Turkmenistan: North South Railway Project Monitoring Report January 2015–August 2016 Turkmenistan:...

Environmental Monitoring Report

January 2015–August 2016

Turkmenistan: North–South Railway Project Prepared by the Consultant for the Ministry of Railway Transport of Turkmenistan and the Asian Development Bank.

This environmental monitoring report 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. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

CONTENTS

ABBREVIATION ........................................................................................................................ 1

INTRODUCTION ....................................................................................................................... 2

1. GENERAL INFORMATION ............................................................................................. 2

1.1. Objectives, Scope and Methodology ................................................................... 2 1.2. Construction Activities and Project Progress ....................................................... 2 1.3. Construction Activities and Project Progress ....................................................... 3 1.4. Relationships with Contractors, Owner, Lender .................................................. 4 1.5. Capacity Building and Trainings .......................................................................... 7 1.6. Project Permitting Status ..................................................................................... 7

2. ENVIRONMENTAL MONITORING .................................................................................. 7

3. SITE ENVIRONMENTAL MANAGEMENT PLAN ............................................................ 9

3.1 Environmental Management System................................................................... 9 3.2 Site Inspections and Audits ................................................................................. 9 3.3 Consultation and Complaints ............................................................................ 12

4. CONCLUSION ...............................................................................................................13

APPENDIXES ...........................................................................................................................15

Appendix 1: Environmental Passport Developed by Contractor ............................................... 15 Appendix 2: Revised Limits for Emissions for 2014–2015 ........................................................ 16 Appendix 3: Revised Limits for Emissions for 2016 .................................................................. 17 Appendix 4: Agreement with Sanitarian Epidemiological Station on Disinfection ...................... 18 Appendix 5: Certificate of Compliance of Working Conditions (2015 and 2016) ....................... 19 Appendix 6: Environmental Monitoring Plan included in IEE .................................................... 21 Appendix 7: Example of Contractor's EMR............................................................................... 22 Appendix 8: Conclusion of SES on Compliance with Standards ............................................... 26 Appendix 9: Photo Report on Environmental Monitoring .......................................................... 27 Appendix 10: Required Measures, Correction Actions and Status of Earlier Recommended Corrections Actions .................................................................................................................. 38

ABBREVIATION

ADB – Asian Development Bank

CCSD – Construction Civil Structure Department

EA – Executive Agency

EMP – Environmental Management Plan

EMR – Environmental Monitoring Report

ES – Environmental Safeguards

FL – Fuels and Lubricants

IA – Implementation Agency

IEE – Initial Environmental Examination

LA – Loan Agreement

MRT – Ministry of Railway Transport

PAM – Project Administration Manual

PMC – Project Management Consultant

PPTA – Project Preparation Technical Assistance

PSCD – Power Supply and Communication Department

RTAP – Regional Technical Assistance Project

SE – Safety Engineering

SEMP – Site Environmental Management Plan

SES – Sanitarian Epidemiological Station

SPS – Safeguard Policy Statement

TA – Technical Assistance

TDS – Total Dissolved Substance

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INTRODUCTION

1. GENERAL INFORMATION

1.1. Objectives, Scope and Methodology

1. This report has two objectives—(i) provide information on operations under Environmental Monitoring for 2015 and the second half of 2016, and (ii) consolidate the outcomes of Environmental Monitoring for the whole project implementation period as compared to basic conditions.

2. The report is also prepared to comply with environmental safeguards of the Government of the Turkmenistan and ADB Safeguards Policy Statement (ADB, 2009) as well as to fulfill the loan covenant as described in the Loan Agreement: TRKM 2737 between ADB and Turkmenistan.

3. To achieve these objectives, following activities were carried out: (i) review of the obtained regulatory and authorization documents related to environmental performance, and the ContraМtor’s rОports on ОnvТronmОntal monТtoring for 2015–2016; (ii) meetings with experts and inspection of construction sites in the project area; and (iii) preparation of Environmental Monitoring Report with analysis of the status of implementation of corrective actions recommended within previous environmental audits.

4. The report provides information on environmental performance for 2015 and January–June 2016, and analysis of compliance with environmental requirements and an action plan to address identified non-compliances prepared based on previous audits.

1.2. Construction Activities and Project Progress

5. The “NortС–South RaТlаaв ProjОМt” Тs tСО part oП largО raТlаaв МonstruМtТon projОМt North–South with the total length of 680 km, connecting Uzgen (Kazakhstan) with Jorgan (Iran). Construction project of one-track line for diesel locomotive is divided into two parts:

Part 1 (UгОn’–Gyzylgaya–Bereket) – in the north, length 574 km, including 444 km in the territory of Turkmenistan and 130 km in Kazakhstan.

