NGO MANS’s general comments on environmental impact assessment study on the construction of thermal power plant Pljevlja

ENVIRONMENTAL PROTECTION AGENCY
P O D G O R I C A

NGO MANS’S GENERAL COMMENTS ON

ENVIRONMENTAL IMPACT ASSESSMENT STUDY ON THE CONSTRUCTION OF THERMAL POWER PLANT PLJEVLJA 

• It is unclear why the public debate on the Environmental Impact Assessment Study is being held if taking into account the uncertainty of the project of construction of Unit II, due to problems of finding a financier
• The document contains contradictory information as to whether the construction of Unit II of the thermal power plant is planned for covering the electricity deficit in Montenegro or to export electricity to the region, especially to Italy
• The study did not examine the actual alternative scenarios, such as the production of electricity through the construction of a biomass power plant, wind power plants, solar panels, etc.
• Raw material for the new thermal power plant in Pljevlja has not been confirmed, so it remains questionable whether the inner Pljevlja basin has enough coal reserves for 40 years of operation of Unit II
• The Environmental Impact Assessment Study shows inaccurate information on the current employment in Rudnik uglja Pljevlja (Coal Mine Pljevlja) and the existing thermal power plant Pljevlja
• The document contains conflicting information as to whether and when the environmental remediation of the existing Unit I of thermal power plant is envisaged
• On a few occasions the study mentions a district heating system in Pljevlja, which is not only unlikely to be realized, but it is not an integral part of the project of construction of Unit II of the thermal power plant
• The document contains a series of arbitrary, outdated and incomplete data about the real causes and pollution level in Pljevlja
• It is unacceptable that the authors of the Study have not answered the question regarding the impact of the existing power plant Pljevlja on the health of its citizens
• The best technology solution for Unit II has not been provided and it is questionable whether it will meet the new limit values set ​​for pollutants and particulate matter, which should be adopted within the European Union in 2017
• The authors of the study accept a ready-made solution – to dispose ash and slag on the existing open pit Potrlica, although this solution has not been discussed at a public debate, and the question whether this would mean an illegal state aid granted to Rudnik uglja Pljevlja has been also raised
• The document contains incomplete information about possible incidents that may occur due to blockages in the filters or removal of the dam Otilovici
• The study does not tackle the issue of cross-border impact of the construction of Unit II of the thermal power plant
• The document should be revised, whereas a public debate over the DPP and SEA should be held before the revision so as to discuss the proposed solution of conveying flue gases in the atmosphere through the cooling tower of the new unit

NGO MANS’S DETAILED COMMENTS ON

ENVIRONMENTAL IMPACT ASSESSMENT STUDY ON THE CONSTRUCTION OF THERMAL POWER PLANT PLJEVLJA 

1. Environmental Impact Assessment Study contains contradictory information as to whether the construction of Unit II of the thermal power plant is planned for covering the electricity deficit in Montenegro or to export electricity to the region, especially to Italy.

When defining the object and purpose of the project, the page 29 states the following: “The company Elektroprivreda Crne Gore (Montenegrin Electric Enterprise) wants to build a new thermal power plant to cover the electricity needs in Montenegro, which are projected for the period up to 2050″, then points out that the reason for the construction and “export of electricity to the region, especially to Italy, after installing and launching the HVDC submarine cable,” and as one of the priority goal to be attained is ” elimination of the current electricity deficit in Montenegro. “

The said is contradictory, because it is claimed that export of electricity is envisaged, whereas on the other hand, the electricity deficit, which did not exist in 2016, is given as the reason for building a new power plant, which in the course of 2016 in Montenegro did not exist.

2. Environmental Impact Assessment Study did not examine the actual alternative scenarios, such as the production of electricity through the construction of a biomass power plant, wind power plants, solar panels, etc. 

As an alternative scenario to building a 254 MW-Unit II of the thermal power plant in Pljevlja the authors of the document offered to build a coal power plant with a greater power, which shows that this is not a real alternative proposal but a mere pro-forma solution prescribed by the Law on Environmental Impact Assessment.

Thus, the authors failed to offer other models as real alternative scenarios, such as construction of biomass power plants, wind power plants, solar panels and the like.

