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Contents
I. INTRODUCTION.......................................................................................5
V. STAKEHOLDERS CONSULTATION.....................................................20
VIII. CONCLUSIONS.................................................................................30
Stage 50
Task / Progress.............................................................................. ...............50
Yes / no (comment).............................................................................. .........50
Date 50
1. Minimizing Asbestos Liabilities.......................................................... ........51
2. Preparation of Detailed Design............................................. ....................51
3. Preparation of Construction Contracts................................... ...................52
4 Monitoring During the Construction Period.................... ............................52
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Figures
Tables
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LIST OF ABBREVIATIONS
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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 rehabilitation of 1.3-km of the Dr Ziauddin Ahmad Road Sewer Line from Shaheen
Complex to Clifton Pumping Station. 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 (GoS) 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) if required by the
Pakistan Environmental Protection Act, 1997 its subservient rules and regulations.
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 Sensitive areas are listed on the Federal EPA website and periodically updated.
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6.The installation or rehabilitation of sewer lines is not specifically mentioned in the IEE-
EIA. However, “waste disposal facility for domestic or industrial wastes, with annual
capacity less than ten thousand cubic meters” requires an IEE. Similarly, regulations on
rehabilitation or reconstruction of existing facilities are not specific. In case of highways
and major road projects, the regulations explicitly exempt “maintenance, rebuilding or
reconstruction” of existing roads from IEE or EIA requirements. The scale of the
proposed sewer project is relatively small and at this stage it is assumed that no IEE or
EIA is required by SEPA. However, the IEE-EIA Regulations 2000 allow the Federal
Environmental Protection Agency (EPA) to direct the proponent of a project whether or
not listed in Schedule I or Schedule II to carry out and file an IEE or EIA for any project
for reasons recorded in such a direction. Such a direction would need to be issued after
recommendation in writing from the Environmental Assessment Advisory Committee to
be constituted under the IEE-EIA Regulations 2000. At this stage it is not known if
CDGK will be required to submit an IEE for the Sewer Line. Therefore this IEE has been
prepared for ADB submission and it can be also be used as the basis for regulatory
approval requirements of the PEPA 1997 if required by SEPA in due course.
7.The National Environmental Quality Standards is applicable to any process emission
or effluent from the subproject. However, no such emission or effluent is envisaged from
this project.
D Report Structure
11.Following this introduction this report contains seven more sections including (ii)
description of sewer line 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.
12.Photographs of the project area are in Appendix A, the environmental management
plan in Appendix B, and the asbestos management framework in Appendix C.
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A Background
13.The drainage system of Karachi is developed around a network of natural drains and
nallahs (dry streams). These drains are the main disposal mechanism for the sewage
as well as storm water from the city. According to the survey undertaken by Orangi Pilot
Project (OPP) there are 41 such drains in the city. Of these 25 drains discharge their
effluent to the Lyari River; 9 to the Malir River; and 7 to the Karachi harbor backwaters
(see Figure 1). All the disposed effluent and storm water eventually finds its way to the
Arabian Sea.
14.In addition to these drains there is also a network of underground sewers that collect
sewage from different parts of the city and through various pumping stations carry it to
the treatment plants operating in different parts of the city. This network, however, serve
only a small fraction of the city population. One such sewer line follows the Dr Ziauddin
Ahmad Road. This sewer, however, has choked and damaged at various places.
Further, due to increased population in its catchment, the existing line does not have the
capacity to carry the sewage generated in the area that it serves. This creates blockage
in the system and has the potential to cause environmental and health problems for the
communities.
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Physical Environment
19.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.
20.Pakistan has 15 seismo-tectonic regions.4 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 Pakistan5 places Karachi in Zone 2 corresponding approximately to Intensity VII of the
Modified Mercalli Scale of 1931.6 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.
21.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.
22.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.
23.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.
4 Quittmeyer, R. C. 1979. The Seismicity of Pakistan and Its Relation to Surface Faults in Geodynamics of
Pakistan. Quetta: Geological Survey of Pakistan.
5 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.
6 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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24.The climate of the Karachi can be broadly classified as moderate and which lies in
‘Subtropical Double Season Coastland zone’7. 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.