Part 2 (Bereket–Etrek–Jorgan) – in the south, length 338.5 km, including 256.5 km in the territory of Turkmenistan and 82 km in Iran.

6. Project design and construction works, and laying of the railway line were implemented by the Government of Turkmenistan. According to the specifications prepared by MRT and included in tender documents, the following works need to be implemented within ADB-funded loan:

Power Supply – includes detailed design, installation of 10 kV electricity line, distribution system, substations and SCADA, spare parts;

Signaling – includes detailed design, connection and installation of alarm system, spare parts;

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Telecommunication – includes detailed design, connection and installation: (i) communication of Ashgabat and stations along the section Chilmamet–Buzkun; (ii) mobile railway radio system (MRRS); (iii) fiber optic cable with related transmit-receive switching;

Track maintenance machinery – procurement: (i) a high-performance ballast cleaner machine for railway and turnouts, (ii) two machines for cleaning of sand.

7. Civil works related to construction within all three components have been completed. At the time of the report preparation (August 2016), tСО projОМt’s НОПОМts lТabТlТtв pОrТoН has come into effect. The Contractor has completed the project civil work, therefore the Temporary Rotational Camps at Buzkhun stn (Khazar), Tuver stn (Arsary Baba), and Burugun Byli stn have been moved out to Production and Storage Depot at Chilmamet stn (Aq Yol) in case of repair work during defects liability period.

8. In accordance with the national legislation of Turkmenistan, the object is deemed handed over upon its acceptance by the State Acceptance Commission. Participation of representative of State Committee of Environmental Protection and Land Resources as member of the commission is mandatory. The designated representative evaluates objОМt’s compliance with the requirements of national environmental legislation of Turkmenistan.

9. On 28 July 2016, members of State Committee signed a certificate of acceptance, which is indicative of tСО ПaМТlТtв’s МomplТanМО аТtС natТonal ОnvТronmОntal rОquТrОmОnts.

1.3. Construction Activities and Project Progress

10. Organizational structure of project management is shown in Figure 2. The Executing Agency for this project is the Ministry of Railway Transport of Turkmenistan (Client). Department of Capital Construction (NACO) is a division in MRT appointed as responsible for acceptance of the project into operation. Two NACO’s subНТvТsions are involved in the project: (i) Department of signaling, telecommunications and power supply, (ii) Department of Economics and Finance. The project is directly supervised by the Project Manager, who is the contact person and liaison between the Client and the Contractor.

11. There is no separate unit dealing with nature protection within the Ministry of Railway Transport of Turkmenistan. To monitor the implementation of environmental requirements a Consultant - environmental specialist is hired. The Consultant conducts environmental audits, prepares of Environmental Monitoring Reports on behalf of MRT for further submission to ADB.

12. The Contractor has an environmental specialist who was in charge of H&S and Environmental Protection issues during construction and was involved up to the mid of August 2016. Environmental specialist conducted an environmental monitoring on project sites, training for workers. In addition, the expert was responsible for getting all necessary permissions and timely payments in accordance with national environmental legislation.

13. To ensure compliance of project works with environmental legislation of Turkmenistan, occupational health and safety national requirements, the Contractor worked with the Balkan branch of environmental protection, sanitary and epidemiological services, municipal services of Balkan province on the issues of obtaining the required permissions.

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1.4. Relationships with Contractors, Owner, Lender

14. Starting in 2015, the Contractor provided semi-annual reports on the implementation of environmental protection measures on construction sites. The last semi-annual report was submitted in February 2016. At tСО samО tТmО, a Consultant Пrom ADB’s TОМСnТМal AssТstanМО conducted an environmental audit and prepared a report on environmental monitoring for 2015. The report described the status of implementation of nature protection measures and the revealed failures to comply with the requirements, and a work plan to rectify the shortcomings was prepared. The 2016 environmental monitoring report was prepared by the Executive Agency and submitted to ADB for review and approval. An approved copy of the report was delivered to the Contractor to rectify the revealed shortcomings.

15. In May 2016, an ADB Mission, which consisted of an environmental specialist, also conducted an inspection of the project territories and provided some comments on improvement of environmental situation at the project sites.

16. In July 2016, a final report was prepared, which highlighted all comments made under the 2015 environmental monitoring report and by the ADB Mission. The subsequent chapters give a photo report of the work done on shortcomings rectification.

17. As part of cooperation between the Contractor, the Balkan subdivisions of the State Committee1 for Nature Protection and Land Resources (SCNPLR) and Sanitary and Epidemiological Station (SES), the Contractor received all the necessary permits for 2016, made required payments in accordance with national environmental legislation. More information on permissions and payments are presented in the following chapters.

