. vi) Need for road closures and the necessary Orders. vii) Co-ordination with other planned road and street works. viii) Discuss the CDGK inspection/monitoring role. ix) Discuss establishment of incident management system for duration of the works x) Agree publicity / public consultation requirements (advance signing etc.).

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103.The plan will be reviewed by CDGK and approved, if found appropriate. Resources from contractor, CDGK, and the traffic police will be provided as per the plan before construction commences. Public Safety 104. Public safety, particularly of pedestrians can be threatened by the excavation of the trenches for pipeline construction. Project safety plan shall be submitted by the contractor and properly resourced at least on month before construction commences and approved by CDGK before construction commences. The plans shall include provisions for site security, trench barriers, reflective signs and covers to other holes, hoarding plans and any other safety measures as necessary. 105.Public safety, particularly of pedestrians can be threatened by the excavation of the trenches for sewer construction. A safety plan will be submitted by the contractor and properly resourced at least one month before construction commences and approved by CDGK before construction commences. The plans will include provisions for site security, trench barriers, reflective signs and covers to other holes, hoarding plans and any other safety measures as necessary. 106.It is also recommended that a contingency plan shall be in place before construction commences to cover emergencies in the case of damage to other infrastructure such as wastewater collection and drainage system, water distribution lines, power cables etc, especially when the works are near utilities serving hospitals. 107.With the thorough identification of all utilities and correct planning for rerouting and re-provisioning there should be no damage to other infrastructure such as wastewater collection and drainage system cables etc. However in order to cover any unforeseen disruption or disaster the contractor and to see through the plans effectively it is recommended that CDGK convene a project utility re-provisioning coordinating committee to meet with the contractor(s), PIU and representatives of all utilities to anticipate and plan works on a six weekly basis (twice per quarter). C

Operational Impacts

108.No major operational related environmental impacts are expected from the subprojects. Some minor impacts may include malfunctioning of plant and pipe bursts that might cause hardships to communities but these will be dealt with by the routine emergency procedures and . Maintenance works causing disruption of traffic will need to be coordinated with the traffic planning authorities. 109.Disposal of sludge and wastewater from the water treatment such as the clarifiers and filter wash water are two waste streams of water treatment plants treating surface water. These can contain high concentrations of organic pollutants and solid particles entrained in raw water. It is relatively difficult and expensive to dewater the sludge because of its high specific resistance due to alum. Alum can be recovered from sludge while the sludge can be disposed of in large lagoons or eventually into the sanitary landfills when they become operational. 110.The new water treatment plant is likely to use chlorine gas for disinfection of treated raw water. Chlorine is applied for the deactivation of microorganisms. Being a cheap process, it is one of the most commonly used methods for water disinfection. Chlorine is stored in the water treatment plant as pressurized gas in steel cylinders. 111.Chlorine is used as a standard disinfectant in all water treatment plants in Karachi. However, it has not been possible to identify any written operational plan for clorination or water monitoring. It is entirely possible that due to operational and economic reasons

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the chlorination may not be very well monitored but as yet no information is available on the specifications for chlorination. 112.Chlorine is a skin irritant and an asphyxiating toxic gas that has a very strong odor. The odour threshold for chlorine varies between individuals but is estimated to be between 0.2 to 0.4ppm. USEPA has established an environmental air limit of 0.5 ppm. Exposure to higher levels could result in discomfort and irritation. The occupational safety limit for chlorine is 1ppm for eight hours. Short-term exposure to 30 ppm or more of chlorine gas can result in chest pain, vomiting, coughing, difficulty breathing, or excess fluid in the lungs. Exposure to 430ppm in air for 30 minutes will cause death. 113.The chorine related risk during plant operation includes accidental release and exposure of plant workers and, in the worse, case exposure of the community. Although the probabilities are low, during the handling of storage cylinders and their piping connections, the potential exists for an accidental leak and resulting release of chlorine gas. To minimize the risk of adverse impact on the workers and communities an operational plan will be developed for refilling and routine maintenance and emergency plan will be developed and put in place. Regular surveillance shall be conducted to check for chlorine leaks using grab sampling and chlorine indicator tubes. 114.KWSB has a laboratory in Karachi for testing of raw water, treated water and water supplied to the consumers. There are facilities to test all commonly measured water quality parameters. The consultants have not been able to identify any information on the frequency at which water is tested or what parameters are checked. There is no regular reporting of the water quality to public. However some testing is apparently undertaken if there is a complaint or when there is a problem. In the absence of complaints it is assumed that water quality is acceptable. Some independent tests conducted by some organizations that claimed that the water supplied to the citizen is overwhelmingly contaminated. KWSB position is that there is no contamination at the distribution head. The contamination (mainly biological) enters the water due to damaged distribution system. There is no independent verification of whether the supplied water is free of contamination or not, however, the distribution system certainly appears to be the source of contamination. To address this problem, one option is to rehabilitate the entire distribution system. This project is the one of the first steps in this process. 115.The water served in distribution systems may therefore be polluted or contaminated due to (i) fluctuating pressures due usually to excessive leaks in the distribution system causing seepage of pollutants/contaminants into pipes, (ii) inadequate operation and maintenance (O&M) for filters and chlorinators and (iii) lack of chlorine residual monitoring in distribution systems. 116.Raw water quality may also be unsatisfactory caused by excessive total dissolved solids, chlorides, nitrates, fluorides, and other contaminants present at concentrations above acceptable limits and which cannot be removed by feasible treatment processes. There could also be excessive pathogenic pollution and excessive mineral constituents (iron, manganese, color, hardness, and turbidity). 117.Therefore the EMP has included the need for a competent Water Quality O&M Plan with monitoring of the relevant parameters to address these problems. KWSB must also make operational plans to introduce 7-days-a-week, 24-hours-a-day, water supply to prevent depressurizing of distribution system which results in ingress of contamination.

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D

Beneficial Effects

118.The key benefits are the provision of treated water to the communities and the monitoring of water quality. This will lead to improvements in hygiene, health, environment and sanitary conditions and consequent savings due to overall improvements in environmental health. Other enhancements can be made through tree planting, removal of the dilapidated asbestos water pipe system and the introduction of better management practices for construction contracts.

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V. STAKEHOLDERS CONSULTATION 119.The objectives of the stakeholder consultation process was to disseminate information on the project and its expected long-term and short-term impacts among primary and secondary stakeholders, and to gather information on relevant issues so that the feedback received could be used to address these issues at an early stages of project design. Another important objective was to determine the extent of the negative impact of different project activities and suggest appropriate mitigation measures. A

Identification of Stakeholders

120.Stakeholders are people, groups, or institutions that may be affected by or can significantly influence, or are important to the achievement of the stated purpose of a proposed intervention. 121.Group meetings were held along the two pipeline routes and around the COD Filtration Plant. There are no communities in the vicinity of the NEK Filtration Plant to consult. A total of 62 persons were consulted. The consultation locations are shown in Figure 6. B

Consultations

122.The results of the public consultations are summarized below. The details are recorded in Table 5. Meetings with Residential Consumers 123.Group meetings and individual meetings were held with various residents of Korangi residential areas and Malir Residential Areas. 124.People complained of shortage of water and welcomed the laying of new pipeline. A figure of Rs700 was reported as the amount that the residents are paying for water from tankers. Water quality was also reported as a common concern. Some people have boreholes in their houses but the water is brackish. 125.Several respondents complained of the disruption that takes place during the construction activities on large public projects. Other than delays on the road, the blockages also cause the public buses to take alternate routes forcing the commuters to walk longer distances to catch the buses. 126.The dust from the construction activities and spoil banks was cited as a cause of concern as it affects the business of the roadside vendors such as fruit sellers. The residents were concerned about the diversion of traffic to smaller roads and streets that increases the risks of accidents. 127.Other issues raised by the commuters included the alteration or potential blocking of storm water run-off and disruption of utilities. Landhi Association of Trade and Industry 128.The Association was represented by its secretary in the consultation. He highlighted the problems that are faced by the industries when development work takes place. He cited the example of the fly-over that is under construction in Landhi. According to him, other than the disruption in traffic, the construction also resulted in damage to the sewerage lines, telephones system and other utilities. He suggested that a) alternate

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routes should be provided for traffic; b) coordination between the civic agencies should be improved; and c) the industries should be involved in monitoring and evaluation. Korangi Association of Trade and Industry 129.Consultation was undertaken with the Secretary of the Association. He claimed that there is acute shortage of water for the 2,500 industrial units in Korangi. Industrial units are also purchasing water from tankers. Some units also have water bores to extract groundwater. Urban Resource Centre 130.Mr Arif Hassan of the Urban Resource Center gave detailed opinion on the problems of Karachi water supplies and provided valuable suggestions. His discourse emphasized that recovery of the losses (that according to him are of the order of 40%) should be a priority instead of introduction of new supplies. He also suggested that desalination of subsoil water should be considered as an option. 131.On planning and research aspects, Mr Arif Hassan suggested that detailed documentation of existing system should be produced. He proposed that uninformed decisions, taken in absence of research and consultations, were the main cause of failures of projects. In his opinion, each individual project should be component of a larger master plan and the complete component should be implemented. Further, the planning should be based on research and mapping not on intuitions and public demand. He also suggested decentralization of water supply and the introduction of bulk water metering at UC levels. 132.Other problems that he mentioned included the poor institutional capacities, constant political interference, and poorly paid staff that causes inefficiencies.

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Figure 6: Location of Public Consultations

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Table 5: Summary of Public Consultation No. 1

Town

Name

Korangi

Shah Jahan, Waliullah, Sartaj Khan

Participants

Address

Date June 7

Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed Delays in project, “We do not expect any new project will complete in less than 7 years” Dust during construction and due to incomplete restoration is the major problem that the community and shopkeepers will face Access to the shops, industries, and residential areas will be blocked.

Action Taken/Proposed Institutional capacity building, organizational and management structure to ensure sound project management and prevent delays, obstructions, and services utility disruption

Most of the existing traffic will be diverted into the residential areas which will result in the congestion of traffic in the streets and may pose hazards of accidents to the community especially to the children. Road from Hussain Chorangi to the graveyards is already blocked due to construction activities which has also resulted in the blockage of sewerage The commuters have to walk for 1 to 3 kilometers each day to reach to the nearest bus due to this blockage. Buses also take alternative longer routes which takes additional time. Telephone cables of the community are damaged during construction activities which take months for the relevant department to fix. There is no coordination among the departments within the government. The storm water drainage system is disturbed during construction and due to incomplete restoration.

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No. 2

Town Landhi

29/03/08

Name

Participants

Address

Azra, Housewives Sherpao Zaitoon, Colony Jano, Parveen, Nasara, Khari, Nazra, Jamala, Rukhsana, Mushtari, Nazara, Tasleem, Meena Gul, Robina, Sahzia, Shazia, Mazerat, Nishad

Date

Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed

June 11, 2007 No comments

Action Taken/Proposed -

General discussion on lack of water, health facilities, poor sanitation, transportation problems, and deteriorating road network. Concerns about the existing excavations for road construction and the associated hazards for the community particularly children.

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No.

Town

3

Name Urban Resource Centre

Participants

Address

Arif Hassan

A-2, 2nd Floor, West Land Trade Centre Commercial Central Area Karachi Administrative Cooperative Housing Society Block 7&8, Shaheed-eMillat Road, Karachi

Date

Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed

Action Taken/Proposed

40% losses to be recovered first before introducing new supplies. Even 20% recovery will give more water. More planning required on each project before final decisions. Subsoil water desalination is one of the options. Bulk water metering should be introduced at UC levels. A detailed documentation of existing system should be produced. Uninformed decisions taken in absence of research and consultations will lead project to the failures. Each individual project should be component of a larger master plan and the complete component should be implemented. Planning should be based on research and mapping not on intuitions and public demand. The current project if it is done will have not problems in becoming successful. Decentralization of water supply. Better institutional arrangements would be required. System is poor but easy to rectify. Constant political interference create hurdles in implementation. Staff is inefficient because they are badly paid. Contamination is not necessarily on source it might be in the distribution system. There is contamination proven even in treated water. Contamination happens from sewerage and subsoil water.

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No.

Town

Name

Participants

Address

Date

Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed

4

Landhi

Mukhtair Ashraf Shahjee Shamso Khan Fayyaz Faheem Naeem Saeed Asad Ismael Raj Mutabar Shah Wali

Sellers of Sherpao fried fish, Colony salad, Tikka, Haleem, juice, ice, burger, kheer, paan, food, chicken meat, biryani, and fruits (last two)

June 10, 2007

5

Landhi

Syed Rahim Shah

Homeopathic doctor, social activist

June 11, 2007 If once a road excavated it takes years to carpeted again

Ismael

Dry and seller

June 11, 2007 The roads repair after long interval of time

6

Landhi

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fruits Sherpao juice Colony

Action Taken/Proposed

The excavation of the road is an obstacle to our business

Institutional capacity building, organizational and management structure to The blockage of roads compel the people to shift their ensure sound project way management and prevent delays, obstructions, and People stop buying from our stalls as ours is directly services utility disruption affected and affects our income

The development work damages telephone lines, drainage system, gas line and water pipe lines

Institutional capacity building, organizational and management structure to ensure sound project management and prevent delays, obstructions, and services utility disruption

Institutional capacity building, organizational and When roads had been excavated some years ago, the management structure to public hesitated in buying from us due to the dust ensure sound project management and prevent Traffic jams were observed in the area delays, obstructions, and Proposed pipe lines/ excavation of might resulted the services utility disruption same what experienced in the past

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No. 7

Town Landhi

8 9

Name Moin

Participants

Address

Burger shop Sherpao Colony

Landhi

Khaista Gul Burger shop Sherpao Colony

Korangi

Nehal Hassan

Secretary, Korangi Association of Trade and Industry

Date

Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed

June 11, 2007 The excavation of roads will affect our business Dust would cover everything in the area. Very few would like to eat in the presence of dust

June 11, 2007 No comments There are 2500 industries in Korangi industrial area, these industries face acute shortage of water and sewerage problem. There is no water in some areas.