3. Raw material for the new thermal power plant in Pljevlja has not been confirmed, so it remains questionable whether the inner Pljevlja basin has enough coal reserves for 40 years of operation of Unit II

The Environmental Impact Assessment Study, in Mining Reserves of Coal (page 34), does not give tabulated data on mining reserves of coal in tons in the so-called inner Pljevlja basin, nor in the individual deposits.

In this way, the information which should confirm whether there are sufficient coal reserves for the operation of the new thermal power plant is hidden from the public. It is unacceptable that the authors of the study state that the coal reserves in Pljevlja basin will be fully exploited, without supporting it with the data on coal reserves.

Furthermore, on page 37 of the document the authors state that the available coal reserves in the inner Pljevlja basin are crucial for selecting the optimal power of 254 MW for 40 years of operation of Unit II, even though a number of earlier published documents have stated that the available coal reserves in the inner Pljevlja basin are crucial for selecting the optimal power of 220 MW for 40 years of operation of Unit II.

So, the relevant information which would clearly confirm that the actual coal reserves in the inner Pljevlja basin are sufficient for a 40-year period of operation of the new thermal power plant is missing.

Additionally, the table is given on page 55 according to which for the operations of Unit I and Unit II 87,512,857 tons of coal will be required, but further it is stated that the coal reserves are 164,987,781 tons (Pljevlja basin: 66,822,297 tons, mine Maoce: 90,667,500 tons; mine Mataruge: 7,497,984 tons).

The abovementioned implies that the mine Maoce will be open and that there are not enough coal reserves in the Pljevlja basin for the operating of Unit II for a whole period of 40 years, whereas the document itself states that the distance of the mine in Maoce is such that a conveyor belt for coal transport is practically out of the question, but the coal needs to be transported by trucks, which would ultimately increase the cost of the total investment. 

4. The Environmental Impact Assessment Study provide inaccurate information on the current employment in Rudnik uglja Pljevlja and the existing thermal power plant Pljevlja

The Environmental Impact Assessment Study, in Existing Operations, on page 15 states: “The mine provides employment for about 1,100 workers,” as well as that “there are more than 400 employees in Elektroprivreda in the Municipality of Pljevlja.”

This data is inaccurate. According to the information from the website of the Securities Commission of Montenegro, Rudnik uglja Pljevlja employed 872 workers at the end of June 2016, while the data collected by the MANS Investigation Centre shows that  at the end of 2014 the existing thermal power plant provided jobs for 207 workers. 

5. The document contains conflicting information as to whether and when the environmental remediation at the existing Unit I of thermal power plant is envisaged 

The Introduction to the Environmental Impact Assessment Study states that “The plan is to carry out a full environmental remediation of TPP I and after TPP II becomes operational: installation of the system DeSOx, DeNOx and waste water treatment system.”

Furthermore, page 171 shows a table with the limit values for pollutants and particulate matter in the air after “possible remediation of Unit I of the TPP Pljevlja”, while the graphs on page 173 show that Unit I will be operational until 2026, and the launch of Unit II is projected in 2019.

The said indicates the contradictions regarding the Unit II rehabilitation plan, i.e. whether it will ever be remediated, and when the remediation is projected. 

6. It is perplexing that coal-burning stoves in households which annually consume about 100,000 tons of coal are claimed to be the root cause of pollution in Pljevlja, while it is not at all mentioned that the biggest polluter is the existing thermal power plant, which annually consumes about 1.6 million tons of coal, as stated in earlier documents. 

The Environmental Impact Assessment Study, in Climatic Characteristics, on page 26 states that: “Due to long and cold winters, the heating season lasts at least 6-7 months. Local boilers or coal-burning stoves use coal as a primary heating fuel. It is estimated that during winter in Pljevlja over 100,000 tons of coal is used for the purpose of heating. Currently, central heating in Pljevlja is limited to downtown buildings. This heating system receives heat energy from the outdated, inefficient coal-fired boilers, which are located in basements of the buildings. They are controlled manually and there is no emission control equipment, which leads to the high pollution level. “

From the above mentioned it appears that the principal cause of the pollution in Pljevlja are coal-burning stoves in households, which annually use about 100,000 tons of coal, while the document fails to mention that the biggest polluter is the existing thermal power plant, which annually uses about 1.6 million tons of coal, as stated in earlier  documents. 