18. In accordance with the national environmental legislation, the Contractor developed "Environmental Passport", which was approved by Ministry of Nature MON (SCNPLR) in 2013 (Annex 1). This document is a basis for the calculation of allowed emissions during construction works. Annual norms for emissions are developed on the basis of the Environmental Passport, and then allowable air emissions, water resources, and wastes generation limits (norms/rates) are approved. The Contractor prepared emission norms that were later approved by the SCNPLR, and made all relevant payments.

19. Compliance with the established norms during construction is monitored and evaluated by representatives of SCNPLR according to the internal state program of environmental monitoring. In the case of detection of the fact of exceeding the established norms SCNPLR calculates the penalty for excess and sends written notice of the violation and an invoice for payment of fine to the Contractor. During 2015 and 2016 SCNPLR has not submitted any written notifications, which indicates the absence of excess emissions into environment from construction activity.

20. The Contractor also signed contracts with the municipal services for disposal of solid domestic wastes and effluents from the territory Chilmamet station (the new name of Ak Jol) at the municipal landfill and sewage treatment plants Bereket city, located 30 km away from the station.

1 In January 2016, the Ministry of Environment of Turkmenistan was merged with Land Resources Conservation

Service into the State Committee for Nature Protection and Land Resources.

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Figure 2: Project Organizational Chart

Ministry of Railway Transport – Executing Agency

Department of Capital Construction

Department of Signaling,

Communication and Electricity Supply

Department of Economics and

Finance

Technical Assistance (ADB

Mission, Env. Specialist)

Contractor (Env.

Specialist)

ADB

Project Manager

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Figure 1: Map with alignment of railway

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1.5. Capacity Building and Trainings

21. During the reporting period, external training courses on environmental issues have not been conducted. Contractor conducted briefing on issues of safety personnel, occupational health and the environment, which are recorded in the logs.

22. In addition, during the environmental audits conducted by the Environmental Consultant and the ADB Mission in February and May 2016, on-the-job trainings were also conducted. The environmental audits were conducted in presence of the MRT and the Contractor, during which the auditors, along with identification of discrepancies, also recommended the ways for solution of the problems and ways for prevention of such in future.

1.6. Project Permitting Status

23. As stated in the previous sections an official government environmental permission to conduct project works, namely Ecological Passport was received from SCNPLR (formerly MOE) in 2013. Based on this document, state inspectors of SCNPLR calculated the allowable emissions for 2015-2016 and amount of compensations for them. A copy of permissions is provided in Appendix 2.

24. In addition, the Contractor has signed a contract with the local agency «Bereket Etrap Jemagat Hojalygy» on the removal and disposal of municipal solid waste and sewage waste water from a warehouse and labor camps for 2015-2016 (Appendix 3).

25. In aММorНanМО аТtС tСО agrООmОnt №17 bОtаООn tСО ContraМtor anН SES of Bereket city (Appendix 4), disinfection of warehouse and premises at construction sites were held regularly during 2015-2016.

26. A certificate issued in July 2015 and valid until July 2016 indicates compliance of workplaces and residential requirements of the sanitary standards (Appendix 5).

27. Intital version of SEMP was prepared by Contractor and approved by PMCSC in 2012. In December 2013 the SEMP was updated in accordance with recommendations provided by Environmental Auditors during the environmental training and audit in October 2013. Following comments made during the environmental audit in 2015, on necessity of official submission of SEMP to the Client, the Contractor has submitted plan in 2015.

2. ENVIRONMENTAL MONITORING

28. In accordance with Environmental Monitoring Plan provided in the IEE the following parameters needed to be monitored during the construction stage (Appendix 4):

Air quality;

Water and waste water quality;

Noise;

Solid wastes;

Hazardous materials;

Soil erosion and sand movement;

Avifauna

29. Only visual inspection of construction sites in term of dust monitoring is being implemented by the ContraМtor’s EnvТronmОntal EбpОrt and MRT inspectors. The Contractor

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also ensured that all construction activities were being imlemented in the period between 7:00-19:00 to avoid artificial noise generation during the night time. Instrumental measurements of air quality were not conducted due to location of construction sites and allignment itself in the are remote from settlements (human activity is concentrated in Bereket city, approximately 22 km from the southern end of the Project and in Gyzylgaya village located 6 km away from Gyzylgaya station).

30. During the reporting period, water tests has not been carried out, since the construction works were conducted at the sites remote from the water sources used for drinking or agricultural purposes.

31. Visual monitoring of wastes disposal practice including utilization of hazardous wastes Тs bОТng ТmplОmОntОН bв MRT ТnspОМtors anН ContraМtor’s EnvТronmОntal EбpОrt.

32. The monitoring of impact of works on signaling and electrification on soil adjacent to the railway track vegetation has been conducted. After a visual inspection and determination of areas in which sand strengthening plantations were damaged, MRT’s inspectors sent notification about observed damage to the Contractor. Following to received notification the Contractor addressed damages, restored affected sites, and after that notified the Client through official letter.