Action Taken/Proposed Institutional capacity building, organizational and management structure to ensure sound project management and prevent delays, obstructions, and services utility disruption Improve water quality management (WQO&M Plan)

Water is contaminated Industries facing excessive bills for water charges Association has been recording daily 15-20 complains on water issues Survey for water is desperately needed and important task because industries purchasing water from tanker suppliers. It is increasing the production cost. PKR 1800 is being paid per tanker in the Korangi industrial area. There is a private hydrant in the Korangi industrial area (at Chamra Chowrangi). Underground water available at 10ft. Some industries prefer boring instead of purchasing water from water tanker suppliers

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No.

Town

10 Landhi

Name Ali Sher, Akber, Shabir and Shabir

Participants Factory workers

Address Zorash Towel Factory

Date

Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed Fresh water is available for drinking in the factory Drinking water is purchased from tanker suppliers

Action Taken/Proposed Improve water quality management (WQO&M Plan)

Boring water is being used in the factory for industrial purposes There is no connection of water in the factory

11 Korangi

Tasleem and others

Bilal Colony

There is no running water. Water shortage persisting for a year. We are purchasing water for PKR 700 per tanker. If we use brackish water, it result in itching and skin diseases. Two families (13 persons) use half tanker of water in about a week (about 2.5 tankers per month). We have to boil the water to drink. We use to pay PKR 500 for water charges to city. There was agitation for water in which all of us participated. We are ready to pay for water charges if good service is available. in this street 3-5 house using water getting from boring but the water is brackish.

12

13

14

29/03/08

Tanker Supplier /driver

5 times come to supply water to this street

Water supplier (Donkey cart driver)

Water is being supplied from Gulzar colony

Khalid

A water tanker is supply 1600 gallon water

A drum (container ) of water is being sold for PKR 30 Boring Mechanics

Improve water quality management (WQO&M Plan) Improve water quality management (WQO&M Plan)

Water is available at 80ft but it is brackish. We charge Improve water quality PKR 60 for per ft of boring. management (WQO&M Plan)

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No.

Town

15

Name

Participants

Fatah Khan

Address Bilal Colony (Sector B)

Date

Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed

Action Taken/Proposed

There are 700-800 household in Sector A of Bilal Improve water quality colony. There is a acute shortage of water in the area. management (WQO&M Sewerage system and roads are in poor condition. Plan) In the past water had been supplied for 2 hours on daily bases, then it was reduced to 10 minutes. Even this water was contaminated. Water for sector A is being supplied form industrial area while for sector B water is being supplied from Awami colony

16 Korangi

Mr Nehal Hassan

Secretary, Korangi Association of Trade and Industry

There are 2500 industries in Korangi industrial area, these industries face acute shortage of water and sewerage problem. There is no water in some areas and where it is available it is contaminated.

-

Industries are facing excessive bills for water charges. The Association records 15-20 complaints daily on water issues alone. Survey for water is desperately needed and important task because industries purchasing water from tanker suppliers. It is increasing the production cost. PKR 1800 is being paid per tanker in the Korangi industrial area. There is a private hydrant in the Korangi industrial area (at Chamra Chorangi). Underground water available. Some industries prefer boring instead of purchasing water from water tanker suppliers

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No.

Town

17

Name

Participants

Address

Faiz Ahmed watch maker Bilal Colony (Sector A)

Date

Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed There are 1000 plot in Sector A mostly occupied by industrial workers with income PKR 3,000-15,000. The colony was established in 1972. Plots consist of 80 and 240 sq yards. There are also many illegal constructions.

Action Taken/Proposed -

Water shortage started 3 years ago. Now the city is also sending us water bill. Six month ago I received a bill of 25000 for last 15 years. We ready to pay for water but the charges should be rational. Water is providing after a gap of 4 days 10 minutes only. We supplement this water by brackish water that is brought in drums by our children. Some boil the water before use. 18

Sawar Khan, Akhter Ali, M Shafiq

Bilal Colony

Ina nearby locality, about a month ago 3 people died of Improve water quality water disease caused by some chemicals were found management (WQO&M in the water. Plan)

19

Zafar Iqbal Rahim Khan

Bilal Colony

No comment on the project.

Bilal Colony

No comment on the project.

20

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-

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No.

Town

21

Name

Participants

Landhi Mr Rashid Association of Trade and Industry

Address Deputy Secretary

Date

Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed

Action Taken/Proposed

June 2, 2007 Government do not provide any alternate route while development work carried out. We are facing a lot of problem from the fly over build near Younaus Brother (YB) Textile.

Institutional capacity building, organizational and management structure to ensure sound project management and prevent delays, obstructions, and services utility disruption

The sewerage system is destroyed, telephones are dead The industrial wastewater is not properly discharged because the wastewater lines are blocked Before the construction of fly over meetings were held with authorities but in vain. Even Mohmmad Ali Tabba (owner of YB textile) tried his best to avoid the wreck but failed. Work on the proposed pipe line should not begin unless the fly over at Quaidabad and on railway line near Younaus Brother not completed. According to plan the Quaidabad the fly over must be completed in June. It seems that 3-4 month more required accomplishing the task. The fly over near YB will required more time to complete. We need better management and more coordination Although we have been informed before the development work yet we not involve in monitoring and evaluation

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No.

Town

Name

22 Gulshan Major (Rtd.) Ali Mirza, Qazi Iftikhar, Abdash Deho, Nisar Chandio, Abdullah Abdur Rasheed Noorani

29/03/08

Participants Residents and Businessmen

Address

Date

Shanti Sept 13, 2007 Nagar, Dalmia, UC 6, Gulsahn Block 18 and 19

Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed

Action Taken/Proposed

People of the area express that they do not expect any Institutional capacity adverse impact on the community because the land is building, organizational and inside the boundary of KWSB management structure to ensure sound project After the completion of construction government management and prevent should ensure that no water is stolen delays, obstructions, and services utility disruption Traffic movement during construction should be managed and that heavy traffic should not add to the existing worst condition especially during afternoon and evening timings in the streets. .A designated route should be specified avoiding narrow streets to ensure the minimized risk of accidents and to minimize the disturbance due to noise and dust

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VI. INSTITUTIONAL REQUIREMENTS AND ENVIRONMENTAL MANAGEMENT PLAN

A

Institutional Requirements

133.Environmental regulations of the GoP require proponents of projects that have reasonably foreseeable qualitative and quantitative impacts are required to submit an IEE for their respective projects (Schedule I). Proponents of projects that have more adverse environmental impact (Schedule II) are required to submit an environmental impact assessment (EIA) to the respective provincial Environmental Protection Agency (EPA). Water supply and treatment facilities costing more than PKR 25 million require and EIA and those costing less than 25 million require and IEE. Whereas the impacts for these projects are very manageable no IEE has been submitted by CDGK for any other similar water sector project. However CDGK has submitted an IEE and had approved by EPA for one of the waste transfer stations at (Gulshan-e Iqbal) but not under this MFF. That project would be fairly similar to the NEK and COD plant improvements. Therefore it can be expected that the environmental assessment requirements for NEK and COD plants may not be to exacting. However it is also noted that all four water sub-sector projects will exceed the Rs25 million EIA threshold / trigger. 134.It has also been noted that in another ADB MFF project, Pakistan EPA has assumed that all proponents will consult with the relevant provincial EPAs (PEPA) and follow their advice with regards to environmental assessment requirements for all MFF subprojects. In 2006 Punjab EPA requested disclosure of the scope and extent of each of the subprojects in ADB Power Transmission Enhancement MFF. As such it is expected that all the Tranche 1 and subprojects in future tranches will be disclosed to the SEPA and the environmental assessment requirements of the statutory authority will be followed. An Environmental Assessment and Review Framework (EARF) has also been prepared to select, assess, monitor, and manage the potential environmental impacts of any subprojects in future tranches. 135.Therefore prior to implementation and commencement of construction of the treatment plants and pipelines subprojects, CDGK will need to notify the provincial EPA (SEPA) of the location and scale of the subprojects and comply with any environmental requirements and, if IEE is required, obtain approval “No Objection Certificates” and PEPA clearance (under the Environmental Protection Act 1997). Whatever the SEPA requirements, IEEs must be prepared for All components for ADB. CDGK will also need to liaise and coordinate with SEPA. The EMP (Appendix B) was prepared taking into account the capacity of the CDGK Municipal Services Department, as described in the Institutional and Environmental Assessment of SEPA and City District Government of Karachi18. 136.In September 2007, Municipal Services of CDGK had one full time environmental staff member, the District Officer Environment (DOE). The DOE is responsible for addressing environmental concerns for a citywide development program. The DOE took charge of his post and department in February 2007. The DOE therefore faces considerable challenges in implementing the terms of reference. Other problems have been identified with the lack of capacity in SEPA but these are not the subject of this IEE.

18

Institutional Appraisal of Environmental Assessment and Management Capability within Sindh Environment Protection Agency (SEPA) and City District Government of Karachi (CDGK), TA 4573 PAK, Preparing the Karachi Mega City Development Project, September 2007.

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137.At present DOE is responsible for overseeing several key functions that relate to environmental assessment and management. These were previously under the jurisdiction of the Law Department but were transferred to the DOE. The environmental responsibilities of CDGK are defined under the Sindh Local Government Ordinance 2001 (SLGO 2001) and there is a general requirement to raise environmental awareness in the CDGK jurisdiction. The key elements directly relevant to the implementation of the MFF subprojects can be summarized as follows: i)

To ensure implementation of environmental protection and preservation measures in all development projects at district level and sensitize government agencies on environmental issues (that can be achieved by following the EARF);

ii) To assist provincial EPA in discharge of its functions under the Pakistan Environmental Protection Act, 1997; iii) To ensure, guide and assist proponents of new projects in the submission of IEEs and EIAs to the Director General EPA Sindh for approval; iv) To request the Environmental Magistrate or Environmental Tribunal to take cognizance of any offence under the provisions of PEPA 1997; v) To undertake regular monitoring of projects financed from the provincial sustainable development fund and to submit progress reports to the DG FPA Sindh for publication in its annual report. 138.At present the DOE is alone within the CDGK with sole responsibility for brining environmental issues to the notice of corporate management (District Coordination Officer, DCO and City District Nazim). The most significant challenge is the lack of human and financial resources and necessary infrastructure. In 2006, the Governor of Sindh made a call to establish a separate environment department in the face of growing national and international environmental concerns. The DOE has made a proposal for a separate environment department to the District Coordination Officer (DCO) but as of September 2007 there is no change to the existing CDGM departmental structure. 139.If the terms of reference stated in the SLGO are to be realized then overcoming environmental capacity deficit within the CDGK will need to be addressed. Environmental assessment and coordination with SEPA are both key to CDGKs environmental responsibilities under the SLGO. However although proposals have been made to address this shortfall in environmental capacity by DOE, a response in terms of adequate additional human and financial resources may not materialize for some time. Therefore there is likely to be a period at the start of the KMCSDP MFF when DOE has insufficient resources to carry out the environmental assessment requirements for ADB. The lack of appropriate institutional arrangements may interfere with the KMCSDP attempts to ensure compliance with both GoP and ADB environmental assessment requirements. Therefore it is recommended that the KMCDSP provide an environmental cell of at least two full time environmental specialists to support the DOE and remain in support until such time as the proposed Environmental Department is created or sufficient other resources are made available to DOE in CDGK and the proposed EDO Environment is fully capable of supporting the environmental assessment portfolio of CDGK. At such a time the appointed environmental cell professionals may be absorbed into the EDO Environment in order to retain institutional memory. 140.The EDO will need more staff and training resources if effective quality control is to be provided for the EMP implementation and much of the environmental assessment work may be delegated to consultants. The aspirations of the SLGO objectives, to raise awareness both within Municipal Services Department and more broadly in CDGK, are sound, but at present the awareness level is not high. Specific areas for immediate

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attention are in environmental assessment and auditing, waste, air, water and noise pollution management and impact mitigation. As a first step CDGK should consolidate DEO as soon as possible and nominate additional suitable staff to work from within the department to monitor and audit progress on environmental management for the MFF. 141.For the KMCSDP, the environmental cell staff, engaged to support the DEO for the MFF subprojects, must be appointed at the outset of the implementation. At the detail design stage of subproject the cell shall have at least one environmental specialist to assist the DEO to address all environmental aspects in the detailed design and contracting stages and the relevant statutory submissions and approvals. In addition, there needs to be an environmental specialist to cover the implementation of environmental mitigation measures in the construction stage of the subproject packages. The environmental specialists should work as members of the environmental management team with significant proportion of time spent in the field, observing and making recommendations to improve or modify environmental mitigation measures executed by the contractors, as the EMP evolves and the MFF subprojects proceed, to respond to unexpected circumstances. 142.The requisite staff should be appointed prior to the commencement of the tendering for the construction activities to ensure the inclusion of environmental requirements can be translated into contractual works for completion of the pipeline and filtration plants and also respond to unexpected circumstances. Both members of the cell can initially be bolted on to the DEO or within supervising consultant’s team. i)

The environmental specialists will: a)

Work with DEO to execute any additional EIA and IEE requirements prior to project commencement and review the EMP;

b)

Work with the project management team(s) in CDGK to ensure all environmental requirements and mitigation measures from the EIAs and IEEs and environmental performance criteria are incorporated in the contracts; and

c)

Work with contractors to manage the implementation of the project EMP (as revised).

ii) Overall implementation of the EMP will become CDGK’s responsibility. Other parties to be involved in implementing the EMP are as follows: a) Contractors: responsible for implementing all measures required to mitigate environmental impacts during construction; and b) Other government agencies: such as UC, Towns authorities, regional EPA and state pollution authorities for monitoring the implementation of environmental conditions and compliance with statutory requirements in their respective areas. 143.Considering the number of government agencies that need to be involved in implementing the EMP, training workshops should be conducted at every six months or twice each year, for the first 3 years, to share experience in the implementation of the subprojects and the monitoring report on the implementation of the EMP, to share lessons learned in the implementation and to decide on remedial actions, if unexpected or uncontrolled environmental impacts occur. B

Environmental Assessment of Follow-Up Subprojects

144.Other Network Improvement Programs, treatment plants, pipelines etc. may be proposed in future Tranches in specific supply zones and the details will be prepared

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later. Based on the likely urban location it will be in similar location to the two treatment plant and two pipeline subprojects considered above and a range of similar impacts is likely. Other follow-up subprojects in the water management sector may involve more complex environmental assessments. A detailed environmental assessment and review framework (EARF) procedure has been prepared that must be followed as required by ADB for all the subprojects in future tranches. C