25.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 airquality as well
as the availability of ambient air quality data are important concerns.
26.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 Karachi8. 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)
27.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
28.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%
of the country including all of Sindh, central and southern Punjab, most of Balochistan
7 Shamshad, K.M. 1988. The Meteorology of Pakistan. Karachi: Royal Book Company.
8 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.
9 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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and the plains of Northwest Frontier Province (NWFP). 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 region 10. 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.
29.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.
30.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
region11.
10 Nasir, Y. J. and A.R. Rubina. 1995. Wild Flowers of Pakistan. Karachi: Oxford University Press.
11 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.
12 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.
13 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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that cater for the needs of the persons working in the commercial buildings around the
area.
37.The sensitive receivers on the first alternative route include the commerce college
and the commercial and the residential areas on the second alternative route.
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38.This section of the IEE discusses the potential environmental impacts of the
proposed sewer subproject and identifies mitigation measures to minimize the impacts in
the design, construction and operational phases. The main issues relate to construction
impacts such as noise, dust and hindrance to road traffic during construction phase. The
process of impact prediction is the core of the environmental assessment process and it
is critical that the recommendations and mitigation measures are carried out during the
construction and operation of the sewer line in accordance with the ADB’s
Environmental Policy (2002) and Environmental Assessment Guidelines.2
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MFF an asbestos management framework (AMF) has been developed in tandem with
this IEE to provide guidance to CDGK and Karachi Water and Sewerage Board (KWSB)
on how to manage the excavation, handling, transport, storage and disposal of ACP from
the sewer and water subprojects and any other subprojects in Tranche 1 and future
tranches which may involve removal and disposal of asbestos containing materials.
14 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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Silt Disposal
50.The existing sewer line is choked and is likely to contain sewage and silt. As the
removal of the sewage material is likely to create odour and pose a hazard to the health,
a disposal plan for it will be developed. The plan will include measures to collect the
material immediately after its excavation, transfer it off site immediately in secure trucks
and dispose at one of the city landfill sites. Considering that the pipes are broken and
some sewage will have inevitably leaked into the surrounding earth the amount of
materials will be greater than the volume of the pipes. It is estimated that in excess of
1,000 m3 of the silt from the sewer and soil contaminated from pipe leakages would have
to be disposed. This would require more than 200 truck loads to remove all the silty
sewage and other contaminated soil material from site. The silt and contaminated soils
will all be removed from site on the same day they are uncovered. The lorries will be
lined with waterproof plastic or tarpaulin linings prior to loading and covered with
waterproof sheeting when loaded. Excavated materials will be transported to the
disposal site in trucks securely covered with tarpaulins or equivalent to prevent any
emission during transportation.
51.Operative staff will wear personal protective equipment provided free by the
Contractor during the work. This will include per operative and driver at least one pair of
waterproof boots, one pair overalls, one half face paper mask (disposed of daily at end
of shift) and one hard hats during all days when construction work is carried out.
52.The landfill sites in Karachi are mostly operating as dumping sites with only limited
provision for covering the material once it is disposed. Therefore it must be ensured that
the contractor is made responsible to dispose of the silt at the landfills and to cover and
mark these materials in location and in a manner that does not pose any hazard to the
waste pickers working at the site. These requirements would be put in contracts and be
included in a waste management plan. Safe disposal can than be achieved by covering
the material with fresh soil after disposal on a relatively hard ground. The contractor will
be made responsible to dispose of the silt at specific locations in the landfills and to
obtain a source of cover materials and cover the silt to a pre arranged depth and mark
the locations on site and on plan according to the Waste Management Plan agreed prior
to construction. The disposal will be monitored from cradle to grave using a trip ticket
system.
53.All roads within the vicinity (50 m) of the excavation shall be swept at the end of the
shift and any surplus residual silt and contaminated soil to be are to collected up and put
in waste drums or a waste skip. No residual excavated silt and contaminated will be
allowed to foul the pavements or to remain exposed overnight. Ths process will be
repeate nightly to reduce odour emissions until the roads are repaved and work is
completed. The work areas will also be sprinkled regularly with water to prevent dust
transmission (see above).