33. There are requirements for the monitoring of avian fauna, particularly bird mortality in IEE. Two sites were identified as important bird areas: Tekedzhik Beynekyr-and-Ersarybaba Akkyr. The IEE stated that the Ministry of Environment and/or independent organization are responsible for taking such actions.

34. During conduction environmental audit (in February 2016) two meetings were held with representatives of the Committee for Environmental Protection and Land Resources and MRT’s experts on bird nesting and migration issues.

35. Due to low electric tension of power lines – 10 kV and their location far away from the place of migration and nesting additional measures on incorporating mitigation measures for birds were not required.

36. Thus, there was an exclusively local environmental impact at the first stage of project implementation, without any change in the air quality, water resources, and any adverse impact on flora and fauna of the project area.

37. The soil resources were mainly polluted within the rotational camps territory in the form of small oil spills, which, after the audits, were removed in accordance with established procedure.

38. Owing to remoteness of the railway track where project work was conducted from settlements (the nearest one is at 6 km) and by virtue of respective operation and further removal of the construction camps, there was no adverse social impact as well. Instead, non-hazardous wastes (wooden and paper packing) intended for further utilization were donated to local communities.

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3. SITE ENVIRONMENTAL MANAGEMENT PLAN

3.1 Environmental Management System

39. As mentioned above in addition to the SEMP approved in 2012, the Contractor had НОvОlopОН “ComprОСОnsТvО plan oП ОnvТronmОntal mТtТgatТon mОasurОs” (CPEMM), as a supplementary document. This document was developed in accordance with recommendations provided during Environmental Training and Audit in 2013. The CPEMM was officially approved bв ContraМtor’s Countrв DТrОМtor Тn TurkmОnТstan Тn DОМОmbОr 2013 and in 2015 it was submitted to the Project Manager.

40. The CPEMM comprises of a set of additional activities aimed to mitigate adverse impacts of construction activity – on air quality, collection wastes and its disposal, proper handling oil and lubricants and completion of construction sites.

41. The Contractor has established an environmental monitoring system. The Environmental Engineer who is in charge of Health, Safety and Environmental issues on the construction sites, conducts environmental audits as part of general H&S and Environmental audit on the monthly base. All observations and needed correction actions are reported in office memos which are submitted to Contractor Management. It should be noted, that the office memos contain information about implementation of correction actions made in previous office memos.

42. Following the comments made during environmental audit in 2014, the Contractor submitted reports on the implementation of the construction works on each site / station, where at the time of preparation of the report project works were carried out. Samples of such reports are given in Appendix 7.

3.2 Site Inspections and Audits

43. Site inspections and audits on compliance with environmental safeguards have been МonНuМtОН on tСО sОvОral lОvОls: (Т) montСlв bв ContraМtor’s EnvТronmОntal EбpОrts, (ii) quarterly bв MRT’s inspectors (iii) audits conducted by environmental auditors/Consultant from the ADB (October 2013, February 2015, February 2016, and May 2016).

44. During the audit in February 2016 all 11 stations, 3 working camps and several high mast towers were inspected on their compliance with environmental requirements. As mentioned above, at the time of the audit, all construction works had been completed and the on-going works were mainly carried on running-in telecommunication, signaling equipment and SCADA systems. Although the civil works were not conducted, Contractor's personnel involved running-in process was at the sites.

45. In this regard, the main purpose of the environmental audit on the project sites was to survey:

Living conditions of labor camp

Waste management

Oil handling

Environmental documentation on the construction sites

46. The main findings of the audit are presented in the following paras.

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Inspection of the Contractor’s Workers Camp

Based on February 2016 Audit Findings

47. Across whole route of the project site Contractor has 3 construction bases/labor camps, located at the stations of "Ak Jol" (the old name of "Chilmamet"), "Gyzylgaya" and "Hazar" (the old name of "Buzhun"). The largest camp is located on the "Ak Jol" station that can accommodate up to 40 people at a time. In the camps, located on the "Gyzylgaya" stations and "Khazar", can be placed between 10 and 20 people.

48. Inspection of the working camp at "Ak Jol" showed that suitable living conditions for the workers at the construction were established. Bedrooms, office rooms and a kitchen equipped with devices for air conditioning, provided with permanent hot and cold water supply in the bathrooms and in the kitchen (Appendix 9).

49. Waste disposal practice is being implemented at the warehouse. Separate bins for glasses, plastic and domestic wastes are placed on the camp. Grey water from the kitchen and the bathroom is collected into a metal septic tank located next to the warehouse. During a previous visit it was noted that the septic tank may be dangerous because poorly fence and lightening. The Contractor undertook appropriate measures - improved fencing and lighting of this site (Appendix 9, Figure 7–8).