Environmental Management Plan

145.This IEE concludes that the construction impacts will be manageable if the mitigation measures are implemented thoroughly. The Environmental Management Plan is based on the type, extent and duration of the identified environmental impacts. The EMP has been prepared by close reference to best practices and in line with ADB’s Environmental Policy (2002) and Environmental Guidelines (2003). 146.Implementation of construction of the treatment plants and pipelines will need to comply with several environmental requirements and clearance will be required from SEPA for environmental assessment. DOE will also need to confirm that contractors and their suppliers have complied with all statutory requirements for licenses from CDGK. DOE should check that contractors have all the necessary valid licenses and permits for all powered mechanical equipment, permissions and licenses for use of powered mechanical equipment if necessary and the use of local water supplies (and to construct and operate plants such as concrete batching in line with all environmental regulations and license conditions from EPA). 147.The effective implementation of the EMP should be audited as part of the loan conditions and the executing agency must be prepared for this. In this regard the CDGK (the Implementing Agency) must be prepared to guide the design engineers and contractors on the environmental aspects and ADB has suggested that such leadership and auditing should be undertaken by the DOE and an “environmental cell” from the commencement of the MFF. 148.Prior to implementation of Tranche 1 and again before Tranche 2 the EMP shall be amended and reviewed by the DOE and environmental cell in due course after detailed designs are complete and contracting arrangements are known. Such a review shall be based on reconfirmation and any additional information on the assumptions made at the feasibility stage on location scale and expected operating conditions of the subprojects. For example, in this case if there is additional land required for installation of facilities or pipelines the designs may be amended and the environmental significance must be reviewed. Although no major additional impacts would be anticipated based on the information provided to date, the performance and evaluation schedules to be implemented during project construction and operation can be reviewed, updated, and costs estimates can be revised if necessary. 149.The EMP must be reviewed by the DOE and project management in CDGK and approved before any construction activity is initiated on Tranche 1, to take account of any subsequent changes and fine tuning of the proposals. It is recommended that this takes place before the Tranche 1 contracts are worked out in detail and before prequalification, so that the environmental status of the existing treatment plants and pipelines is carried out as a baseline for benefit monitoring, using the EMP as the performance indicator. 150.This IEE including the EMP should be used as a basis for an environmental compliance program and an updated EMP should be included in the revised contract documentation for All components. The updated EMP, any conditions of the environmental clearance from the SEPA and any subsequent licenses and approvals

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from EPA should also be included in the environmental requirements for the contractors in the compliance program. Therefore, continued monitoring of the implementation of mitigation measures, the implementation of the environmental conditions from environmental clearance, and monitoring of the environmental impact related to the construction of all future works to complete the treatment plants and pipelines should be properly carried out and reported periodically in monthly progress reports. Compliance with all of the EMP requirements shall also be reported in other periodic project performance reports. 151.The impacts from construction and operation of the subprojects will be manageable and no insurmountable impacts are predicted providing that the updated EMP is included in the contract documents and implemented to its full extent. The details of the current summary EMP (Appendix) are in the form of the matrix and may require revision as the project reaches detailed design. The impacts have been classified as per the design/preparation stage, construction stage and operation and maintenance stage. The matrix details the mitigation measures recommended for each of the identified impacts, approximate location of the mitigation sites, time span of the implementation of mitigation measures, an analysis of the associated costs and the responsibility of the institution. The institutional responsibility has been specified for the purpose of the implementation and the supervision. The matrix is supplemented with a monitoring plan for the performance indicators. An estimation of the associated costs for the monitoring is given with the plan. The EMP has been prepared following best practice and the ADB Environmental Assessment Guidelines 2003. D

Monitoring

152.Monitoring activities during implementation will focus on compliance with license conditions, recording implementation of mitigation measures, recording environmental parameters, reviewing contractor environmental performance and proposing remedial actions to address unexpected impacts during construction. Some of these tasks can be assigned to the contractors and managed by the DOE and environmental cell. The monitoring plan (Tables 6 and 7) was designed based on the likely subproject cycle. 153.During the preconstruction period, the monitoring activities will focus on (i) checking the contractor’s bidding documents, particularly to ensure that all necessary environmental requirements have been included; and (ii) checking that the contract documents’ references to environmental mitigation measures requirements have been incorporated as part of contractor’s assignment. Where detailed design is required (e.g. for further elaboration of the recycling facilities at the treatment plants and pipelines) the checking of updated designs must be carried out. During the construction period, the monitoring activities will focus on ensuring that environmental mitigation measures are implemented, and some performance indicators will need to be monitored to record the subproject’s environmental achievements and to guide any remedial action to address unexpected impacts. 154.Monitoring activities during project operation will focus on (i) volume of raw water and treated water; (ii) volume of sludge and wastewater discharged from the treatment plant; (iii) residual chlorine in certain sections of transmission mains; and (iv) physicochemical and biological parameters of raw water supplied to the treatment plant. The operation phase Environmental Monitoring Plan is provided in Table 8. 155.To facilitate EMP implementation, during preparation for construction the contractors must be prepared to cooperate with the environmental cell team, DOE, and the local population in the mitigation of impacts. However, experience suggests that contractors may have little impetus or interest in dealing with environmental problems in the absence of performance-linked criteria. Therefore, the required environmental mitigation must be

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clearly described in a memorandum of understanding and other contract documents at the bidding stage; the completion of mitigation should be linked to payment milestones.

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Table 6: Environmental Monitoring Plan for Tranche 1 Water Sector Subprojects Environmental Monitoring Tasks19

No. 1

Implementation Responsibility

Implementation Schedule

Design Phase

1.1 Audit project bidding documents to ensure CDGK through IEE and EMP is included. environmental officer

Prior to issue of bidding documents.

1.2 Disclosure of subproject to SEPA 1.3 Monitor final site selection (alignment) and CDGK through its environmental compliance with EMP environmental officer

Prior to CDGK approval of detailed designs.

1.4 Monitor the performance of environmental CDGK through training and briefings and of the environmental officer environmental awareness of project staff and CDGK

Ongoing, prior to and during implementation of works and operation.

2

Construction Phase

2.1 Regular (monthly) monitoring and reporting (quarterly) of contractor’s compliance with statutory environmental requirements

CDGK through environmental officer

Continuous throughout construction period.

2.2 Regular (monthly) monitoring and CDGK through reporting (quarterly) of contractor’s environmental officer compliance with contractual environmental mitigation measures

Continuous throughout construction period.

2.3 Regular (monthly) monitoring and reporting (quarterly) of complaints and responses or environmental mitigation measures

CDGK through environmental officer

Continuous throughout construction period.

2.4 Monitor adjustments to the EMP and the thorough implementation of detailed EMP

CDGK through environmental officer

During all phases of the subprojects

2.5 Commissioning phase monitoring of as built equipment and facilities versus environmental contractual performance criteria

CDGK through environmental officer

At commissioning.

3

Operation and Maintenance Phase

3.1 Observations during routine maintenance CDGK through inspections of facilities. Inspections will environmental officer include monitoring implementation of operational mitigation measures versus environmental criteria specified in EMP for operational impacts

As per CDGK inspection schedules

3.2 Implement Water Quality O&M Plan.

During the life of the project

Include monitoring operational water parameters from appropriate locations based on the preliminary schedule shown in Table 8.

CDGK through environmental officer

Table 7: Summary of Estimated Costs for EMP Implementation 19

Monitoring of issues related to compensation of landowners for land acquisition and loss of production, etc. are addressed in the Resettlement Action Plan.

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Item

Sub Item

Staffing, audit and monitoring

1 persons for 2 years

Monitoring activities

As detailed under EMP

Mitigation measures

Estimated Total Costs [PKR]

Estimated Total Cost [USD]

1,500,000

25,000

16,000,000

266,700

As prescribed under EMP and IEE

8,000,000

133,300

Transport

1 vehicle for 2 years

1,000,000

16,700

Contingency

4% contingency

500,000

8,300

27,000,000

450,000

Total

Table 8: Operations Phase Environmental Monitoring Plan Parameters

Frequency

Volume of Raw water received

Flow rate

Daily

Treated water supplied

Flow rate

Daily

Wastewater discharged to pond/tank

Flow rate

As and when generated

Water re-used

Flow rate

As and when used

Sludge generated

Quantity/volume

As and when generated

Quantity

As and when used

Physical, chemical, and biological parameters

Monthly or when significant change in raw water quality is suspected

Dosing of Chemicals used (quantity) Quality of Raw water

Treated water at plant outlet Physical, chemical, and biological parameters, residual chlorine

Monthly or when significant change in raw water quality is suspected

Treated water at the head of Physical, chemical, and the distribution system biological parameters, residual chlorine

One sample monthly drawn from different localities

Treated water in taps

One sample monthly drawn from different localities

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Physical, chemical, and biological parameters, residual chlorine

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VII. FINDINGS AND RECOMMENDATIONS 156.This IEE study was carried out when the MFF Tranche 1 subproject were at the stage of conceptual design during the TA 4753 (PAK). Essentially secondary data were used to assess the environmental impacts in a comprehensive manner and public consultation and site reconnaissance were carried out in order complete the environmental assessments and recommend suitable mitigation measures. 157.Several actions are required during the detailed design stage to minimize impacts to acceptable levels and described in the EMP. The negative environmental impacts from the treatment plant and pipeline subprojects will mostly take place during the construction stage but there are also some potential negative impacts for the operational stage as well as many significant beneficial impacts. The construction impacts should be very predictable and manageable and with appropriate mitigation few residual impacts are likely. 158.Some key actions are required after the detailed designs are developed. CDGK should update the EMP and together with the IEE recommendations all mitigation measures should be included as contractual requirements, accepted by all contractors prior to signing the contract(s). Certain mitigation management plans (temporary traffic management, utilities management, materials management master plan, waste management etc.) should be deliverable by the contractors before construction commences. 159.The construction is restricted to Government land and as far as can be ascertained at this stage there is not likely to be any significant additional land required to complete the construction. However given the stage of the treatment plant and pipeline designs it is possible that some additional engineering requirements could be included at the detailed design stage, that may require additional land. At this stage these requirements are not quantifiable. If further land is needed it can be determined as the detailed designs are worked out and to dovetail with the detailed design and minimize adverse impacts and maximize benefits. A social impact assessment and resettlement action plan has been completed in tandem with the environmental work stream that will apply to All components. 160.At the detailed design stage a review should be conducted of the monitoring activities proposed in this IEE for air quality, noise and water quality to establish the parameters to be checked during the construction and operation. Reference should also be made to the recommend monitoring plan for performance indicators (Table 6) from this study. If necessary baseline monitoring should be carried out prior to the commencement of construction to redefine the parameters and frequency of monitoring to be checked during treatment plants and pipelines construction and operation. Provisions should be made in the contract documentation to allow integration of the results of the baseline review into the contract to establish performance action thresholds, pollution limits and contingency plans for the contractor’s performance. Impact and compliance monitoring activities will focus on compliance with license conditions, recording implementation of mitigation measures, recording environmental parameters, reviewing contractor environmental performance and proposing remedial actions to address unexpected impacts and complaints. 161.The IEE, including the EMP, should be used as a basis for an environmental compliance program and be included in the contract documentation. The EMP shall be reviewed at the detailed design stage. In addition, any conditions that are part of the environmental clearance from the SEPA should also be as a basis for the environmental

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compliance program. Therefore, continued monitoring of the implementation of mitigation measures, the implementation of the environmental conditions for work and environmental clearance, and monitoring of the environmental impact related to the operation of the treatment plants and pipelines subprojects should be properly carried out and reported monthly to track and determine the net environmental benefits that have accrued. These should be summarized by CDGK in regular quarterly progress reports to ADB also summarized at least twice per year as part of the ADB project performance report. The negative environmental impacts from treatment plants and pipelines will mostly take place during the construction. There are no operational impacts to be addressed in the detailed designs. If the projects are managed in line with internationally accepted environmental auditing procedures very significant environmental benefits can be expected to be demonstrated in the operational stage. 162.The implementation of the environmental mitigation measures during the construction period will be assigned to the contractors. However, experience suggests that contractors may have little impetus or interest to deal with environmental problems in the absence of performance linked criteria. Therefore, the required environmental mitigation must be clearly described in the contract documents at the bidding stage and the completion of mitigation should be linked to payment milestones.

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VIII.CONCLUSIONS 163.Environmental impacts associated with the construction and operation of the treatment plants and pipelines need to be effectively mitigated and institutional arrangements are available. Additional human and financial resources will be required by CDGK to complete the detailed designs and incorporate the recommendations effectively and efficiently in the contract documents, linked to payment milestones. The proposed mitigation and management plans are practicable but require additional resources. 164.Monitoring activities in the design and construction phase will need to focus on compliance with IEE and EIA requirements, license conditions, recording implementation of mitigation measures, recording environmental parameters, reviewing contractor environmental performance and proposing remedial actions to address unexpected impacts. Monitoring activities in the operational phase will need to focus on full implementation of the recommended monitoring requirements in the EMP to ensure good system performance, delivery of water of the expected quality and control of pollution due to waste from treatment plants. The operational controls must ensure efficient measurement of water quality parameters and recording of water, waste and wastewater to allow and ensure feedback of results to management to propose remedial actions to address unexpected problems and amend monitoring as necessary. 165.The water sector subprojects in Karachi are sustainable environmental options but thorough implementation of the EMP, that includes operational monitoring, is required throughout the construction and operation of the treatment plants and pipelines in order to deliver quality water efficiently, minimize impacts and retain public support for the project.

.

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Appendix A:Selected Photographs

Pipri-Malir Pipeline existing RoW

Pipri-Malir Pipeline existing RoW – Malir River Crossing

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Pipri-Landhi Pipeline RoW along National Highway

Pipri-Landhi Pipeline RoW along the Final Stretch

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Appendix B:Environmental Management Plan

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B.1.1

Water Treatment Plant and Water Distribution Mains - Environmental Management Plan – Matrix

Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

DESIGN STAGE 1. Project disclosure

Ensure statutory compliance with PEPA 1997

Disclose WTP & WDM project and design to the SEPA Commencement All WTP and WDM Design and clarify what documents are required to be filed (if of detailed consultant / any) with the provincial and federal EPA to ensure design CDGK compliance with Secion 12(1) of the PEPA 1997 (as amended).