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55.The disposal vehicles will maintain a speed limit of 10 km/h or less on all corners
while traveling with full loads to avoid slopping of wet silt and contaminated soil over the
sides of the lorries. 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.
Traffic Disruption
57.The intersection of Dr Ziauddin Ahmad Road and Moulvi Tamizuddin Khan Road is a
major of traffic corridor for office commuters. Construction activities at the intersection
are likely to cause a major 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 maximise the safety of the workforce and the travelling public. The main secondary
objective will be to keep traffic flowing as freely as possible.
58.The Temporary Transport Management Plan will include consideration of the
following
i) Lane availability and minimise 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.).
59.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
60.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
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security, trench barriers, reflective signs and covers to other holes, hoarding plans and
any other safety measures as necessary.
Contingency Planning
61.It is also proposed that a contingency plan will be put 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, and power cables.
With the thorough identification of all utilities and correct planning for rerouting and re-
provisioning there should be no damage to other infrastructure. However in order to
cover any unforeseen disruption or disaster, the CDGK will convene a project utility re-
provisioning coordinating committee to meet with the contractor. Working with the
committee, the contractor will anticipate the likely disruptions, plan the work accordingly,
and prepare an effective utility management plan prior to the commencement of the
construction.
Asbestos Management
62.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 AMF (Appendix C) in conformance to the ADB’s Environmental Policy (2003)
and the Environmental Guidelines (2003). The AMF 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 an 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.
D Beneficial Effects
64.The key benefit is the effective disposal of wastewater that will lead to improvements
in hygiene, health, environment and sanitary conditions and consequent savings due to
overall improvements in environmental health.
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V. STAKEHOLDERS CONSULTATION
A Identification of Stakeholders
66.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 project. For this project, stakeholders are the people living close to the
pumphose and the people working in various buildings and businesses along the route.
Meetings were held along the sewer route.
B Consultations
67.The results of the public consultations are summarized below. The details are
recorded in Table 3.
68.The stakeholders did not express any particular concern about the design of the
subproject. The noise and dust from the construction activities was cited as a cause of
concern. The stakeholders were also concerned about the disruption to traffic. Other
issues raised included the disruption of utilities.
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Table 3: Summary of Public Consultation
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A Institutional Requirements
69.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). According to the regulation, “waste disposal facility for domestic or industrial
wastes, with annual capacity less than ten thousand cubic meters” requires an IEE.
However, as this project is a rehabilitation project and the EPA regulations exempt some
rehabilitation projects, such as the road, no IEE may be required.
70.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.
71.Therefore prior to implementation and commencement of construction of the sewer,
CDGK will need to notify the provincial EPA (SEPA) of the location and scale of the
proposed subproject and comply with any environmental requirements and, if IEE is
required, obtain approval “No Objection Certificates” and SEPA clearance (under the
Environmental Protection Act 1997).
72.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 Karachi15.. The AMF (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 Karachi.
73.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.
74.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
15 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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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 SEPA 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 SEPA for
publication in its annual report.
75.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.
76.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.
77.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
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.
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78.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.
79.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.
80.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.
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82.Construction of the sewer line will need to comply with several environmental
requirements and clearance will be required from SEPA for any statutory environmental
assessment that is required. DOE will also check 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).
83.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.
84.Prior to implementation of Tranche 1 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 sewer 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.
85.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 pre-
qualification, so that the environmental status of the sewer route is monitored to set a
baseline for benefit monitoring using some of the key EMP mitigation measures as the
performance indicator.
86.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
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.
87.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
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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.
C Monitoring
88.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 4 and 5) was designed based on the likely subproject cycle.
89.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 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.
90.Monitoring activities during project operation will focus on the volumetric flow of
sewage and its treatment.
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16 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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Table 5: Summary of Estimated Costs for EMP Implementation
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91.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.
92.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.
93.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.
94.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.
95.At the detailed design stage a review should be conducted of the monitoring activities
proposed in this IEE 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 from this study.
96.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
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 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.
97.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
98.Environmental impacts associated with the construction and operation of the Sewer
Rehabilitation need to be mitigated and institutional arrangements are available.
Additional human and financial resources will be required by CDGK to complete the
detailed designs and incorporate the environmental recommendations effectively and
efficiently in the contract documents, linked to payment milestones. The proposed
mitigation and management plans are practicable but require additional resources.