50. Oiled trash is collected into the specially designated box. Soil contaminated with oil residuals are collected into another box (Appendix 9, Figure 9-12). Content of both boxes are disposed by municipal services on base of agreement between the Contractor and the municipal service.

51. Fuels and lubricants (FL) are stored in tanks, drowned in an earthen pit, refueling of vehicles are done at the warehouse. During first environmental audit the Consultant recommended to improve storage conditions of oil containers in order to prevent oil leakages and to organize special places for oil replacement and all activities which could lead to soil contamination with oil. At the time of the current environmental audit of such places for work with the technique were not organized. Taking into account that the project works are almost completed, which means minimal use of technology, it is recommended to ensure proper cleaning of the territory from the existing oily spots and carry out land reclamation.

52. During site inspection, comments on non-compliance with requirements on oil and fuel storage, which is temporarily kept on the territory of the construction camp. In this regards, Sub-contractor has to ensure proper storage and handling of oil products for the remaining period and ensure restoration of land that have been exposed. Contractor has to report about undertaken measures in his final EMR.

53. Used tires and wood wastes are collected separately, and after accumulating some amount such wastes are transferred to local population for free. Periodic disinfections of the warehouse territory and a residential base from rodents and insects are conducted on the regular base in accordance with an agreement between the Contractor and a local Sanitarian Epidemiological Station.

54. TСОrО Тs a СarН Мopв oП SEMP’s ТnТtТal vОrsТon at tСО аarОСousО oППТМО. GОnОral traТnТng on Health, Safety and Environmental Issues is mandatory for each new worker and it is conducted on periodical basО as аОll. TСО EnvТronmОntal EбpОrt kООps “Log book on traТnТng” with records of all trainings conducted for each worker.

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55. Results of an environmental audit are also recorded as a part of a general audit conducted by the ContraМtor’s EnvТronmental Expert and necessary corrective actions are rОgТstОrОН Тnto tСО “Log book oП monТtorТng oП аorkТng МonНТtТons”. TСО maТn rОmarks about environmental performance relate to wastes disposal on the construction sites and timely cleaning of workers living rooms. The book also includes information on status of implementation of previously recommended corrective actions.

56. There is a special log book for recording emergency situation or accidents on work places. As of date of the environmental audit, there have been no records of any incident or accident.

57. As recommended under the previous environmental audit, a Public Appeal Log has been started at the construction camp. As of the audit date, there were no records in the log.

58. Works on installation equipment at the Chilmammet (Aq Yol) railway station have already been completed. There was not any incompliance with environmental safeguards – all packing materials were removed from station, rooms were cleaned.

59. In general, at the time of carrying out an environmental audit, conditions of site complied with environmental requirements, with some remarks for the storage Sub-contractor’s oil and fuel and the organization places for minor repairs equipment on site. It is recommended that after completion of all project works to carry out a full site cleanup and reclamation of affected land, including septic tanks, remove the remnants of equipment and construction materials, or to transfer them to the executive agency for internal usО aПtОr EA’s approval.

Inspection of Workers' Camp at Gyzylgaya Station

60. At the time of the environmental audit 5 people lived on the site, where proper living conditions were provided for them: kitchen, bedrooms and showers. Sewage water from kitchen and showers are being dumped into a septic tank, located next to the territory of the construction camp.

61. Separate wastes storage practice is not being implemented at the camp, all wastes are disposed into one pit located near railway station. Non-compliance with storage and handling of petroleum products on the site were observed as well. There are several oil spills were observed on the territory of labor camp (Appendix 9).

62. There is Action on occupational safety and health, safety and fire safety at the site. However, the EMP was not available.

63. Inspection of the station and set signaling and telecommunications equipment showed the presence of residues of building materials such as wires, cables, packaging residues, etc. on adjusted territory. Contractor has to conduct a final clean-up before commissioning of the station and supporting equipment.

64. To complete the work in accordance with the environmental requirements it is necessary to ensure complete cleaning of the site, including the removal of debris from the pit for the storage of waste, recycling of used packaging from under fuel, removal of spills of petroleum products on the ground and carry out reclamation of damaged land. The results of the work on closing the construction camp to present a photo report in the final report on Environmental Monitoring.

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Inspection of Workers' Camp at «Hazar»

65. At the time of the audit no more than 5 workers were residing in this camp. Situation on Hazar camp was similar to the situation described in Gyzylgaya camp. Therefore, requirements for the worker camp at "Khazar" station are the same as for the station Gyzylgaya.

Site Inspection

66. The Consultant checked all the remaining railway stations from "Ak Jol" to "Khazar", examined the masts between the stations and surrounding areas, as well as the adjusted area along of the railway with installed signaling equipment and transmission towers.