CDGK ADB

2. Buffer distance

Ensure sufficient buffer distance to sensitive receivers to prevent nuisance and achieve safety criteria.

Detailed designs to assess and include appropriate layout to allow setback of noisy and hazardous installations (e.g. chlorine storage) from SRs to prevent nuisances.

Completion of All WTP & WDM detailed design. facilities

Design consultant / CDGK

CDGK – ADB

Review IEE and EMP and confirm findings and recommendations.

Completion of All WTP & WDL detailed design. facilities

Design consultant / CDGK

CDGK – ADB

Completion of All WTP & WDM detailed design. facilities

Design consultant / CDGK

CDGK – ADB

3. Subproject Ensure EMP detailed design. sufficient to control impacts and compliance with statutory requirements PEPA 1997.

Submit REA, revised IEE/EIA and EMP to ADB. Complete the environmental assessment process in line with SEPA and ADB Guidelines. Obtain waiver for IEE from SEPA OR “No Objection Certificate” from SEPA. Prepare EMP and Obtain “Clearance Certificate” from SEPA.

4. Asbestos management

Confirm provisions in asbestos management framework are

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

ACP condition survey - trial pits to assess condition and extent of ACM pipes to be removed. Review AMF and EMP with CDGK and confirm findings and recommendations.

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

DDC = Detailed Design Consultant ACP=Asbestos Cement Pipe Page 62 of 101

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Environmental Concern

5. Waste Disposal

6. Minimize impacts due to Water Distribution Mains alignment designs.

Objectives

Timing to Implement (MM)

Locations to Implement (MM)

met sufficient to control asbestos waste removal and disposal and comply with ADB ERP guidelines.

Submit revised AMF and EMP to ADB.

Ensure rapid removal of ACP and adjacent contaminated spoil and other wastes and sufficient disposal space for all wastes and prevent flytipping.

1. Operational waste management of sludge from 1. Detailed clarifiers and filter wash water to be planned for by the design output. detailed designers and agreed with CDGK.

All WTP & WDM facilities

To ensure that provisions are made to preserve the operation of any existing local infrastructure and that utilities are protected.

Detailed Design Consultants include in detailed design Before the commencement of 1. Footbridges and overpasses to be included in construction. mobilization/preparation works to avoid severance of Installations and pedestrian access. activities included during 2. Existing drainage and other utilities identified and design stage. avoided /re-provisioned.

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

Mitigation Measures (MM) Recommended

Resp Implement (MM)

Resp Monitor (MM)

Confirm AMF included in tender documents and that bidding contractors have capacity to comply with AMF and other safety requirements.

2. Design consultants to identify sufficient stockpiling or disposal locations for excavated materials cut surface materials and include disposal locations and requirements in contracts.

Design consultant / CDGK

CDGK

1. All WTP & WDM CDGK with facilities close to the Design mosques, schools Consultant and other SRs to be avoided.

CDGK

2. Within one month of award of contract or earlier.

2. Before works commence selected contractor to prepare Waste Management Plan with disposal sites identified for agreement by construction supervision consultants and CDGK.

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

2. Locations of overpasses and utilities to be included in plans..

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Environmental Concern 7. Retain trees and landscape designs

Objectives

Mitigation Measures (MM) Recommended

To avoid negative 1. Detailed design to avoid tree removal unless impacts due to justified on engineering, safety and environmental unnecessary grounds. removing of trees 2. If trees have to be removed identify of off-site landscape opportunity spaces in liaison with local community for planting with trees and shrubs and spaces for compensatory planting to be included in detailed designs.

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

1. Detailed design output.

All WTP & WDM facilities

Design consultant / CDGK.

CDGK

Noise sensitive locations to be reconfirmed and checked in the EMP that is 2. Include in the approved by contract. ADB/SEPA.

CDGK with the design consult-ant.

CDGK

During detailed

Design

CDGK/AD

4. Include tree protection and mitigation requirements in tender and contract documentation as milestone payments. 5. Landscaping with trees and shrubs shall take place at Water Treatment Plants. Planting of trees/shrubs/ornamental plants as enhancement. 8. Noise control Ensure noise impacts are acceptable in operational phase.

1. Detailed design stage, with the benefit of known plant specifications, make acoustical assessments to determine if noise mitigation at source (noise barriers) is required to prevent nuisance to sensitive receivers. 2. For schools, hospitals and temples make detailed assessment of noise climate and conduct detailed acoustic assessment for all residential, school, temple (other sensitive structures) within 100m of WTP.

1. During designing stage no later than pre-qualification.

3. if predicted noise at sensitive receiver exceeds agreed criterion [e.g. 3dB(A) above baseline or leq67dB(A) if who criterion acceptable] design and include construction of acoustic measures to control noise at source, e.g. solid barrier to attenuate noise to below agreed criterion at SR. 9. Water quality, To design to CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

Detailed design engineers to prepare a competent

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

Locations to be

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

monitoring and minimize leaks Chlorine usage. and monitor chlorine leakage/check chlorine usage at the treatment plants in the operational phase.

operations and maintenance plan and monitoring plan design. identified and listed consultants/ of relevant water quality parameters to address in revised WQO&M CDGK problems of delivery of contaminated water (Water Plan. Quality O & M Plan). Determination of critical sites and Review strategy and policy on chlorination, methods of disinfection methods, continuity of supply, monitoring monitoring. raw water quality and delivered water quality.

10.Traffic Condition

1. Avoiding blocking existing roads access near WDM During detailed routes. design

Plan to minimize disturbance of vehicular traffic and pedestrians during construction.

Resp Monitor (MM) B

Design chlorination system to minimize leaks in the operational phase and during maintenance.

2. Design provisional temporary traffic management plan for updating by the construction contractors one month prior to start of works in any given sector. 3. Formulate a construction related traffic management plan that takes into account other Tranche 1 subprojects such as the Urban Traffic Control System and Transport Master Plan.

The most important locations to be identified and listed in revised EMP. Relevant plans and possible hot-spots to be made available to the Contractor with tenders.

Detailed design engineer / CDGK.

CDGK

4. Proximity of schools and hospitals to be considered. 5. Installation of traffic warning signs, and enforcing traffic regulations during transportation of materials and equipment and machinery. 7. Include plans for conducting awareness programs on safety and proper traffic behavior near construction sites. 8. Plan requirements to assign dedicated traffic control personnel. CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

9. The EMP review must take into account any changes to operational modeling assumptions that will need to be reviewed relative to ground realities or other changes that result from the assumptions made in other Tranche 1 subprojects such as the development of the Urban Traffic Control System and preparation of the comprehensive long term Transport Master Plan. I.e. the potential cascade of effects upon traffic conditions at the street level resulting from the proposals for the of Urban Traffic Control System and Transport Master Plan must be integrated into the WDM proposals at the detailed design stage. There is insufficient data to make these assumptions at the present stage. 11. Environmentally responsible procurement

Avoid operational environmental pollution and impacts upon decommissioning .

Contractor to submit Method Statement and schedule At tender stage of environmental mitigation measures with tender. and again during product Contractor required to include techniques and acquisition, prior machinery selection to minimize impacts and duration to purchase. of works. Choose non polluting equipment. Specify equipment not to contain POP, asbestos, other hazardous or toxic components.

CSC/Tender evaluators to check contractors Method Statements and proposed mitigation measures and timing.

CSC/Tender evaluators

CDGK

Equipment specifications and performance with company certificates / accreditations.

CONSTRUCTION STAGE CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

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Environmental Concern 1. Plans to control environmental and associated impacts.

Objectives

Avoid impacts from unplanned activities

Mitigation Measures (MM) Recommended

1. Temporary traffic management plan, 2. Drainage and utilities re-provisioning plan, 3. Noise and dust control plan, 4. Waste management plan,

Timing to Implement (MM) Prior to construction activity Submission to ADB

Locations to Implement (MM) To cover construction of all WTP & WDM facilities.

Resp Implement (MM)

Resp Monitor (MM)

Contractor.

CDGK.

All WTP & WDM Contractor facilities and where and CSC. more trees can be replanted for enhancements.

CDGK/

5. Tree removal and compensatory planting plan. 6. Written agreement to follow Asbestos Management Framework. should all be deliverable in final form by the contractors one month before construction commences. 2. Loss of trees and vegetation cover of the areas workareas and aesthetics

To avoid several negative impacts due to unnecessary removing of trees and other street foliage.

PAYMENTS LINKED TO TREE REESTABLISHMENT One month prior NOT TREE REMOVALto and during construction of 1. Removal of trees>10cm DBH (diameter at breast relevant height) to be justified on engineering and safety activities. grounds in tree removal plan.

CSC

2. Clearing of trees for construction, cutting trees and other important vegetation during construction should be minimized. 3. Trees that are unavoidably to be removed for construction shall have compensatory planting and replacement and establishment plans for trees that shall be approved by the CSC and agreed with Contractor one month before existing trees are cut. 4. Payments for site clearance shall be withheld until compensatory tree planting is complete for that sector and payment therefore linked to tree reestablishment not removal as one of the milestone payments.

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

Induction for all site agents and above including all CSC staff new staff before commencement of work.

All site agent staff. monthly induction and six month refresher course as necessary until contractors comply/improve.

Contractor management with the CSC and record details and report quarterly.

CDGK & to observe and record success.

5. At lease seven (7) new trees shall replace each cut tree and maintained alive for three years as part of the contractual agreement and milestone payments. 6. Landscaping with trees and shrubs shall take place at all WTP stations and boundaries as an enhancement. Planting of trees/shrubs/ornamental plants to contribute to the aesthetic value of the area. 7. At conclusion of the project, all debris and waste shall be removed. All temporary structures, including office buildings, shelters and portable toilets shall be removed. 3. Orientation for Contractor, and Workers

Ensure that the CSC Contractor and workers understand and have the capacity to ensure that the environmental requirements and mitigation measures must be implemented by them.

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

Contractors tenders shall be required to separate clearly the resources and funds to be applied to the mitigation measures for environmental impacts Contractors tenders shall identify named staff to supervise and plan, Drainage and utilities re-provisioning Temporary traffic management,

Weekly tool box talks and Waste management, refreshers at early stages of Tree removal and compensatory planting construction for Compliance with asbestos management framework. all construction employees as Contractual clauses shall be included to tie the implementation of environmental mitigation measures far as reasonably in the above plans to milestone payments. practicable. Contractual clauses shall require Contractors to Include with Noise and dust control,

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

conduct special induction briefing and/or on-site safety talks. training for the contractors management, contractors staff, subcontractors and workers to cover the environmental requirement of the project. Contractors shall record and report regularly on record attendance and achievement test for all staff and managers. Contractual clauses shall be included to require contractors to employ dedicated environmental management staff to conduct/oversee the environmental orientation sessions and the implementation of environmental mitigation measures so as to facilitate checking for milestone payments. Contractual clauses shall emphasize that financial compensation shall not be allowed as mitigation for environmental impacts or environmental nuisance without written and environmentally justifiable agreement from the relevant environmental authorities. Engineering controls shall be proposed in the first place by the construction contractors and shall be designed as mitigation measures to control the impacts at source in the first place. The CSC shall be responsible to approve the measures and report the update of EMP.

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

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Environmental Concern 4. Institutional strengthening and capacity building

5. Air quality

Objectives

Mitigation Measures (MM) Recommended

To ensure that CDGK and PMU officials are trained to understand and to appreciate EMP

Capacity building activities

To minimize air impacts effectively and avoid complaints due to the airborne particulate matter released to the atmosphere.

Contol all dusty materials at source.

Consolidation of the DOE or Setting up of an Executive District Officer (EDO), Environment Office within CDGK

Timing to Implement (MM) Initiate preconstruction and continue beyond project completion

Locations to Implement (MM)

Resp Implement (MM)

All senior staff in CDGK CDGK at senior engineer and above in PMU and related units

Resp Monitor (MM) ADB

Development of a strengthening plan for the EDO Before works All WTP & WDM commence and facilities 1. If any area of the WDM replacement works are throughout all within 10m of any sensitive receivers, or have given construction rise to complaints over dust, the contractor shall install works segregation between the works at the edge of the excavation trench nearest the SRs before works commence to provide a barrier to protect the sensitive receivers and passing traffic. The segregation should be easily erectable 3 m high tarpaulin hoarding within which all construction works can take place. The hoarding can be moved on from worksite to worksite along the WDM routes as the work proceeds and removed when the works are completed to trigger a milestone payment.

The Contractor should maintain the accepted standards.

CDGK

CSC should monitor hoardings and wetting and other relevant activities.

The design of the hoardings and works layout must also allow for pedestrians to cross the roads and avoid community severance. 2. All heavy equipment and machinery shall be fitted in full compliance with the national and local regulations. 3. Excavated or stockpiled soil and sand shall be slightly wetted before loading, particularly in windy conditions. CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

DDC = Detailed Design Consultant ACP=Asbestos Cement Pipe Page 70 of 101

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

All WTP & WDM facilities

Contractor should monitor and maintain the accepted standards)

Resp Monitor (MM)

4. Fuel-efficient and well-maintained haulage trucks shall be employed to minimize exhaust emissions. Smoke belching vehicles and equipment shall not be allowed and shall be removed from the project. 5. Vehicles transporting soil, sand and other construction materials shall be covered. Speeds of such vehicles shall be limited to 10km/h within the works site and on unpaved areas. 6. Transporting materials through densely populated areas should be avoided. 7. Open areas of the sites and nearby roads (50m adjacent either side of the active works areas) shall be sprayed at least twice per day with water to suppress dust. 6. Noise/Ground To minimize Vibration noise level increases and ground vibrations during construction operations.

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

Install, maintain and monitor all requisite mitigation as Maximum per contract allowable noise levels at the 1. Outside schools or hospitals construction timetable façade of the shall be discussed with the occupiers and work should sensitive be avoided at sensitive times. As fall back option to receiver are control noise, mass of hoardings can be increased using heavy thick ply-board or corrugated metal sheet 1. 70dB(A)LEQ to achieve a mass of >10kg/m2. Design and works or layout must allow pedestrians to cross roads or pass around or over sites and avoid community severance. 2. 3dB(A)LEQ The installation of such measures should be above the discussed with the local population and serve as a background means for further public consultation during (measured no implementation and assist in public relations. more than 2 weeks before 2. All heavy equipment and machinery shall be well the CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

Within 50m of all hospitals schools and colleges

CDGK/ CSC

CSC should monitor relevant activities.