99.Monitoring activities will need to focus on compliance with license conditions,
recording implementation of mitigation measures, adherence to agreed waste disposal
practices, reviewing contractor environmental performance and proposing remedial
actions to address unexpected impacts.
100.The implementation of the Sewer Rehabilitation is a feasible and sustainable
environmental option but thorough implementation of the EMP is required throughout the
design, construction and operation of the Sewer in order to minimize impacts and retain
public support for the project.
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Shaheen Complex
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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp
Concern Implement MM Implement MM Implement MM Monitor MM
and disposal and that bidding contractors have capacity to comply
comply with ADB with AMF and other safety requirements.
ERP guidelines.
5. Waste Ensure sufficient 1. Before works commence selected contractor to 1. Within one The sewer route Design CDGK
Disposal disposal space prepare Waste Management Plan with disposal month of award consultant /
for waste sites identified for agreement by construction of contract or CDGK
materials and supervision consultants and CDGK. earlier.
avoid fly-tipping.
6. Permanent Avoid disruption 1. Identify all locations for drains that are to be 1. During Dr Ziauddin CDGK with the CDGK.
drainage to large drains crossed. designing stage Ahmad Road sc and design
protection. nearby at no later than pre- and any other consultant.
2. Design protection for works in sewer in line with
Dr Ziauddin qualification or vulnerable
worst case storm predictions.
Ahmad Road. tender locations to be
3. Contracts to specify locations and expected negotiations identified during
Include
mitigation measures. detailed design
preliminary 2. Include in the
stages.
designs in 4. Include reprovisioning in contracts as payment contract.
contract. milestone(s).
7. Traffic Plan to minimize 1. Avoiding blocking existing roads and access near During detailed The most Detailed design CDGK
Condition disturbance of the sewer route during construction. design. important engineer.
vehicular traffic locations to be
2. Design provisional temporary traffic management
and pedestrians identified and
plan for updating by the construction contractors
during listed in revised
one month prior to start of works in any given
construction. EMP. Relevant
sector.
plans to be
3. Installation of traffic warning signs, and enforcing made available
traffic regulations during transportation of materials to the Contractor
and equipment and machinery. with tenders.
4. Include plans for conducting awareness
programs on safety and proper traffic behavior near
sewer construction sites.
5. Plan requirements to assign dedicated traffic
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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp
Concern Implement MM Implement MM Implement MM Monitor MM
control personnel and assign diversion roads before
starting work on the excavation.
6. Prior to the conclusion of the detailed design
stage, modify plans as required to respond to any
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.
8. Look for Choose non polluting or enhancing methods. During detailed CSC/Tender CSC/Tender CDGK
Environmentally enhancement Contractor to submit Method Statement and design and evaluators to evaluators
responsible opportunities in schedule of environmental mitigation measures with compiling check
procurement design and tender. Enhancements, techniques and machinery contracts and contractors
construction. selection to minimize impacts and duration of during contractor Method
works. selection, prior to Statements
Avoid
contract signing. include sufficient
construction and Choose non polluting equipment
resources for
operational
Specify equipment not to contain persistent organic mitigation
environmental
pollutants, asbestos and other hazardous or toxic measures and
pollution.
components. correct timing in
tender/bids.
CONSTRUCTION STAGE
1. Plans to Avoid impacts 1. Temporary traffic management plan, Prior to To cover all the Contractor. CDGK.
control from unplanned construction sewer route.
2. Drainage and utilities re-provisioning plan,
environmental activities activity
and associated 3. Materials management master plan,
Submission to
impacts
4. Noise and dust control plan, ADB
5. Waste management plan;
should all be deliverable in final form by the
contractors one month before construction
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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp
Concern Implement MM Implement MM Implement MM Monitor MM
commences.
2. Orientation for Ensure that the Contractors tenders shall be required to separate Induction for all All site agent Contractor CDGK & to
Contractor, and CSC, Contractor clearly the resources and funds to be applied to the site agents and staff. monthly management observe and
Workers and and workers mitigation measures for environmental impacts. above including induction and six with the CSC to record
materials understand and all CSC staff new month refresher check monthly success.