7. Authors of the Environmental Impact Assessment Study do not offer relevant evidence, but claim that when it comes to the pollution level in Pljevlja the impact of the existing thermal power plant is smaller than the pollution caused by coal-burning stoves in households.

Part of the document focusing on the quality of air and immissions (pages 115-119) states the following: “Maximum daily values of PM10 exceeded the prescribed limit value of 50 ug/m3 during 189 days( out of 360 days of valid measurements), while maximum daily values exceeded the margin of tolerance of 90 ug/m3 during 121 days. A permitted number of exceedances is 35. An average annual concentration (annual average), which amounted to 99.8 ug/m3 was above the prescribed standards (40 ug/m3). Based on the measured values, it can be concluded that there is a high concentration of PM10 in the air in Pljevlja, not only based on the measured values, but also because of large number of exceedances. “

The presented data relates to 2015, and the document further states: “The measured concentrations of particulate matter  primarily reflect the impact of coal-burning stoves in households on overall pollution, as well as contribution from vehicles and other sources, and to a lesser extent the impact of TPP Pljevlja. “

Given that the overall pollution in Pljevlja is at issue, it is unclear how the claim that the thermal power plant has smaller impact on the overall air pollution has been made, especially as the unlawful exceedances occurred out of the heating season, as well.

8. On a few occasions the study mentions a district heating system in Pljevlja, which is not only unlikely to be introduced, but it is neither an integral part of the project of construction of Unit II of the thermal power plant.

The Environmental Impact Assessment Study mentions a heat-only boiler station on page 44, stating that: “A heat-only boiler station will provide hot water, which is mainly used for heating, for the district heating system for Pljevlja and the suburban area. According to the heat consumption and taking into account the projected heat consumption for the future, the heat-only boiler station of Unit II is planned with a rated capacity of 75 MWth in the regime 130/65 C. In case of unavailability of Unit, up to 25 MWth can be provided through using steam from the auxiliary boiler room. “

Furthermore, page 187 states: “By introducing district heating in accordance with the DPP TE Pljevlja (create conditions for the realization of the first stage of the heating system of Pljevlja) it is possible to effectively reduce air pollution.”

The said shows that the project of the district heating of Pljevlja is unlikely to be realized, because the rated capacity which is at stake is 75 MWth and 25 MWth, which will certainly depend on an investor, but it is also unclear why the authors in the overall assessment of the reduction of air pollution even refer to the district heating system, when it is not part of the project of constructing Unit II.

9. Authors of the Environmental Impact Assessment Study do not tackle the causes that led to the enormous drop in the number of inhabitants in Pljevlja, which particularly coincides with the period from the beginning of the thermal power plant’s operating in the city, and it can be realistically assumed that the construction Unit II would lead to even more drastic decline in the population of this city. 

The Environmental Impact Assessment Study, in Population, on page 27, states: “Pljevlja has a population of 28,595  – based on the Monstat’s estimate for 2015, i.e. 4.6 percent of the Montenegrin population. Compared to the 2011 census, the population (in just 4 years) decreased by almost 2,200 (7 percent). In 1981 Pljevlja had a population of 43,316. “

The existing thermal power plant began operating in 1982, which means that in the period that coincides with the operating of Unit I the population in Pljevlja declined to 14,721, or by 34 percent, i.e. by a third. It is obvious that the work of the existing thermal power plant has had an extremely negative impact and influenced inhabitants of Pljevlja to leave their hometown. Taking this trend into consideration, the operations of the new unit will cut in half the population of Pljevlja. In this regard, it is completely incomprehensible that the authors of the study fail to mention the causes that led to such a large decline in the population.

10. Authors of the Environmental Impact Assessment Study fail to explain why Pljevlja has a higher mortality rate compared to the rest of Montenegro.

In part of the document relating to the population, page 61 states: “The death rate, which ranged from 6.9 percent to 14.8 percent from 1991 to 2015, is higher than the average mortality rate in Montenegro (9.4 percent in 2015) and it is among the highest ones in the country’s municipalities. According to the Monthly Statistical Review (September 2016) in the first nine months of 2016, 123 infants were born whereas 261 people died. “

The authors do not give reasons for such a high mortality rate and to which extent the existing thermal power plant has contributed to it.