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

maintained and fitted in full compliance with the national and local regulations.

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

commencement of work).

3. As a rule, the operation of heavy equipment shall be conducted in daylight hours unless agree otherwise with local residents. 4. Construction equipment, which generates excessive noise, such as compressors, jack-hammers shall be enclosed to prevent noise release. Wellmaintained haulage trucks will be used. The contractor shall also maintain and service all equipment to minimize noise levels. 5. Performance criteria during nighttime (10 pm to 7 am) shall be the measured impact noise at the residential or hospital sensitive receiver shall not be more than 3dB above background noise levels measured at the nearest sensitive receiver (Leq15minutes) two weeks prior to the commencement of works. The contractor shall also maintain and service all equipment to minimize noise levels. 7. Near Mosques and schools the contractor shall discuss with the CSC and the school and mosque principals the agreed time for operating the noisy machines and completely avoid machine use near schools during examination times and near mosques during religiously sensitive times. 8. Large concrete building components shall be prefabricated near the concrete batching plants or in controlled dedicated areas away from SRs to minimize impacts. CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

9. Contractor shall be allowed to take other acoustic measures to minimize noise nuisance in the vicinity of construction sites if the necessary noise attenuation to keep within the noise criteria can be achieved. 10. Contractor may obtain guidelines for noise reduction from ISO/TR11688-1:1995(e), which enumerates methods by which air-borne, ground– borne and structure-borne noise sources may be curtailed with suitable design criteria.

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

DDC = Detailed Design Consultant ACP=Asbestos Cement Pipe Page 73 of 101

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Environmental Concern

7. Removal of Asbestos Cement Pipes (ACP)

Objectives

1. To adopt ERP in line with ADB requirements.

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Asbestos cement pipes shall be carefully excavated, lifted on to plastic sheets, wrapped in polythene and sealed with duct tape to be transported to the designated storage area or landfill.

Locations to Implement (MM)

Update once a 1. The location of month and buffer temporary report quarterly. store or permanent disposal areas to 2. To control the be identified by release of The procedure shall follow the measures indicated detailed design harmful asbestos below: engineer to be fibres. prepared at the Preparation contract stage for 3. To control 1) The CONTRACTOR shall implement all the proagreement. disposal of ACP, cedures in Appendix 2 of the AMF and make availa hazardous able all the materials in Appendix 3 of the AMF. waste. 2. The records of 2) The CONTRACTOR shall agree to remove and asbestos transport all the wrapped asbestos (ACP) from the abatement sites to secure temporary buffer store(s) desigactivities and audit nated by DOE - CDGK to await disposal. of waste disposal 3) The CONTRACTOR shall provide approved proquantities to be tective clothing to all workers and DOE – CDGK reconfirmed and inspector as and when requested. that disposal area is available as 4) Workers handling the asbestos cement pipes shall identified by wear the personal protective clothing provided. detailed design 5) The DOE - CDGK Asbestos Specialist inspector engineer. shall visually inspect the preparation before instructing the Contractor to proceed.

Resp Implement (MM)

Resp Monitor (MM)

2.CDGK DOE CDGK/ and CSC CSC should supervise and take action to ensuure completion of Contractor’s relevant activities according to environmental standards.

6) The DOE - CDGK Asbestos Specialist inspector shall monitor the works and carry out a visual inspection to certify that all the ACP have been removed to a satisfactory standard in line with Appendix 2 of the AMF. CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

7) The DOE - CDGK Asbestos Specialist inspector will check and record the number of packs of

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

DDC = Detailed Design Consultant ACP=Asbestos Cement Pipe Page 74 of 101

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

8. Construction Waste Disposal

To minimize the impacts from the disposal of construction waste.

Waste Management Plan to be submitted to the CSC and approved one month prior to starting works. 1. Estimating the amounts and types of construction waste to be generated by the project. 2. Investigating whether the waste can be reused in the project or by other interested parties. 3. Identifying potential safe disposal sites close to the project OR those disposal sites designated in the contract.

Timing to Implement (MM)

Locations to Implement (MM)

Update once a 1. A list of month and temporary report quarterly. dumping areas identified by detailed design engineer to be prepared at the contract stage for agreement.

4. Investigating the environmental conditions of the disposal sites and recommendation of most suitable and safest sites. 5. Redundant asbestos cement and other redundant pipes and contaminated soil shall not be left in the soil or stockpiled on site but to be removed efficiently in line with the provisions of the Asbestos Management Framework.

Resp Implement (MM) 1.Contractor

Resp Monitor (MM) CDGK/ CSC

2.CSC should supervise and take action to ensure completion of Contractor’s relevant activities 2. The list of waste according to sites to be environmental reconfirmed and standards. that dumping areas is available as identified by detailed design engineer.

6. Piling up of inert loose soil based material should be done in segregated/protected areas to arrest washing out of soil. Debris shall not be left where it may be carried by water to down stream drains, flood plains, lagoons etc. 7. Used oil and lubricants shall be recovered and reused or removed from the site in full compliance with the national and local regulations. Oily waste must not be burned. LICENSED DISPOSAL LOCATION TO BE AGREED WITH CDGK/SEPA 8. Machinery should be properly maintained to CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

minimize oil spill during the construction. 9. Solid waste should be disposed at an approved solid waste facility. 10. Waste shall not be burned - under any circumstances. OPEN BURNING IS CONTRARY TO GOOD ENVIRONMEMTAL PRACTICE and ADB guidelines on ERP. 9. Worker canteen and toilet facilities

To ensure that the operation of the works and worker facilities does not adversely affect the surrounding environment and residents in the area.

1. Identify location of worker canteen and toilet UPDATE Once facilities in consultation with local communities. a month Location subject to approval by the CDGK. If possible, canteen and toilet facilities shall include drinking water supplies.

Location Map is prepared by the Contractor.

Contractor

CDGK/ CSC

2. In order to maintain proper sanitation around construction routes, temporary toilets will need to be provided. Waste shall not be buried (see above) 3. Drinking water and sanitary facilities shall be provided for employees. 4. Solid waste and sewage shall be managed according to the national and local regulations. 5. The Contractor shall organize and maintain a waste separation, collection and transport system. 6. The Contractor shall document that all liquid and solid hazardous and non-hazardous waste are separated, collected and disposed of according to the given requirements and regulations. 7. At the conclusion of the project in a particular

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

DDC = Detailed Design Consultant ACP=Asbestos Cement Pipe Page 76 of 101

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

sector, all debris and waste shall be removed. All temporary structures, including office buildings, shelters, waste receptacles and toilets shall be removed. 8. Exposed areas shall be replanted with suitable vegetation in line with the landscape plans and be inspected by CDGK and CSC shall inspect and report that the site has been vacated and restored to preproject conditions or as agreed with CDGK. 10. Safety To ensure safety Precautions for of workers the Workers and first aid.

1. Providing adequate warning signs. 2. Providing workers with skull guard or hard hat and protective boots.

During construction

Relevant canteen Contractor and worker and CSC sanitation facilities.

CDGK/ CSC

3. Contractor shall instruct his workers in health and safety matters, weekly, and require the workers to use the provided safety equipment. 4. Establish all relevant safety measures as required by law and good engineering practices. 5. Contractor shall provide first aid facilities for the workers on the WTP and WDM and at the worker canteens with at least one qualified first-aider or nurse present at all times. It is recommended that the workforce be given access to a trained doctor at least once per two weeks for routine checks and medical examinations if necessary. 11. Traffic Condition

Minimize disturbance of vehicular traffic & pedestrians during haulage of

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

Submit temporary traffic management plan one month Day time prior to start of works in any given sector. Formulation and implementation of a construction related traffic management plan and assign traffic CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

The most Contractor CDGK/ important locations and Engineer CSC to be identified and listed. Relevant plans of the DDC = Detailed Design Consultant ACP=Asbestos Cement Pipe Page 77 of 101

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Environmental Concern

Objectives

materials, spoil, equipment & machinery. No blocking access near construction sites.

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

control personnel. The Temporary Transport Management Plan will include consideration of the following.

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

Contractor on traffic arrangements are available.

Lane availability and minimise traffic flows past the works site. Establish acceptable working hours and constraints. Agree the time scale for the works and establish traffic flow/delay requirements. Programming issues including the time of year and available resources. Acceptability of diversion routes where necessary. Need for road closures and the necessary Orders. Co-ordination with other planned road and street works. Discuss the CDGK inspection/monitoring role. Discuss establishment of incident management system for duration of the works Agree publicity/public consultation requirements (advance signing etc.). The plan will be reviewed by CDGK and approved, if found appropriate. Resources from contractor, CDGK, and the traffic police will be provided as per the plan before construction commences. The Vicinity of schools and hospitals to be considered.

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

DDC = Detailed Design Consultant ACP=Asbestos Cement Pipe Page 78 of 101

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

Installation of traffic warning signs. Conducting awareness programs on safety and proper traffic behavior in densely populated areas near the construction sites. 12. Nuisance to nearby properties

Control nuisances and reduce impacts on property value or interruption to neighbouring land uses.

Contractor to agree to monitor and enforcement of implementation of mitigation measures versus milestone payments for mitigation.

At all times

Contract clauses to specify acceptable construction practices to mitigate nuisances, noise, vibration and dust impacts and liaison with local community on approach to mitigation. No payment unless environmental mitigation measures are implemented and penalty clauses in contract.

All WTP & WDM facilities with special focus on areas within 50m of all residences, hospitals schools, colleges and places of worship.

CSC To CSC / monitor, CDGK enforce implementatio n of contract clauses versus milestone payments. Complaints response time rerecorded.

Incorporating good construction management practices – complaints reported once per month for each site/km of water main under construction.

Contractor to respond and resolve complaints.

Compensation will be paid for loss of livelihood due to construction disruption in line with ADB guidelines. Set up complaints hot line, recording, response and resolution monitoring. OPERATIONAL STAGE 1. Monitor clorine usage/leakage checking.

To reduce chlorine leakage/check chlorine usage at the treatment plants and

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

Regular inspection of all chorine dosing equipment and storage facilities.

Throughtout operations

Monitor for chlorine leaks all chorine dosing equipment and storage facilities CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

Weekly checks at CDGK all water treatment locations.

CDGK

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement (MM)

Locations to Implement (MM)

Resp Implement (MM)

Resp Monitor (MM)

dosage equipment. 2. Raw Water quality

Ensure knowledge on water quality to determine effectiveness of water treatment.

Establishing guidelines and standards and regulations Throughtout for raw water quality. operations

Weekly during operation

CDGK

CDGK

Weekly at least CDGK three locations for each WTP & WDL facility.

CDGK

Implement a competent operations and maintenance plan and monitoring plan of recommended water quality parameters to address problems of delivery of contaminated water (Water Quality O & M Plan). Implement agreed strategy and policy on chlorination, disinfection methods, continuity of supply, monitoring raw water quality and delivered water quality.

3. Residual chlorine in water delivered water Clorine usage monitoring

To monitor Monitor chlorine at dosing point (>100mg/l). chlorine leakage / Measure pH at dosing point (<8.0) check chlorine usage at the Ensure contact time of 30mins to chlorine. treatment plants Monitor chlorine at selected delivery points.

Throughtout operations

Measure pH at selected delivery points. Consider to maintain residual chlorine in distribution mains at 0.2 to 0.3mg/l as a sentinel against pollution entering the mains and to prevent growth of nuisance bacteria.

CDGK = City District Government Karachi PMU = Project Management Unit or Similar 29/03/08

CSC=construction supervision consultant WTP & WDM = Water Treatment Plant & Water Distribution Main

DDC = Detailed Design Consultant ACP=Asbestos Cement Pipe Page 80 of 101

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Appendix C:Asbestos Management Framework This Asbestos Management Framework (AMF) was prepared for all the subprojects that will arise in all tranches of the proposed Karachi Mega City Sustainable Development Program (KMCSDP or the ‘Program’) as required by ADB. The Asbestos Management Framework focuses specifically on environmental liabilities with respect to asbestos. Nothing in this AMF shall be construed to modifying or release the Implementing Agency (IA) CDGK from any other obligations for environmental assessment of subprojects as required under the EARF with regards to the policy, procedures and institutional requirements for preparing subsequent sub-projects under the MFF loan. The executing agency (EA) will be the Department of Finance of the Government of Sindh (GoS) and the implementing agency (IA) will be the City District Government of Karachi (CDGK). A

Development Activities requiring Asbestos Management

166.Government of Pakistan (GoP) has requested the Asian Development Bank (ADB) to provide a multi-tranche financing facility (MFF) to facilitate investments to support the proposed Karachi Mega City Sustainable Development Program (KMCSDP or the ‘Program’). Water supply and sewer subprojects are included under the KMCSDP MFF (Table 1). These subprojects will include replacement of water distribution mains (WDM) and sewer pipes. Asbestos cement pipes (ACP) are known to have been used to construct the existing WDM and may also have been used to construct the sewers. The objective of this AMF is to reduce the risk of exposure of workers that have to handle asbestos, reduce the environmental liabilities associated with asbestos and also build capacity in CDGK to manage asbestos related issues. 167.During the course of conducting environmental assessment for the subprojects in Tranche 1 of the KMCSDP MFF it has been discovered that more than half of the WDM was constructed from asbestos cement pipes (ACP). The extent of asbestos cement pipes in the existing sewers is not known. The extent to which the ACP have been replaced is unknown. ADB Environmental Assessment Guidelines 2003 recommend environmental responsible procurement (ERP) which that is a fundamental principle for robust environmental management of subprojects. Asbestos is on the ADB Prohibited List in the Environmentally Responsible Procurement guidelines (2007)20. 168.Asbestos is recognized internationally as a hazardous material because it can present a risk to human health. In many jurisdictions asbestos is classified as hazardous and is a controlled chemical waste or a hazardous waste because if it is mishandled it can release airborne fibers that are known to cause asbestosis and have also associated with other lung diseases and cancer. All forms of the asbestos mineral will release asbestos fibers if broken up and all types of ACM will release asbestos fibers to some degree if damaged or abraded. 169.Asbestos has been widely used in numerous types of materials, usually because of its good qualities as a thermal insulation material. Asbestos has also been used extensively in numerous types of cement materials, pipe insulation plaster and in refractory brick work. Asbestos is often used because of its good qualities as a thermal insulation material but it is also useful as a binder to form complicated cement shapes and durable pipes. The amounts of asbestos used vary from product to product but certain types of asbestos cement can contain more than 50% asbestos. When bound in 20 Environmentally Responsible Procurement – A guide to better practice ADB (2007)