67. There were no oil spills or their traces on inspected sites. The main comments on cleaning sites adjusted to railway stations, masts and areas along with railway – removal residual of construction wastes. Consultant observed presence of packaging residues, cables and used containers from the water, empty reels, etc. More common non-compliances are presented in Appendix 9.

68. Despite the fact that not all trash in the inspected area was generated by project activities, the Contractor has to clean area before project commissioning to the State Acceptance Commission and to reflect conducted activity in the final EMR.

Based on May 2016 Audit Findings

69. In May 2016, the ADB Mission conducted an audit of the first 130 km of the site and another site at Aq Yol station. The Mission confirmed the findings of previous audit and noted improvements in FL spills response. At construction sites the FL spills response was implemented by removing contaminated soil spots and hauling them to municipal dumps. There were no solid domestic wastes along the railway track.

Final Audit

70. A final audit of project sites was conducted by the Contractor taking into account the comments made under previous audits. Final environmental monitoring report was prepared based on the audit results (July 2016), which included the site photos that were earlier used for comments. From the photos provided, it may be concluded that the Contractor rectified all shortcomings, which was confirmed by representatives of the State Acceptance Commission.

71. The status of implementation of the comments recommended in previous report is given in Appendix 10.

3.3 Consultation and Complaints

72. Consultations process and cooperation with national agencies involved into the nature and health protection are being undertaken within the Project on permanent base. As described in previous chapters, the Contractor works in full compliance with national environmental legislation and received on a timely basis all necessary permits for disposal of solid wastes and sewage, emissions of pollutants into the air, etc.

73. Environmental monitoring of compliance with emission standards are being conducted by national environmental protection agencies. According to the existing practice in case of exceedances inspected organization will send a notification letter with requirements to address

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non-compliance and to pay the prescribed penalty for such cases. During the reporting period, no notifications from the national environmental agencies were received, which indicates that the project activities met environmental requirements of Turkmenistan.

74. A Grievance Redress Mechanism at the construction site is presents by log book maintained by Contractor. For the reported period no complaints were received from local communities. As part of cooperation with local communities, an agreement has been reached between the Contractor and the local communities on managing wood waste (equipment packs) by its use as fuel.

75. In order to clarify the issue on monitoring the projОМt’s impact on birds both during construction and operation stages, the Consultant held a meeting with the head of Department of Nature Protection Mr. Ballaev Batyr. During the meeting issues of locations of birds nesting in the area close to project works, potential effects of the project on them were discussed.

76. Following the meeting it was revealed that project works sites are located at the area remote from environmentally sensitive sites which require special mitigation measures (such as installation bird guards, using special insulated wires for power transmission lines, etc.).

77. At the same time, Mr. Ballaev expressed a request for further investment projects to involve national environmental authorities in the earlier stages of project such as a preparation of project documents, development of environmental monitoring plans and audits.

4. CONCLUSION

78. Since this report has two objectives, the provided comments have been divided into two areas:

For 2015–2016 Reporting Period

During project implementation the main requirements of the national environmental legislation and the SEMP's requirements developed within the IEE were met.

Reporting system between MRT and Contractor on implementation of environmental requirements was established. The Contractor should prepare final EMR report and submit it to MRT. The EMR has demonstrated that all non-compliances and recommendations made within the previous environmental audits have been addressed.

The Contractor has implemented full clean-up of sites where 2 rotational camps are located with due attention paid to oil and wastes disposal, affected land re-cultivation. The rotational camp at Aq Yol station has been left to ensure possible work during defects liability period.

Area adjusted to railway has been cleaned from construction wastes.

The project may be considered as completed since it has been accepted by State Environmental Agencies within the State Acceptance Commission and complies with EMP requirements.

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79. A detailed information on the status of earlier recommended correction actions with indicating timeliness of preparation and completion are provided in Appendix 10.

On the Project Overall

80. Overall, the project’s implementation has had no adverse impact on the environment, as evidenced by the findings of environmental audits conducted by the consultants and observations of local nature protection agencies, and meetings with Nature Conservation Committee of Turkmenistan.

81. At the project start, there were some difficulties with implementation of environmental requirements in ADB format, namely development and approval of Environmental Management Plan, relevant organization of construction sites, and wastes management. The difficulties were driven by insufficient coordination of work on environmental matters between the project Executive Agency, Project Engineer, and Contractor.

82. Following the trainings conducted in 2013 under regional cooperation and subsequent ADB audits, corrections were made to maintenance of environmental documents, monitoring and reporting, cooperation was established with external stakeholders (Nature Conservation Committee of Turkmenistan, SES). As a result, this enabled to improve efficiency of implementation of nature protection measures under the project.