11. It is unacceptable that the authors of the Environmental Impact Assessment Study do not answer the question about the impact of the existing Thermal Power Plant Pljevlja on the local population’s health. 

The Description of Segments of the Environment, in part relating to the local population’s health, on page 63, states: “Due to the characteristics of the area, i.e. the fact that this is the area of pollution (mine and thermal power plant) it might affect the population’s health (SO2, particulates, etc.). There have been no regular monitoring of the environmental factors, nor their effect on human health, and that is the area which is covered to a large extent by the environmental health protection. “

It is unacceptable to associate the health of Pljevlja population with the pollution from the thermal power plant and the coal mine only arbitrarily, randomly and in a disparaging manner. This is extremely frivolous approach since the relevant information about the effects of these pollutants on human health is not given.

In addition,  the data on cancer and respiratory illnesses are out of date (the latest data are from 2012), and is particularly unacceptable that, although the number of these diseases grows from year to year, it is arbitrarily stated that the number of patients with cancer increased due to various causes, such as smoking, air pollution in winter, inadequate nutrition. The actual causes of the increased number of patients suffering from these diseases are not given, so it actually appears that the thermal power plant and Rudnik uglja in Pljevlja do not contribute to the increased number of patients with these diseases.

12. Environmental Impact Assessment Study does not include modeling health impact of constructing Unit II of the thermal power plant in Pljevlja on the local population.

In the part of the study which refers to the impact of the Unit II project on the population in Phase of Use, page 155 states: “The effects will be positive due to preserving or increasing the number of jobs (about 50 jobs). Due to the use of modern technology (remediation of Unit I and the best available technique BAT for Unit II) the pollutant emissions will be reduced so the significant improvement in air quality is envisaged, particularly when it comes to SO2 and dust, i.e. particles. This will have a positive effect on health of the local population, as well. In terms of health it is necessary to highlight the problem of pollution (especially the air pollution) due to use of coal for heating in households (particulate matter), but that the situation will improve significantly due to the construction of the heat-only boiler station for district heating of Pljevlja and its suburban area. “

The claim that employment will rise has not been supported, especially as the remediation of Unit I (as stated in the Introduction to the Study) is envisaged before the construction of Unit II, and by that time Unit I will have to be shut down in accordance with the regulations of the European Union. Also, it is not certain that the project of constructing the heat-only boiler station for district heating of Pljevlja will be realized and it is not even an integral part of the project of construction of Unit II of the thermal power plant in Pljevlja.

Furthermore, instead of using some of the existing models for analyzing health effects with the quantification of health effects, the authors used an assessment scale (0-4), which is subject to a subjective assessment, and it is also not clear which indicators were used for evaluation. Modelling Unit II health effects of pollutant emissions and particulate matter, which must be made within a radius of 500 kilometers, has not been carried out, taking into account that part of the harmful gases go across borders and greatly impact the environment.

It is necessary to carry out the health impact assessment, which will include a minimum: 1) the age specific mortality rate for persons older than 30 years of age 2)  all mortality rates, 3) postneonatal infant mortality rate, 4) hospitalization for respiratory diseases, 5) hospitalization for cardiovascular disease 6) bronchitis incidence in children, 7) chronic bronchitis incidence in adults, 8) days with restricted activity, 9) working days lost 10) asthma symptoms in asthmatic children.

It is necessary to make an analysis of the cumulative health impacts per each year of operation of Unit II. Earlier studies by international organizations HEAL showed that the new plant in Pljevlja, if in accordance with applicable regulations, will cause 15 deaths annually, or 600 for 40 years of operation of Unit II.

In addition, it is necessary to classify and analyze the health effects of other pollutants, such as mercury and other heavy metals that are emitted in the air.

13. The authors of the Environmental Impact Assessment Study have not acknowledged the latest situation concerning international obligations in the area of climate changes, i.e. the signing of the Paris Agreement on Climate Change and new commitments on reduction of greenhouse gases emissions.

Page 119 of the document contains the information about the United Nations Climate Change Conference held in 2011 in Durban, South Africa. Meanwhile, in December 2015, Paris Agreement on Climate Change was signed, which officially became effective on 4 November 2016. The Agreement provides for the obligation of signatories to reach net zero emissions of greenhouse gases in the second half of this century.