Contractors tenders shall identify named staff to
management. have the capacity staff before course as and record
supervise and plan,
to ensure that the commencement necessary until details and
environmental Drainage and utilities re-provisioning of work. contractors report monthly
requirements and comply / in progress
Temporary traffic management, Weekly tool box
mitigation improve. reports
talks and
measures must Materials management, refreshers at
be implemented
Noise and dust control, early stages of
by them.
construction for
Waste management, all construction
Contractual clauses shall be included to tie the employees as far
implementation of environmental mitigation as reasonably
measures in the above plans to trigger milestone practicable.
payments. Include with
safety talks.
Contractual clauses shall require Contractors to
conduct induction briefing and / or on-site training
for the contractors’ management, contractors’ staff,
subcontractors and casual workers to cover the
environmental requirements of the project.
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
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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp
Concern Implement MM Implement MM Implement MM Monitor MM
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 promulgated 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.
The contractor shall be responsible for
implementation of an effective environmental
monitoring and reporting system using checklists of
all contractual environmental requirements and
EMP.
3. Exploitation To minimize and Contracts to include specifications for Update monthly 1. A list of routes Contractor and CDGK
handling, or avoid adverse of transport of CSC to agree
Move bulk materials at site off peak less busy
transportation environmental construction
times.
and storage of impacts arising material is to be
construction out of Maintain vehicles used in material transport and prepared for the
materials construction waste in good condition and covered with contract and
material handling, tarpaulins. agreed one
transportation month prior to
Update materials management plan monthly and
and storage. commencement
include in progress report of construction.
To minimize
contamination of
the surroundings
4. Institutional To ensure that Capacity building activities. Initiate during All senior staff in CDGK ADB
strengthening CDGK and PMU preconstruction CDGK at senior
Consolidation of the DOE or Setting up of a
and capacity officials are and continue engineer and
Executive District Officer, Environment Office within
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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp
Concern Implement MM Implement MM Implement MM Monitor MM
building trained to CDGK. beyond project above in PMU
understand and completion. and related
Development of a strengthening plan for the EDO.
to appreciate and units.
have the
resources to
apply the EMP.
5. Air quality To minimize air CONTOL ALL DUSTY MATERIALS AT SOURCE. 1. Before works The sewer route 1. The CDGK
impacts commence and Contractor
1. If works have given rise to complaints over dust,
effectively and weekly should maintain
the contractor shall investigate the cause and
avoid complaints throughout all the accepted
review and propose alternative mitigation measures
due to odour and construction standards.
before works recommence.
airborne works
2. CSC should
particulate matter 2. All heavy equipment and machinery shall be
2. Monthly monitor dust
released to the fitted in full compliance with the national and local
reporting in complaints,
atmosphere. regulations.
progress wheel washing
3. Stockpiled soil and sand shall be slightly wetted reports. and surface
before loading, particularly in windy conditions. wetting and
3. Report to
other relevant
4. Fuel-efficient and well-maintained haulage trucks allow inclusion in activities.
shall be employed to minimize exhaust emissions. PPR to ADB.
Smoke belching vehicles and equipment shall not 3. CDGK
be allowed and shall be removed from the project.
5. Vehicles transporting soil, sand other
construction materials or waste shall be covered
with tarpaulin sheets. Speeds of such vehicles shall
be limited to 15km/h within the works site
6. Removal of 1. To adopt ERP Asbestos cement pipes shall be carefully Update once a 1. The location of 2.CDGK DOE CDGK/
Asbestos Cement in line with ADB excavated, lifted on to plastic sheets, wrapped in month and report buffer temporary and CSC
CSC
Pipes (ACP) requirements. polythene and sealed with duct tape to be quarterly. store or should
transported to the designated storage area or permanent supervise and
2. To control the
landfill. disposal areas to take action to
release of
be identified by ensure
harmful asbestos The procedure shall follow the measures indicated
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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp
Concern Implement MM Implement MM Implement MM Monitor MM
fibres. below: detailed design completion of
engineer to be Contractor’s
3. To control Preparation
prepared at the relevant
disposal of ACP,
1. The CONTRACTOR shall implement all the contract stage activities
a hazardous
procedures in Appendix 2 of the AMF and make for agreement. according to
waste.