83. Based on outcomes of the project implemented, the following recommendations can be made, which will help ensure effective implementation of nature protection (environmental) measures of successive projects:

84. Ensure inclusion of environmental requirements into bidding and design documents, designate a responsible person for environmental issues from the Executive Agency.

85. Recruit experts from the Nature Conservation Committee of Turkmenistan at initial stage of design documents preparation and during environmental monitoring at the stage of project implementation.

86. Conduct trainings in implementation of environmental issues under investment projects, recruiting experts of the Nature Conservation Committee at the earliest stages of project implementation.

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APPENDIXES

Appendix 1: Environmental Passport Developed by Contractor

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Appendix 2: Revised Limits for Emissions for 2014–2015

17

Appendix 3: Revised Limits for Emissions for 2016

18

Appendix 4: Agreement with Sanitarian Epidemiological Station on Disinfection

19

Appendix 5: Certificate of Compliance of Working Conditions (2015 and 2016)

21

Appendix 6: Environmental Monitoring Plan included in IEE

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Appendix 7: Example of Contractor's EMR

26

Appendix 8: Conclusion of SES on Compliance with Standards

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Appendix 9: Photo Report on Environmental Monitoring

Fig. 1: St Chilmmamet storage of empty plastic bottles Fig. 2: Bins for collection of domestic garbage

Fig. 3: FL storage place Fig. 4: Storage of used FL which required relevant

utilization (May 2015) – revised (May 2016)

Fig. 5–6: Bedrooms and kitchen for construction personnel at Chilmamet station

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Fig. 7: Notes about conducting environmental training in ContraМtor’s log (OМtobОr 2015)

Fig. 8: Regulatory documents on HS and environmental protection measures at rotational camp

Fig. 9: Spill of oil, st Chilmamet (February 2016) – revised (May 2016)

Fig. 10: St Chilmamet (February 2016) – revised (May 2016)

Fig.14–15: Construction wastes near to tower (February 2016) – fixed (May 2016)

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Fig. 14-15: Construction wastes near station (February 2016) – revised (May 2016)

Fig. 16–17: Yazga station and adjacent territory

Fig. 20–21: Remains of construction wastes near station (February 2016), revised (August 2016)

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Fig. 22–23: Station and adjusted territory

Fig. 24: Uzboy station Fig. 25: Signaling equipment at the station

Fig. 26: Module at the station Fig. 27: There were construction wastes near station (February 2016), revised (August 2016)

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Fig. 28: Station Burgun

Fig. 29: Gilgdere station Fig. 30: Basis of tower

Fig. 31: Remains of construction wastes requiring proper utilization (February 2016)

Fig. 32: After conducting final work (August 2016)

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Fig. 33: FL spills requiring proper measures (February 2016) Fig. 34: As of August 2016

Fig.35: Tower between stations Kokdere and Gyzylgaya Fig.36: Soil where wastes were burnt. Recultivation are needed

Fig. 37: Gyzylgaya station Fig. 38: Storage of domestic wastes (February 2016), revised (August 2016)

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Fig. 39: Storage of FL next to camp Fig. 40: Remains of construction materials and equipment (February 2016), revised (August 2016)

Fig. 41: Rotational camp at Gyzylgaya station. Bins for domestic wastes

Fig. 42: Rotational camp at Guzulgaya station. Medical first aid kit

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Fig. 45: Avlamish station Fig. 46: Transmission line

Fig. 47: Remains of constrction wastes on surrounding territory (February 2016), revised (August 2016)

Fig. 48: Remains of construction wastes near station (February 2016), revised (August 2016)

Fig. 49: Module between Avlamish and Arsari Baba stations Fig.50: Construction wastes in 50 meters from module

(February 2016), revised (August 2016)

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Fig. 51: Remains of burned construction materials requiring proper utilization (February 2016), revised (August 2016)

Fig. 52: Part of trasmission line

Fig. 53: Arsari Baba station Fig. 54: TransmТssТon lТnО anН Мamp Пor statТon’s staПП

Fig. 55: Remains of construction wastes (February 2016), revised (August 2016)

Fig. 56: Station territory after completion of work (August 2016)

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Fig. 57: Berkarar station Fig. 58: Construction materials near station (February

2016), revised (August 2016)

Fig. 59: Transmission lines Fig. 60: Veiw of the station

Fig. 61: Remains of construction wastes near to tower

(February 2016), revised (August 2016)

Fig. 62: Bitaraplik station

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Fig. 63: Transmission line on the way to Hazar (Buzhun) station Fig. 64: Territory adjacent to Buzhun station. Empty container for water (February 2016), revised (August

2016)

Fig. 65: Construction wastes near Buzhun station (February 2016)

Fig. 66: Residential trailer for temporary workers' accommodation

Fig. 67: Burned wastes near station (February 2016), revised (August 2016)

Fig. 68: View of adjacent territory as of August 2016

Appendix 10: Required Measures, Correction Actions and Status of Earlier Recommended Corrections Actions

Reference/Impact Requirement Action to date

Action Required/comment

Parameters for monitoring

Data of Implementation Status

Environmental Management Plan

Risk for birds Design of the transmission line is environmentally friendly for birds

No research were done and no special installations for birds protection were applied for power supply line

Based on the outcomes of consultations with the Environmental Protection Committee, no additional requirements are needed.