The abovementioned fact has not at all been taken into account, but the document contains the outdated information and the old data from the National Greenhouse Gas Inventories until and including 2009.

14. The Environmental Impact Assessment Study shows that the best technology solution for Unit II has not been provided and it is questionable whether it will meet the new limit values set ​​for pollutants and particulate matter, which should be adopted within the European Union in 2017.

Page 52, which refers to the analysis of different alternatives in the field of technical and technological solutions states that the planned net efficiency of Unit II is 39.5 percent, which does not meet the criteria of the European Union, which requires a higher degree of efficiency for the projected technology (PC).

Furthermore, page 170, Current and Projected Emissions states that: “It is necessary to carry out an adequate environmental remediation of the existing Unit (improvement of the existing electrostatic precipitator in order to meet the ELV of 10 mg/Nm3, installation of dry flue gas cleaning system in order to reduce SO2 emissions below 150 mg/Nm3, installation of selective catalytic reduction of NOx to limit NOx emissions below 200 mg/Nm3) and other measures. “Then page 171 shows a table with the limit values ​​for pollutants and particulate matter in the air after “possible remediation of Unit I,” and page 172 states: “The exact date of possible opening of the existing Unit after adequate remediation will be subsequently determined and it depends on a decision on the approval of the opt-out, as well as ways of distribution of 20,000 working hours by the operator. “In addition, the graphs (page 173) show that Unit I will operate by 2026, whereas launching of Unit II is projected from 2019.

 The abovementioned brings up a question whether remediation of Unit I has been planned at all, since the term “possible remediation” is used, and the Introduction to the Study indicates that a complete remediation of Unit I will be carried out after the construction of Unit II. Also, the decision on the opt-out option has been adopted at the meeting of the Ministerial Council of the Energy Community on 14 October 2016, which essentially means Unit I will be operating until 2023, so the question why invest heavily in environmental remediation of the existing Unit  if it will soon shut down has been raised.

In addition, the data on the years of operating of Unit I and Unit II of the thermal power plants that are shown in the graphs are completely contradictory. Finally, no attention has been paid to the fact that the European Union is to adopt new conclusions in the future regarding Best Available Technics (BAT) which will lay down new limit values ​​for pollutants and particulate matter in the air, which would in practice mean that Unit II, with the current limit values ​​for pollutants and particulate matter, could violate rules that are yet to be adopted in the years to come.

15. The Environmental Impact Assessment Study prescribes a completely new technological fix for conveying flue gases in the atmosphere, which was not provided in the Detailed Spatial Plan and Strategic Environmental Impact Assessment of the TPP Pljevlja. 

The Introduction to the Environmental Impact Assessment Study stipulates that the “flue gases are conveyed into the atmosphere through the cooling tower of the new Unit.” This technological fix was not defined in the Detailed Spatial Plan nor the Strategic Environmental Impact Assessment of the TPP Pljevlja, which were discussed at a public debate in 2015. 

Given that this is a technological shortcut that has not been discussed at a public debate, and that it is not known how such technological solution increases the level of pollution in Pljevlja, it is necessary to withdraw the Environmental Impact Assessment Study from the procedure, and then organize another public debate on the Detailed Spatial Plan and the Strategic Environmental Impact Assessment that will prescribe the said technological fix, so as the interested public could express its views on its advantages and disadvantages.

16. Measures prescribed to mitigate harmful emissions in the air are not sufficient.

Page 174 of the Impact Assessment Study – Current and Projected Emissions into the Air – Model Scenarios, states: “The mitigation measures that are recommended to reduce the negative environmental impacts associated with the emission of pollutants into the atmosphere, relate to the provision of a system for monitoring air quality, applying good practice relating to earthwork, material transport systems, including road transport, loading/unloading, and storage/disposal facilities.”

Prescribing measures on providing an adequate system for monitoring air quality in itself is not practical, unless the technology that would meet the criteria of the best available techniques for the power plant’s operations is designed.

17. The document contains incomplete information about possible incidents that may occur due to blockages in the filters or removal of the dam.