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the cement matrix of a pipe the asbestos is generally considered safe. However over time the cement surface of a pipe can become corroded or abraded leading to the release of asbestos fibers. The surface of the asbestos cement pipe (ACP) can gradually become more friable and release asbestos fibers. With a buried or submerged pipe the chemical conditions in the surrounding soil or water will also affect the rate of deterioration of the pipes as they gradually wear out or become more fragile. The removal and replacement of pipes will also give rise to some release of fibre as it is almost impossible to remove more fragile old ACP without breaking them. Therefore in addition to giving rise to a controlled waste the removal of the ACP can also easily lead to the release of asbestos fibers if the removal is not conducted under controlled conditions. 170.This AMF has been prepared because the ACP will most likely be disturbed in the process of implementing the Water Distribution Mains (WDM) and Sewer subprojects. Given the concerns over the extensive leaking and dilapidated state of WDM and sewers it is likely that a significant part of the ACP are broken or cracked underground and will have to be replaced. 171.Asbestos containing materials (ACM) may also be present in other CDGK infrastructure and asbestos waste will arise when ACP are replaced. Therefore a management framework is required to deal redundant asbestos containing materials (ACM) that will result from the decommissioning of infrastructure in preparation for the implementation of other component subprojects in Tranche 1 and all future tranches of the KMCSDP MFF. This AMF shall apply to all subprojects under the MFF so as to ensure that the environmental liabilities associated with asbestos are appropriately addressed and managed to reduce the known risks to human health to acceptable levels. 172.Under the MFF loan procedures of ADB, implementation of safeguards is to be achieved by environmental assessment of every subproject to be undertaken following ADB Environment Policy (2002). Therefore the AMF applies to all aspects of the constituent subprojects, in the KMCSDP-MFF under ADB Environmental Assessment Guidelines (2003) that must be followed for all subprojects. ADB policy and recommendations on environmentally responsible procurement1 will prevent further asbestos materials being used in the KMCSDP MFF subprojects as prescribed in the EMPs that are included in the IEEs prepared for all subprojects in Tranche 1. Free limits will not be applied with respect to this AMF. 173.Project implementation will be managed by a Project Implementation Unit (PIU) within CDGK in coordination with the relevant sector departments of CDGK. It is recommended that the implementation of the AMF should be managed by one dedicated officer (Asbestos Specialist) and that officer could be in the DOE in coordination with the relevant sector departments of CDGK, since the asbestos issues will apply more widely across all CDGK activities and infrastructure, The Asbestos Specialist could also be located in the Project Implementation Unit (PIU) within CDGK. If there is no suitably qualified person available, the DOE could be delegate the asbestos work to an international asbestos specialist and then the DOE staff can shadow the international consultant for say six months to gain experience and expertise as the MFF is rolled out. The Program Reform Monitoring Unit (PRMU) within the Department of Finance of GoS would also be expected to monitor the asbestos issues, adherence to the AMF along with monitoring the overall Program and other safeguard issues that arise on specific subprojects. 174.The Asbestos Specialist (whether located in the PIU or DOE) or consultant in CDGK will be responsible ensuring that the AMF is implemented, that asbestos issues have been considered early in the implementation at the detailed design stage and by using

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the asbestos checklist so that necessary asbestos assessments are prepared (to support preparation of EMPs for subprojects).

Table 1: Proposed MFF Subprojects Subsector

Subproject

Asbestos Issue

ADB Category

PRMU

AMF–A

C

PIU

AMF–A

C

Studies

AMF–A

C

Capacity Development and Training

AMF–A

C

Public Awareness and Outreach

AMF–A

C

N/A

C

Water Filtration Plants at COD and NEK total 100 MGD capacity

AMF-D, ERP

B

Water Filtration Plants at COD and NEK total 84 MGD capacity

AMF-D, ERP

B

Water transmission main of 48" and 36" dia. From Pipri Treatment Plant to Korangi Industrial Area and 36" from Pipri Treatment Plant to Malir Town

AMF-D, ERP

B

Water Distribution Network Improvements in priority zone

AMF-D, ERP

B

Sewer from Shaheen Complex to Clifton PS

AMF-D, ERP

B

Bus Rapid Transit along Route 1: Surjani to Karachi CBD; and Route 3: Orangi Town Extn.

ERP

A/B

Bus Rapid Transit along Route 2: University Road to Karachi CBD (Phase 2)

ERP

B

Urban Traffic Control System – Phase 1

N/A

C

Dualization of Link Road between National Highway to Superhighway

N/A

B

AMF-A

C

First Tranche – 2008 to 2011 Part A

Investment Program Management and Support Program Management

Program Support

Monitoring and Evaluation (M&E) Independent M&E Part B

Part C

Water Supply and Wastewater

Urban Transport

Second Tranche – 2009 to 2012 Part A

Subproject Preparation

Part B

Water Distribution Network Improvements in additional zones

AMF-D, ERP

B

Transmission main extensions to Mehmoodabad; from Surjani to 5C Chowrangi and Nazimabad

AMF-D, ERP

B

24" Main from Hub Reservoir to Baldia Town and Scheme 42 and 48" Main from Board Office to Urdu Cowk

AMF-D, ERP

B

Phase 3 extension of water supply network improvement program

AMF-D, ERP

B

Trunk sewer replacements and extensions based on JICA-supported sewerage Masterplan

AMF-D, ERP

B

Bus Rapid Transit (Routes 4,5,6)

ERP

A/B

Urban Traffic Control System – Phase 2

N/A

C

Key link Road Malir Expressway Phase 1

N/A

B

Part C

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Subsector

Subproject

Asbestos Issue

ADB Category

Part D

Pilot low-income housing plot formation and associated studies and assistance

ERP

C

Further water transmission and distribution network extensions based on outcome of water balance and equitable distribution study

AMF-D, ERP

B

Trunk sewer replacements and extensions based on findings of JICAsupported sewerage Masterplan

AMF-D, ERP

B

Scaled up social housing fund for low-income plot formation and assistance

ERP

C

Further water transmission and distribution network extensions based on outcome of water balance and equitable distribution study

AMF-D, ERP

B

Trunk sewer replacements & extensions based on JICA-supported sewerage Masterplan

AMF-D, ERP

B

Bus Rapid Transit (Routes 7,8,9,10,11)

ERP

A/B

Key link roads

N/A

B

Third Tranche – 2010 to 2013 Part B

Part D

Fourth Tranche – 2011 to 2015 Part B

Part C

N/A = not applicable = no foreseeable asbestos issues. ERP = Guidance on Environmentally Responsible Procurement – A reference guide for better practices 2007 that recommends no ACM to be used in new infrastructure. AMF-D = AMF will require waste ACP to be disposed. AMF A = AMF will raise awareness and included in hazardous waste strategy.

175.The procedures to be adopted are outlined in this framework by reference to known asbestos in ACP but this AMF should be applied to all subprojects where any ACM is identified. Asbestos investigations should be prepared for each subproject to check if there is any likelihood of ACM being implicated and if ACM is present Asbestos Management Plans should be prepared, disclosed to ADB for review and approval prior to including the AMP in the contracts before commencement of work. The PIU within the DOF of GoS shall monitor the progress of the environmental work stream in general and the EMP that will include asbestos issues to ensure that the AMF is implemented and that where relevant all asbestos assessments are submitted to ADB prior to the PFR for all Tranches. 176.Each subproject will undergo a preliminary review of asbestos issues to identify any known uses of asbestos containing materials or asbestos containing products that have been procured. In the case of the WDM and Sewer subprojects either all the cement pipes can be assumed to be ACP or sampling of the pipes can be undertaken by the Asbestos Specialist early in the detailed design phase, The ACP samples shall be referred to the relevant laboratory for analysis (Appendix 3). B

Requirement for Asbestos Management

177.Best practice asbestos management usually entails several stages. Survey and investigation are the first steps in which the asbestos specialist will check all structural elements, fixtures and fittings for fibrous materials that are potentially asbestos. Samples are taken under controlled conditions and an accredited laboratory analyses the samples using polarized light microscopy. The asbestos specialist will then assess the type, location and condition of asbestos and make a hazard assessment. If asbestos needs to be removed an asbestos abatement plan is usually prepared to cover removal with detailed work specifications for specialist contractors. In all cases the asbestos should be labeled and safety procedures instigated to prevent disturbance, until such time as it can be removed safely.

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178.Typical of many developing countries Pakistan uses asbestos for many industrial and commercial purposes. Best professional judgment suggests that at this stage asbestos cement pipes have been typically been used in 50% to 70% of the Karachi water supply pipe system which extends over thousands of kilometers. Significant parts of this system will be replaced by ADB supported projects in the immediate future and in a rolling programme over several years. There may well be other residual asbestos waste entering the solid waste management system. 179.There are as yet no statutory controls on hazardous waste in Pakistan. The Hazardous Substances Rules were drafted in 2003 but were never brought into force. Asbestos waste is listed in the draft Hazardous Substances Rules 2003 (HSR). If enacted the HSR would require an entity licensed under the Pakistan Environmental Protection Act (1997) to have a waste management plan for any listed hazardous substance. This AMF is in line with the spirit of Pakistan’s draft legislation. 180.The solid waste management Roadmap for Karachi Mega City Sustainable Development MFF envisaged as one goal as “an effective regulatory framework for the environmentally safe and healthy management of all municipal and hazardous solid wastes generated in Karachi”. 181.The lack of a functioning HWM system in Karachi is of serious concern, as many of the wastes are presumably being disposed of also through illicit dumping methods throughout the city. This would presumably be the fate of any asbestos waste from the MFF Tranche 1 projects if disposal of ACM is not controlled. 182.Therefore although hazardous waste management (HWM) in Karachi is in its infancy, with no regulatory or legislative framework, and no institutional capacity or funding at the Government level, the need for a HWM system has been recognized. 183.ADB may well be involved in HWM (therefore waste asbestos management) corollary to the implementation of subprojects for Karachi Mega City Sustainable development MFF. It is also noted that another ADB initiative, the RETA on Hazardous Wastes Management, covering Nepal, India, Bangladesh and Bhutan is also underway in 2007). 184.Some previous ADB projects and guidelines have also considered asbestos issues. The recently published Environmentally Responsible Procurement1 lists asbestos fibers on the Prohibited List asbestos fibers are on the prohibited list but asbestos cement sheets with less than 20% asbestos are exempted. Other available information on ADB projects does not reveal that asbestos has been a major consideration to date, however ACM is mentioned in several project reports (Appendix 4). 185.ADB standards are guided by the World Bank Pollution, Prevention and Abatement (PPAH) that requires asbestos disposal should be carried out in line with host country regulations or following best international practice. 186.Therefore as there are as yet no local standards for asbestos control in Pakistan, any known asbestos waste requiring removal should be disposed of following best international practice. 187.In line with best international practice, the requirement for a dedicated Asbestos Management Plan has been included in the IEE / EMP for relevant Trance 1 subprojects for Karachi Mega City MFF. This AMF has been prepared taking into consideration other future developments in Karachi and other ADB experience and lessons.

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C

Responsibilities / Authorities of Various Agencies

188.Potential environmental liabilities with respect to asbestos associated with subprojects will be minimized by implementing the requirements of the AMF and by prescribing the selection of alternative non-asbestos materials (section D and Appendix 2). All measures shall be in line with ADB’s Environment Policy 2002 and ADB Environmental Assessment Guidelines 2003, the GOP’s regulations and guidelines, the Environmental Assessment Review Framework and the Guidance on Environmentally Responsible Procurement1.The subprojects shall only involve asbestos activities that follow the AMF. 189.The CDGK as IA will be solely responsible for the implementation of all of the asbestos assessment and review procedures required in the AMF for all subprojects. This will include, but not be limited to, ensuring that the asbestos control procedures are strictly adhered to, that preparation of AIR and AMP are carried out in a timely and efficient manner and included in the construction contracts. CDGK will submit the asbestos checklist (Table 2) an AIR and an AMP and monitoring reports to ADB for review. 190.Prior to the submission of the PFR for a Trance of subprojects the CDGK (Asbestos Specialist) will: i)

Assist CDGK to identify a suitable secure buffer store for waste asbestos.

ii) Prepare an asbestos investigation report (AIR) and checklist to identify any asbestos issues in any subprojects in each Tranche. iii) Ensure that adequate sampling and analysis of the existing facilities has been carried out to ensure all environmental liabilities with respect to asbestos have been identified, review the asbestos assessments AIR and AAP and submit the AIR and AAP to ADB. iv) Prepare the asbestos surveys and investigations prepare asbestos assessments, AIR and AAP reports including an AMP for inclusion in the construction contracts. 191.Prior to the commencement of civil works for a subprojects in a Tranche the CDGK will: i)

Set up the buffer store facility and ensure that all contractors have been briefed as to the presence of ACM in the subproject works and the nature of the hazards posed by the type of asbestos present.

ii) Ensure that the contracts have specified the asbestos management procedure AMP to be used in the construction of the subproject to control environmental liabilities to acceptable levels. iii) Ensure that the required mitigation measures during construction and the AMF are included in the bidding document of the subproject and that the all bidding contractors have access to the IEEs and EMP. iv) Ensure that CDGK have identified a suitable secure buffer store for the waste ACM in lieu of landfill disposal being available and that the contractors know the location of the buffer store in the bidding documents. v) Ensure the selected contractor has made adequate provisions (including human resources, materials methods and training) to carry out works in line with the AMF as a payment milestone. have access to the IEEs and EMP 192.During the implementation of civil works for a subprojects in a Tranche the CDGK Asbestos specialist will:

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i)

Ensure that the asbestos abatement procedures, including all proposed mitigation measures and monitoring in Appendix 2 are properly implemented.

ii) Monitor the implementation of AMPs and present its monitoring report. iii) Ensure that ADB be given access to undertake environmental due diligence for all subprojects. However, the CDGK shall have the main responsibility for undertaking environmental due diligence and monitoring of all the subprojects. The due diligence report as well as monitoring reports on EMP implementation will be systematically prepared and include asbestos abatement issues.