N/a N/a

Air pollution 1. Dust control measures such as spraying of construction sites and stock piles; covering vehicles and trains transporting construction materials,

2. Proper maintenance of construction equipment, fuel efficiency of machinery

1. Spraying of construction sites is implemented during dry season as per request.

2. Technical control of techniques

are being implemented on a regular basis

1. Contractor continues existing practice.

2. Contractor ensures that

all techniques and vehicles are well maintained

Permanently till the project completion

Completed

Water pollution 1. Mobile construction camps located away from water bodies and agricultural lands;

2. Waste water from

equipment and vehicle washing treated biologically

1. Mobile construction located away from water bodies and agricultural lands;

2. There is no collection ponds for waste water from washing

3. Waste water from labor camps collected into the metal tank and timely removed from site as far as filled

1. No additional activities are needed.

2. The Contractor should guarantee that there are no cases of waste water discharge after washing of machinery and vehicles upon the surface without relevant treatment.

3. Ensure removing waste water from construction camp in time.


Completed

Noise and vibration

1. Scheduling operation to avoid late night hours

2. Use of new well maintained equipment and vehicle

1. Work hours is conducted between 7 am and 7 pm

2. All equipment and vehicles have certificates which cover requirements on noise.

1. Make sure that work hours are between 7 am and 7 pm.

2. Make sure that all techniques and vehicles are well maintained.


Completed

Soil and materials Vegetation and stabilization

Contractor and MRT have agrООmОnt. MRT’s spОМТal

Contractor continues existing practice

Permanently till the project

Completed jointly with MRT

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department conducts vegetation along with alignment as needed.

completion

Hazardous materials and waste management

1. Solid waste management plan and proper transport and disposal in designated areas and landfill sites.

2. Maintaining equipment in good conditions to avoid leaks of oil and lubricants, and performing maintenance operation in designated sealed areas

3. Proper storage of oils, lubricants and chemicals for machinery.

4. Training and kits for handling and spills or waste of hazardous materials

1. Contractor has developed amendment on waste management to initial version of SEMP

2. There is no special sealed areas for performing maintenance with oil and lubricant

3. Oil and lubricant are storage in special place. Oily wastes are kept in special designated places. Used oil are taken by local residents for own use

4. ContraМtor’s ОnvТronmОntal training program includes topics on handling and spills or waste of hazardous materials

Contractor will: 1. Ensure clean-up of

territories of rotational camp from domestic and construction wastes.

2. Conduct full re-cultivation

of soils polluted by oil spills.

3. Conduct soil utilization in

accordance with national legislation.

March 2016 Completed upon the project completion (August 2016)

Environmental Monitoring

Air Quality TSP, NOx, SOx, CO Only visual monitoring of construction site is conducted

Contractor continues existing practice.


Completed

Water Quality TDS, COD, BOD, pH, oil, phenol

Water samples from two stations were analyzed. Detected exceedings are not related to construction activity

Water quality needs to be monitored only in places located close to alignment.

N/a N/a

Noise dB No monitoring are being implemented since there are no sensitive recipients on the surrounded area

No needs to conduct noise monitoring since there are no settlement close to alignment (nearer than 5 km)

N/a N/a

Solid wastes Slag, domestic refuse, metallic scraps, sludge

MonТtorОН bв ContraМtor’s Environmental expert and by site inspectors from MRT. Appropriate records are being carried in case of incompliance events

Visual observation of implementation of measures; Conclusion will be obtained from the State Committee


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that will include an environmental specialist.

Hazardous liquid wastes

Visual inspection and soil sampling if needed

ContraМtor’s EnvТronmОntal EбpОrt anН MRT’s ТnspОМtor monitor implementation

Visual observation of implementation of measures; Conclusion will be obtained from the State Committee that will include an environmental specialist.


Soil erosion and sand movement

Visual inspection Monitoring is being carried by ContraМtor’s EngТnООr anН MRT’s ТnspОМtors. ApproprТatО measures are being undertaken if needed

Visual observation of implementation of measures; Conclusion will be obtained from the State Committee that will include an environmental specialist.


Avifauna Mortality of birds No monitoring on mortality of birds

Committee on Nature Protection will conduct monitoring of bird mortality along the transmission lines.

Project implementation stage

Project implementation stage

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