The Environmental Impact Assessment Study, in Prescribed Measures for Preventing, Reducing or Detecting Adverse Effects, on page 156, states: “Incidents, i.e. the impact on the population may occur due to blockages in the filters, where the environment could be polluted due to ash deposition in the event of removal of dam Otilovici, as well.” It is further indicated that:”  Measures concerning protection of the population are given in the internal documents – Emergency Response Plan – Instructions for Repairing Damages in TPP Pljevlja, Water Wave Propagation in Case of Removal of Dam Otilovici, Informing and Alerting Inhabitants Downstream from Dam Otilovici, Determining Safe Reservoir Level at Otilovici, Water Wave Propagation in Case of Removal of  Dams from Otilovici to dam tailings disposal site Suplja stijena and Fire Protection Plan. “

Given the seriousness of such an issue, just mentioning briefly possible incidents is completely insufficient and wrong, and the citizens of Pljevlja should be given the full information concerning a possible threat, when it can occur, under what conditions, precise protective measures, etc.

18. It is unclear whether the wastewater treatment system is an integral part of the project of construction of Unit II of the thermal power plant. 

Page 109 of the Environmental Impact Assessment Study, referring to the waste water treatment, states: “Energoprojekt Entel a.d. made the preliminary design Wastewater Treatment for the existing Unit of TPP Pljevlja.”

From the said it is not clear whether the wastewater treatment plant is part of the project of Unit II of the thermal power plant.

19. Authors of the Environmental Impact Assessment Study accept a ready-made solution – to dispose ash and slag at the existing open pit Potrlica, although this solution has not been discussed at a public debate, and the question whether this would mean an illegal state aid granted to Rudnik uglja Pljevlja has been also raised.

Page 40 of the Environmental Impact Assessment Study, in Technological Fix for New 254 MW-Unit- Disposal of Products of Combustion and Desulphurization, states: “Unit II will produce ash and slag as by-products of combustion, and gypsum as a by-product after flue gas cleaning. All these by-products can be disposed or used as backfill materials for an excavated area (reclamation), or they can be disposed of on a separate landfill or used for backfilling a separate landfill. Anyway, the example of this is the mine Potrlica as the only active one for a longer period within Rudnik uglja Pljevlja.“

The authors refer to the pit Potrlica as the location for a new ash and slag landfill, although this solution has not been discussed at a public debate. In addition, the Mining Law of Montenegro stipulates the obligation for companies to reclaim mines after exploitation. The fact that the mine Potrlica could serve as a new landfill for disposal of ash and slag would mean that Rudnik uglja Pljevlja does not bear mine rehabilitation costs, so the question whether this would mean an illegal state aid granted to Rudnik uglja Pljevlja has been raised.

Also, it is open to question why the authors of the Study fail to mention the location Sumani as the site for a new landfill, which EPCG bought earlier for the price of €7.5 million from Rudnik uglja Pljevlja – for the purpose of opening a new landfill for ash and slag disposal.

20. The Environmental Impact Assessment Study implies that ash and slag are classified as non-hazardous, but essentially they are considered hazardous waste.

The Environmental Impact Assessment Study, in Waste Management in the Municipality of Pljevlja, Quality of Ash, Slag and Sludge from the TPP Pljevlja, on page 146, indicates that: “In 2012, solid waste from the TPP Pljevlja was tested by the Ecotoxicological Examination Center – Podgorica. According to the analysis of toxic and hazardous materials all samples are considered as non-hazardous waste that can be landfilled, although their pH value is over 11, because the Rulebook does not prescribe a pH value as one of the hazardous properties H1-H15 or H14 from the List of hazardous materials. “

The abovementioned implies that essentially this can be considered hazardous waste.

21. Presented data on contamination of soil with toxic and carcinogenic organic compounds caused by operations of the thermal power plant are outdated and do not show the real level of pollution.

The Environmental Impact Assessment Study, in Toxic and Carcinogenic Organic Compounds in Soil, on page 80, states: “Based on the analysis of samples in the Municipality of Pljevlja, higher level of polycyclic aromatic hydrocarbons in relation to OELs were found only on two sites – Vilici 1 and Deponija 1, whereas the said compounds show the growing trend compared to the previous years.”