Table 2: Proposed preliminary checklist for AMF Implementation on MFF Subprojects@ Stage

Task / Progress

1

Employ Asbestos Specialist (registered /qualified asbestos / hazardous waste consultant#

2

Prepare asbestos screening checklist. A preliminary review of asbestos issues by AS. Are ACM / ACP known to have been used in the system?

3

Have potential locations for ACM / ACP been identified, surveyed, sampled and investigated by the Asbestos Specialist / qualified / registered asbestos consultant in line with best practice.

5

Have the potential ACM/ACP bulk samples been analyzed by an accredited laboratory in line with best practice (Appendix 4).

6

Has the Asbestos Specialist / registered asbestos consultant prepared an asbestos investigation report including the survey, sampling locations and confirmed or refuted the presence and types of asbestos in line with best practice

7

Has the Asbestos Specialist prepared an asbestos management plan (AMP) including asbestos abatement plan including results of the asbestos investigation and ACM locations types of asbestos in line with the AMF procedures and best practice

8

Are the requirements for asbestos management plan including asbestos abatement plan included in the contracts.

9

Have CDGK provided the necessary buffer storage space or landfill disposal location for the asbestos.

10

Can the contractors obtain the necessary skills capability and equipment to carry out the asbestos management in lie with the AMF.

11

Can the contractors obtain the necessary skills capability and equipment to carry out the asbestos management in lie with the AMF.

12

If no to any of the above provide remedial action and detail on separate sheets

Yes / no (comment)

Date

# Link to technical assistance for hazardous waste management strategy - Appendix 1 for ToR Asbestos Specialist. @ To be updated at the detailed design stage as necessary.

193.ADB will be responsible for regular review and timely approval of subproject AMF checklists (Table 2). Technical guidance will be provided by ADB to the CDGK as

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needed. ADB will also be responsible for reviewing regular monitoring reports and officially disclosing the any aspects of on the ADB website if required. 194.During the MFF ADB will: i)

Review asbestos AIR and AMP as a basis for subproject and Tranche approvals.

ii) Monitor the AMF and AMP implementation and due diligence as part of MFF reviews. iii) Provide assistance to CDGK, if required, in carrying out its responsibilities and for building capacity for compliance with the AMF. D

Asbestos Control Procedures 1.

Minimizing Asbestos Liabilities

195.Potential environmental liabilities with respect to asbestos associated with subprojects will be minimized by taking the following measures: i)

Implementing the requirements of the AMF and by prescribing the selection of alternative non-asbestos materials.

ii) Where ACM must be disturbed in a subproject the ACM shall only be removed under controlled conditions for disposal in line with the provisions of the AMF or any rules subsequently promulgated by the Federal EPA or Sindh EPA. iii) Construction of the subprojects will not take place until the contractor has agreed to carry out the asbestos abatement procedures in line with the procedures included in the AMF. iv) Conducting sampling of potential asbestos containing materials (ACM) and compiling an asbestos investigation report (AIR) with adequate implementation. v) For low risk ACP prepare an asbestos management plan (AMP, including asbestos abatement plan (AAP) with adequate implementation and monitoring budget will be developed for each subproject based on Appendix 2 to this AMF. vi) For other high risk friable materials if they are identified prepare alternative asbestos abatement plans (AAP) with adequate implementation and monitoring budget will be developed for other subproject based on best international practice. vii) All measures shall be in line with ADB’s Environment Policy 2002 and ADB Environmental Assessment Guidelines 2003, the GOP’s environmental assessment regulations and guidelines, the Environmental Assessment Review Framework and the Guidance on Environmentally Responsible Procurement1. viii) The subprojects shall only involve asbestos activities that follow the AMF. 2.

Preparation of Detailed Design

196.Detailed design work for each additional subproject will include and follow the recommendations of the AMF. The CDGK will include the requirements of the EMP and IEE/EIAs (including the AMF) in the bid documents and ensure the detailed designs include such requirements. Before contracts are finalized certification shall be provided 29/03/08

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to ADB by CDGK that the detailed designs comply with IEE/EIAs (including AMP) recommendations will be required before contracts can be signed and made effective. The CDGK shall also allocate sufficient resources to recruit and support an Asbestos Specialist in the DOE of CDGK to monitor the progress of the asbestos management process for all subprojects under the MFF. 3.

Preparation of Construction Contracts

197.Early in the implementation period, model construction contracts will be prepared incorporating general environmental safeguards and asbestos management practices based on Appendix 2 and Appendix 3 to this AMF. Specific, individual contracts will be based on the model contracts, but will also be checked by the CDGK to ensure that all special or particular safeguard requirements and mitigation measures, recommended in the AMP for the particular additional subproject, are all incorporated within the contract. The CDGK shall also allocate sufficient resources to the Asbestos Specialist to monitor the asbestos abatement mitigation measures specified in the AMP are included in all construction contracts under the MFF. 4

Monitoring During the Construction Period

198.Monitoring during construction will be the responsibility of the CDGK Asbestos Specialist. Monitoring will relate to compliance with construction contracts. The Asbestos Specialist will inspect the ongoing works regularly and systematically; checking that the above-mentioned the asbestos abatement mitigation measures specified in the AMP have been implemented effectively during the design and construction stages of the project (Table 2) and ensure the implementation and effectiveness of mitigation measures. Reporting will be to the CDGK on a regular basis (at least quarterly) and to ADB semi-annually. The asbestos will be removed in the construction stage and therefore no monitoring will be required in the operational stage. E

Institutional Arrangements

199.The IA for the AMF for the MFF will be CDGK. An environment officers (Asbestos Specialist) within the DOE or other suitably qualified consultant shall lead the implementation of the AMF and have those responsibilities for the duration of the MFF loan and shall report directly to the head of the DOE of CDGK, who will be accountable and responsible for implementation of the AMF. The dedicated Asbestos Specialist will coordinate consistently the implementation of the AMF in all subprojects where asbestos has been identified as an issue. 200.The Asbestos Specialist shall also be responsible for coordinating and supervising monitoring of asbestos abatement, quality control, and writing the periodic progress reports on implementation of the AMF. The implementation of the AMF shall commence immediately upon commencement of the detailed designs for the MFF subprojects. The Asbestos Specialist will therefore be designated at least one month before and released for duty before the loan becomes effective. CDGK will further ensure the release of resources for asbestos management and that monitoring budgets are made available for timely AMP implementation. F

Monitoring and Evaluation

201.The AMF will have both internal and external monitoring. The Asbestos Specialist at the local level will be responsible for internal monitoring of the AMF implementation, and will forward quarterly progress reports to CDGK. The reports will contain progress made in AMF implementation with particular attention to compliance with the principles set out

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in the AMF. The CDGK will submit a brief annual monitoring report to ADB at least once per year.

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APPENDIX 1 DRAFT TERMS OF REFERENCE FOR ASBESTOS SPECIALIST This TOR to be modified depending on the management details. 202. Qualifications 203.The Asbestos Specialist shall preferably be a registered asbestos consultant or member of a recognised waste management association in an ADB member country and/or have work experience and familiarity with all aspects of asbestos management and/or have attended a recognised full time training course on all aspects of asbestos management. Candidates with broad experience in the field of asbestos management or hazardous waste management will be preferred. The Asbestos Specialist shall at least be a graduate in environmental science, environmental engineering or a related discipline with significant experience in asbestos management or hazardous waste management and monitoring of projects and implementation of mitigation measures and engineering controls to minimise risks associated with control of asbestos or hazardous wastes in the environment. 204.The general scope of work will be: i)

To plan asbestos investigations and arrange for bulk sampling of potential asbestos containing materials (ACM) and prepare asbestos investigation report for all subprojects to confirm the extent or refute the presence of ACM.

ii) Prior to controlled landfill disposal facilities being available, to assist CDGK to identify a suitable buffer store to stockpile ACM collected up from subprojects and prepare an asbestos management plan (AMP) for the buffer store and future landfill. iii) Monitor the management of stockpiled ACM in the buffer store buffer store and subsequently monitor the management of waste ACM in the controlled landfill disposal facilities. iv) When controlled landfill disposal facilities are available, to assist CDGK to monitor the implementation of necessary controls on asbestos disposal and to monitor the controlled handling, transfer and disposal of the stockpiled ACM from the buffer store. 205.If ACM is identified: v) To prepare asbestos management plans (AMP) including asbestos abatement plan (AAP) for CDGK DOE for all subprojects and to report directly to the Head of CDGK if the progress with the AMF is insufficient to support PFR to ADB. vi) To review and verify the progress in AMP implementation for each subproject. vii) To assess whether robust asbestos management practices have been achieved and /or improved continually on all subprojects. viii) To assess efficiency and effectiveness of asbestos management practices and engineering control measures that have been implemented, their impacts (positive as well negative) and sustainability, drawing both on policy and practice and to suggest any corrective measures, if necessary. 206.The Asbestos Specialist will be involved in ongoing monitoring of the AMF implementation for the CDGK. The major tasks expected are:

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i)

To Compile and report on preparation of AMP for all subprojects and to notify PMU and Head of CDGK if the progress in AMP is insufficient to support PFR to ADB;

ii) Compile and report results of bulk sampling and monitoring and verify results through random checking at the field level to assess whether AMF objectives have been generally met; iii) Identify the strengths and weaknesses of the AMF objectives, approaches, implementation strategies and identify any unexpected locations of ACM ; and iv) Review and verify the progress in AMF implementation of each subproject and every six months prepare reports for CDGK and ADB.

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APPENDIX 2 ASBESTOS ABATEMENT PROCEDURES Removal of Asbestos Cement Pipes (ACP) Principle The principle will be that asbestos cement pipes shall be carefully excavated, lifted on to plastic sheets for wrapping, wrapped in polythene and sealed with duct tape and then lifted and lowered on to the transport lorry for transport to the designated storage area or landfill. The procedure shall follow the measures indicated below: Preparation 1.The CONTRACTOR shall make available the materials in Appendix 3. 2.The CONTRACTOR shall be prepared and agree to remove and transport, on lorries covered with tarpaulins, all the wrapped asbestos cement pipes ACP and fractured ACP that is in drums, from the site to the secure temporary buffer store designated by DOE - CDGK to await disposal. 3.The CONTRACTOR shall provide approved protective clothing to all workers. The CONTRACTOR shall also provide approved protective clothing to the DOE – CDGK inspector as and when requested. Protective clothing shall consist of an approved disposable full body coverall, with head cover. Hard hats and boots shall also be made available to all workers by the CONTRACTOR. 4.Workers handling the asbestos cement pipes shall wear approved half face dust masks protective coverall and goggles. The CONTRACTOR shall ensure all workers wear the protective clothing provided. 5.The DOE - CDGK Asbestos Specialist inspector shall carry out a visual inspection to check that the preparation has been carried out satisfactorily and instruct issue a written certification to the Contractor to proceed. Abatement Method 6.First of all the ground / pipe trench shall be excavated carefully using hand tools to expose the old ACP. Any accidentally excavated loose pieces of asbestos cement shall be picked up and stored in plastic bags or barrels and sealed. 7.The ACP shall be removed in sections carefully using manual labour and hand tools to expose the old ACP so that it can be lifted carefully to avoid cracking as far as possible. Any accidentally fractured loose pieces of asbestos picked up and stored in plastic bags or barrels and sealed. 8.The drums / barrels to contain the fractured pieces of asbestos cement pipe shall be made of plastic or metal. If made of some other material the drums / barrels shall be lined with two layers of 0.15mm polythene sheeting. When the drums are full the plastic lining shall be folded over the pipe segments and secured in place with duct tape and the lid placed on the drum and secured in place with duct tape. 9.Before commencing with the removal of the ACP the surface of the asbestos shall be wet. Any dry areas of exposed existing asbestos cement pipes shall be sprayed with water (preferably containing a wetting agent) to reduce fibre release. The

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wetting agent shall be of a correct mix and concentration in accordance with the manufacturer’s instructions as specified under materials (Appendix 3). 10.The wetting solution (amended water) shall be sprayed using equipment capable of providing a ‘mist’ application to reduce the release of fibers. The existing asbestos material shall be sufficiently saturated to wet it thoroughly. The existing asbestos material shall be sprayed repeatedly during the removal processes to maintain a wet condition and to minimize asbestos fibre dispersion. 11.The fixed asbestos cement pipes shall be carefully separated and prized off any supporting brackets and separated from any attached asbestos cement pipes or cement screed base and taken up in manageable sections taking care not to drop, crack, break or damage the asbestos cement pipes. POWERED MECHANICAL EQUIPMENT (such as backhoe) SHALL NOT BE USED TO REMOVE THE ASBESTOS PIPES because this will increase the risk of cracking and fibre release. 12.The asbestos cement pipes shall then immediately be wrapped in two layers of polythene or smaller pieces can be double bagged and goose neck tied with duct tape and the polythene shall be wet wiped clean. 13.The bottom 10cm of soil below the old ACP shall be assumed to be contaminated with asbestos fragments or fibers and shall be loosened and shoveled or picked up and stored in plastic bags or barrels and sealed as ACM. 14.The bottom 5cm of soil below the old ACM pipe, loose debris and rubble will be removed to create a level floor to the trench and to designate the completion of the removal work 15.The exposed surfaces of the partially wrapped pipes and the surface of the trench to be sprayed with adhesives (PVA) to be used as “lock down” on surfaces during the final clean up of the area. This is to bind any traces of asbestos fibre which may remain on exposed surfaces. 16.All wrapped asbestos cement packs shall be transferred to the lorries for immediate transportation to the temporary buffer store to await disposal. All wrapped asbestos cement packs shall remain at the temporary buffer store and not be removed 17.The workers shall immediately wet wipe down the overalls and mask and wash hands and face and any accidentally exposed areas of skin to decontaminate. The dust masks and overalls, gloves, wet wipes and any other litter shall then immediately be double bagged and goose neck tied for disposal as asbestos waste. 18.The DOE - CDGK Asbestos Specialist inspector will then carry out a visual inspection to certify that all visible asbestos cement pipe and fragments have been removed to a satisfactory standard. If the visual inspection indicates a satisfactory standard all the asbestos cement packs shall be counted and picked up and transferred to the lorries for transportation to the temporary buffer store to await disposal. 19.The DOE - CDGK Asbestos Specialist inspector will then carry out a reassurance visual inspection to certify that all remaining polythene packs and equipment and visible asbestos has been removed to a satisfactory standard and proper decontamination of tools and equipment has taken place. 20.The DOE - CDGK Asbestos Specialist inspector will then check and record the number of packs of waste transferred to the lorries are the same as those that arrive at the temporary buffer or landfill using a trip ticket system.