available all the materials in Appendix 3 of the AMF. environmental
standards in the
2. The CONTRACTOR shall agree to remove and
2. The records of AMF.
transport all the wrapped asbestos (ACP) from the
asbestos
sites to secure temporary buffer store(s) designated
abatement
by DOE - CDGK to await disposal.
activities and
3. The CONTRACTOR shall provide approved audit of waste
protective clothing to all workers and DOE – CDGK disposal
inspector as and when requested. quantities to be
reconfirmed and
4. Workers handling the asbestos cement pipes that disposal
shall wear the personal protective clothing area is available
provided. as identified by
5. The DOE - CDGK Asbestos Specialist inspector detailed design
shall visually inspect the preparation before engineer.
instructing the Contractor to proceed.
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.
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.
8. The DOE - CDGK Asbestos Specialist inspector
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Concern Implement MM Implement MM Implement MM Monitor MM
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.
7. Construction To minimize the WASTE MANAGEMENT PLAN TO BE Update once a 1. A list of 1. Contractor CDGK/
Waste Disposal impacts from SUBMITTED TO THE CSC AND APPROVED ONE month and report temporary
2. CSC should CSC
construction MONTH PRIOR TO STARTING WORKS. quarterly. dumping areas
supervise and
waste disposal. identified by
1. Estimating the amounts and types of construction take action to
detailed design
waste to be generated by the project. ensure
engineer to be
completion of
2. Identify opportunities for waste to be reused in prepared at the
Contractor’s
the project or by other interested parties. contract stage
relevant
for agreement.
3. Identifying potentially safe disposal sites close to activities
the project. OR THOSE DESIGNATED SITES IN 2. The list of according to
THE CONTRACT. waste sites to be environmental
reconfirmed and standards.
4. Waste shall not be burned - under any that dumping
circumstances. areas is
OPEN BURNING IS CONTRARY TO GOOD available as
ENVIRONMEMTAL PRACTICE. identified by
detailed design
engineer.
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Concern Implement MM Implement MM Implement MM Monitor MM
8. Safety To ensure safety 1. Providing adequate warning signs. During Relevant Contractor and CDGK/
Precautions for of workers and construction canteen and CSC
2. Providing workers with waterproof boots, skull CSC
the Workers and equipment. worker sanitation
guard or hard hat, mask, gloves and overalls.
first aid. facilities
3. Contractor shall instruct his workers in health and
Base height as
safety matters, weekly, and require the workers to
for equipment
use the provided safety equipment. Special focus
yards above
on handling
HFL.
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 site 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.
9. Traffic Minimize Submit temporary traffic management plan one Day time The most Contractor and CDGK/
Condition disturbance of month prior to start of works in any given sector. important Engineer
CSC
vehicular traffic & locations to be
- Formulation and implementation of a construction
pedestrians identified and
related traffic management plan . Assign traffic
during haulage of listed. Relevant
control personnel..
materials, spoil, plans of the
equipment & - Conducting awareness programs on safety and Contractor on
machinery. proper traffic behavior in densely populated areas traffic
near the construction sites. Plan to consider - 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
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Concern Implement MM Implement MM Implement MM Monitor MM
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
OPERATIONAL STAGE
NO significant
concerns
CDGK = City District Government Karachi CSC=construction supervision consultant DDC = Detailed Design Consultant PMU = Project Management Unit or Similar
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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).
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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 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.
5.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.
6.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.
7.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.
8.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.
9.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
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been considered early in the implementation at the detailed design stage and by using
the asbestos checklist so that necessary asbestos assessments are prepared (to
support preparation of EMPs for subprojects).
Table 1: Proposed MFF Subprojects
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be labeled and safety procedures instigated to prevent disturbance, until such time as it
can be removed safely.
13.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.
14.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.
15.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”.
16.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.
17.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.
18.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).
19.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).
20.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.
21.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.
22.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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28.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
needed. ADB will also be responsible for reviewing regular monitoring reports and
officially disclosing the any aspects of on the ADB website if required.
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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.
E Institutional Arrangements
34.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.
35.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.
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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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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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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
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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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