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21.The DOE - CDGK Asbestos Specialist inspector will monitor and periodically audit the buffer store and landfill security to ensure no pilfering or theft of the stockpiled waste. 22.The Asbestos Specialist inspector will report on the progress of all the asbestos abatement works under the MFF twice per year to ADB.

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APPENDIX 3 MATERIALS AND EQUIPMENT and ASBESTOS LABORATORIES Containment Materials a. At least two layers of transparent plastic (0.15mm thickness low density polythene (B.S.4932:1973) shall be used for wrapping the ACP in sizes which minimize the need for jointing. Polythene transparent bags and containers used for packing of asbestos waste should be able to resist puncturing by the sharp edges of the asbestos cement. b. The wrappings shall be carefully joined and sealed with wide duct tape, spray adhesive capable of sealing adjacent sheets of polythene and facilitating attachment of polythene to the asbestos cement. The adhesive agents should be capable of adhering and maintaining the wrapping in place under both wet and dry conditions. c. Pipe sections and fragments of 2m or less shall be completely wrapped in polythene or collected in polythene bags. Pipe sections and fragments of greater than 2m shall have the end up to 1m and any cracked or broken areas completely wrapped in polythene. Intact pipe sections greater than 2m shall have the ends end up to 1m and any cracked or broken areas completely wrapped in polythene. d. The access to the asbestos waste shall be guarded at all times by security personnel. Wetting Agent and Lock Down e. It is strongly recommended to apply amended water containing a wetting agent on the asbestos materials prior to removal so as to minimize the release of asbestos fibers during the removal process. Electrical equipment is not likely to be present in the excavated trenches but if electrical cables are present these should be de-energized and isolated prior to the application of wetting agents. f. The recommended wetting agent for the amended water to enhance penetration should be 50% polyoxyethylene ester and 50% polyoxyethylene ether or equivalent. The wetting agent shall be diluted in accordance with the manufacturers’ instructions. As a fall back option household washing up detergent mixed at 10% to amend wetting water can be substituted g. Water based polyvinyl acetate adhesives (PVA) to be used as “lock down” for spraying on to surfaces during the final clean up of the area shall be able to bind traces of asbestos fibre which may remain on exposed surfaces. The adhesive shall be dyed to indicate where it has been sprayed and facilitate a check as to whether they have been applied or not and to facilitate cross-checking at a later stage. Lifting Gear & Ladders h. All lifting appliances, i.e. wire slings, ropes and chain blocks, must comply with the local construction sites safety regulations. Valid test certificates must be kept on site for checking at all times. i. Ladders shall be used in line with general safety procedures. Joints and ends of ladders, scaffolds and parts of lifting gear where appropriate shall be sealed with tape to prevent the incursion of asbestos fibers and finished to create a smooth surface to facilitate cleaning.

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Respirators (dust mask) j. The respirators to be provided by the CONTRACTOR shall be of an approved type contained appropriate for protection against the level of asbestos fibers reasonably expected in the particular stage and environment of work. In this case half face dust mask shall be required. k. The CONTRACTOR shall provide disposable paper respirators to all workers with a protection factor of 4 (e.g. recommended 3M8812 or equivalent). The CONTRACTOR shall also provide approved respirator(s) to the DOE - CDGK Asbestos Specialist inspector as and when requested. l. The respirators shall be removed when wet and be treated as contaminated waste. A new half face dust mask shall be provided to each worker prior to each shift, and the CONTRACTOR shall hold sufficient spare masks on site at all times for replacement purposes. Protective Clothing m. The CONTRACTOR shall provide approved protective clothing to all workers. He shall also provide approved protective clothing to the DOE – CDGK Asbestos Specialist inspector as and when requested. Protective clothing shall consist of an approved disposable full body coverall, with head cover. Hard hats and boots shall also be made available by the CONTRACTOR. Coveralls will be of a disposable type: •made from material which does not readily retain asbestos dust and •prevents, so far as is reasonably practicable, dust penetration; •is close fitting at the neck, wrists and ankles; and •without external pockets or unnecessary pleating or accessories.

Preferred disposable coveralls, mask and sprayer

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Workers handling drummed high risk friable asbestos

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APPENDIX 3 continued - LABORATORIES IN PAKISTAN WITH CAPABILITY TO IDENTIFY ASBESTOS 1. Pakistan Council of Scientific & Industrial Research PCSIR Labs Complex Off University Road Karachi Tel#: +92-21-8141841 Fax#: +92-21-8141847 2. National Physical and Standards Laboratory (NPSL), Islamabad Plot No.16, Sector H-9 Islamabad Tel#: +92-51-9257459, 9257462-7 Fax#: +92-51-9258162 3. Pakistan Council of Scientific & Industrial Research PCSIR Labs Complex Ferozepur Road Lahore Tel#: +92-42-9230688-95,9230704 Fax#: +92-42-9230705

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APPENDIX 4 REVIEW OF ADB PROJECTS WITH ASBESTOS Asbestos issues for Karachi Mega city Sustainable Development MFF subprojects.

1. Asbestos is internationally recognized as a hazardous waste. Many developed and some developing countries have statutory controls on the manufacture, use, handling, removal, storage and disposal of asbestos containing materials (frequently referred to as ACM). 2. Whereas ACM were often materials of choice for many applications and used widely in the second half of the 20th century, these materials have generally been removed from most applications in developed countries because of the hazard and replaced with materials with equivalent or better performance (e.g. asbestos cement pipes replaced with high density polyethylene or UPVC). 3. Friable forms of asbestos (e.g. woven gaskets, acoustic plaster and thermal plaster pipe insulation - high risk) can readily release asbestos into the environment with potential carcinogenic effects in the lung and less commonly in the gastrointestinal tract. All forms of asbestos (including cement and resin based ACM – low risk) can potentially release asbestos if they are deliberately disturbed or abraded. Therefore controls are placed on all forms of asbestos manufacture, use, handling, removal, storage and disposal to reduce the release of asbestos fibres into environment to reduce the risk. 4. The engineering controls that need to be in place for non-friable (so-called) low risk ACM (including cement based ACM) for handling, removal, storage and disposal, do not require high-tech solutions and need not be expensive or difficult to introduce. The controls will however require some other administrative controls to identify and track the ACM waste “cradle to grave” to further reduce the risk. Main concern for asbestos in Pakistan relevant to Karachi Mega City MFF subprojects

5. Typical of many developing countries Pakistan uses asbestos for many industrial and commercial purposes. Best professional judgment suggests that at this stage asbestos cement pipes have been typically been used in 50% to 70% of the Karachi water supply pipe system which extends over thousands of kilometres. Much of this system will be replaced by ADB supported project in the immediate future and in a rolling programme over several years. There may well be other residual asbestos waste entering the solid waste management work stream. 6. There are as yet no statutory controls on hazardous waste in Pakistan. The Hazardous Substances Rules were drafted in 2003 but were never brought into force. Asbestos waste is listed in the draft Hazardous Substances Rules 2003 (HSR). If enacted the HSR would require an entity licensed under the Pakistan Environmental Protection Act (1997) to have a waste management plan for any listed hazardous substance. SWM in Karachi Mega City MFF

7. The solid waste management Roadmap envisages one goal as “an effective regulatory framework for the environmentally safe and healthy management of all municipal and hazardous solid wastes generated in Karachi” 8. Therefore although hazardous waste management (HWM) in Karachi is in its infancy, with no regulatory or legislative framework, and no institutional capacity or funding at the Government level, the need for a HWM system has been recognized. 9. ADB may well be involved in HWM (therefore waste asbestos management) corollary to the development of SWM in Karachi Mega City MFF. (N.B. Another ADB

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initiative, the RETA on Hazardous Wastes Management, covering Nepal, India, Bangladesh and Bhutan is now underway). 10. The lack of a functioning HWM system in Karachi is of serious concern, as many of the wastes are presumably being disposed of also through illicit dumping methods throughout the city. This would presumably be the fate of any asbestos waste from the MFF Tranche 1 projects if disposal of ACM is not controlled. Standards for asbestos issues arising in Karachi Mega City MFF

11. ADB standards are guided by the World Bank Pollution, Prevention and Abatement (PPAH) that requires asbestos disposal should be carried out in line with host country regulations or following best international practice. 12. Therefore as there are as yet no local standards for asbestos control in Pakistan, any known asbestos waste requiring removal should be disposed of following best international practice. In the recently published ADB Guidelines on Environmentally Responsible Procurement (2007) asbestos fibres are on the prohibited list but asbestos cement sheets with less than 20% asbestos are exempted. Way forward

13. In line with best international practice, a dedicated Asbestos Management Plan in IEE / EMP for relevant subprojects for Karachi Mega City MFF should be developed. As far as can be anticipated, dovetail the AMP with future developments in SWM and HWM for Karachi and other MFFs in Karachi and other ADB experience and lessons. 14. Recommend that Under Karachi Mega City MFF TA (Option 1) or extend existing ToR of international consultant (Option 2) to develop an interim an Asbestos Management Plan for the Tranche 1 subprojects in Water Treatment and Supply and SWM subprojects under the MFF. Some projects mentioning Asbestos from ADB website

15. Asbestos has been identified as a concern in several projects in the table below (this is not necessarily a complete list of all projects an exhaustive list. Short I.d.

Comment

Korangi RRP

Not mentioned in SIEE

PAK PCR

Mentions AC replacement as a benefit, no issues flagged. AC pipes referenced, nothing flagged referencing replacing old AC pipes as a benefit, nothing flagged mentions AC pipes but doesn't flag any issues in handling asbestos roofing: has one footnote

Malaysia: Manila Water:

India RRP

Cook Islands RRP # BAN RRP #

Mentions AC pipes and has Text below as mitigation (?) measures.

ADB website disclosure reference http://www.adb.org/Documents/RRPs/PAK/rrpR15897.pdf http://www.adb.org/Documents/PCRs/PAK/pcr-pak22302.pdf

http://www.adb.org/Documents/PCRs/MAL/in7_02.pdf http://www.adb.org/Documents/RRPs/IND/rrp-35068ind.pdf

http://www.adb.org/water/actions/phi/Manila-WaterReducing-NRW.asp http://www.adb.org/Documents/PPARs/COO/ppa-coo24331.pdf http://www.adb.org/Documents/Environment/BAN/36297BAN-SIEE.pdf

# see comments below

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Karachi Mega City Sustainable Development Program MFF Tranche 1 IEE Report for Water Treatment Plants and Water Distribution Mains Subprojects

One other power sector project for ADB Bangladesh Project

16. A contractor (demolition and construction) in Bangladesh working under ADB funded Power plant project was looking for an asbestos demolition and disposal Specialist/firm/inspector having license as it was apparently a requirement under ADB funded project (personal approach to David Green as asbestos consultant mid 2007). The asbestos handling contractor/Specialist/ Inspector was needed to work or supervise a team for1-2 months engaged in demolition and disposal of asbestos in an old power plant. No other details could be found on the ADB website 17. In the following paragraphs the text located at the specific location is quoted and reviewed and [CONSULTANT OBSERVATIONS IN CAPS and SQUARE PARENTHESES] BAN RRP: http://www.adb.org/Documents/Environment/BAN/36297-BAN-SIEE. 18. Mitigation measures include: (i) damaged AC pipes will be left in place and the replacement PVC pipes [THIS IS NOT MITIGATION BY INTERNATIONAL STANDARDS] whenever possible will be laid parallel to the existing AC pipes [THIS IS NOT RESPONSIBLE PROCUREMENT AS IT DOES NOT PROVIDE ANY CONTROL TO DEAL WITH THE RESIDUAL ACM IF OTHERS HAVE TO DIG THE TRENCH LATER]; 19. Adequate space will be provided between the proposed and current alignments, so that the excavation of trenches for the replacement PVC pipes will not expose the AC pipes. [HOW CAN THIS BE ASSURED]? Left buried [IS NOT IN LINE WITH BEST PRACTICE], impacts due to exposure to airborne asbestos fibers are eliminated; and [BUT FUTURE EXPOSURE CANNOT BE RULED OUT, THEREFORE NOT ELIMINATED] 20. Maintenance workers will be made aware that the old pipe is still there through appropriate documentation and a marker layer. [OPTIMISTIC APROACH AT BEST – IN BEST PRACTOCE AN ASBESTOS MANAGEMENT PLAN WOULD BE PUT IN PLACE TO MAKE SURE THE ACM WAS MANAGED]. 21. An asbestos management plan will be prepared by a qualified international asbestos management consultant as part of the Project Consultants. Exposure to asbestos can be prevented by containment, regular inspections, and proper precautions when working around or with the material. [ACCEPTABLE BUT WHO WILL INSPECT DOUBTFUL IF ANY EXPERIENCED CONSULTANT WOULD RECOMMEND DELIBERATELY LEAVING MATERIALS IN THE GROUND WHEN THEY COULD BE REMOVED EASILY AND STOCKPILED EVEN IF DISPOSAL IS LATER]. 22. [THE PROPOSED MEASURES ARE NOT IN LINE WIT BEST INTERNATIONAL PRACTICE.] Cook Islands RRP: http://www.adb.org/Documents/PPARs/COO/ppa-coo-24331.pdf 23 Asbestos cement sheeting is generally not hazardous if it is intact. But if it is broken or damaged (e.g., during removals), it can become friable and release asbestos fibres, which are a respiratory hazard and are respiratory and gastrointestinal carcinogens. Precautions need to be taken during removal. [OK APPROPRIATE RESPONSE WOULD BE TO HAVE AN ASBESTOS MANAGEMENT PLAN PREPARED BY A QUALIFIED REGISTERED ASBESTOS CONSULTANT IN LINE WITH RECOGNISED CODES OF PRACTICE ON SAFE HANDLING OF LOW RISK ACM]. 24 The consultant could not identify reference text for asbestos in any of the other reports

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