The source of these data is a document Sterbenk and Kotnik from 2007. So, this document is 10 years old and it is not clear what has happened in the meantime, so it is questionable to which extent the data is relevant today.

22. The Environmental Impact Assessment Study contains contradictory information on the rehabilitated land in Pljevlja, which was badly damaged by coal exploitation.

The Environmental Impact Assessment Study, in Soil Quality, on page 75, states: “The highest percentage of permanently lost land is in the  wider area of Pljevlja, as a result of the construction of large industrial facilities (TPP Pljevlja, cement factory with crushing plants, wood processing company  Vektra Jakic, factory Gradjevinar) and the dam Otilovici … In the open pits Potrlica and Borovica over 10 percent of the exploited land was rehabilitated, whereby the rehabilitation after flattening, compacting and leveling ground is based on applying biological measures of afforestation and planting certain plant species. “

In addition, the Study, in Industrial area, on page 123, states: “The biggest mine-Potrlica covers the central part of the Cehotina’s valley, which is why the riverbed was relocated … So far, the coal from the area of over 300 ha was excavated and half of the area was rehabilitated. “

The abovementioned data is contradictory, since firstly it is mentioned that 10 percent of exploited areas was rehabilitated, and then it is claimed that so far half of the used sites at the mine Potrlica were rehabilitated, although no data is provided to support this claim.

23. It is unclear why the document refers to groundwaters and water levels in Maocko polje when coal exploitation from the so-called inner Pljevlja basin is envisaged for Unit II operations.

 

The Environmental Impact Assessment Study, in Groundwaters, on page 85, states: “In times of high water levels of rivers Drijeljevine and Maocnica, when a large part of Maocko polje abounds in groundwaters and surface waters, the maximum water inflow in the reservoir Otilovici from the basin of Maoce is about 4.7 m3/s. In this case, extraction of coal will be certainly related to the resolving the hydrological problems, which will require intense drainage and preventing water inflow in the open pit. These activities can greatly increase exploitation costs. It is therefore necessary to carry out additional analyses at the site Maoce, which would allow greater insight into the conditions of exploitation and a more reliable final decision on the use of this deposit. “

It is unclear why Maoce deposit is even mentioned in the document if operating of Unit II of the thermal power plant in Pljevlja is based solely on the exploitation of coal in the inner Pljevlja basin.

24. The Environmental Impact Assessment Study contains outdated data on groundwaters and surface waters pollution caused by the thermal power plant. 

The Environmental Impact Assessment Study, in Pollution of Surface Waters Caused by Discharges from the Thermal Power Plant, on pages 92-99, states: “Based on the results presented in the table, it can be concluded that the Thermal Power Plant’ wastewaters directly affects the quality of water in river Vezisnica and Paleski potok, whereas their waters affect the quality of water in the river Cehotina downstream from the Vezisnica’s mouth.” In regard to the river Cehotina, it is stated that its watercourse upstream from the city is Class I and downstream from Pljevlja  Class II, says:” Unfortunately, the Hydrometeorological Institute’s monitoring program does not cover heavy metals and organic toxicants in order to assess the possible impact of emissions from thermal power plant “, while the data from 2006 are given in the further text.  In addition, the data from 2006 are provided for the river Vezisnica and it is that noted: “The difference in the water quality of the river Vezisnica before and after Paleski potok flows into it with the discharges from the plant are not radical, but it should be noted that the sampling was carried out during the period when the level of water was high and a significant decrease of pollutants’ concentration occurred.”

From the said, it is clear that the real level of the groundwater pollution caused by the discharges containing heavy metals and organic toxicants from the thermal power station is not known, instead the outdated data from 2006 is given. Also, it is not clear whether the Regulation on Classification and Categorization of Surface and Groundwaters (Official Gazette of Montenegro 02/07) is in line with the European standards.

Furthermore, in Groundwaters Pollution, on pages 101-105, it is stated: “Analyses of groundwaters from piezometric wells around the landfill at Maljevac aimed at assessing the impact of the landfill waters on ground waters has been carried out. The waters from all tested wells share very similar qualities. In fact, all the waters have extremely high turbidity level, high conductivity, high concentration of suspended solids, extremely high concentration of dissolved iron, zinc, sulfate, manganese, ammonia and the high value of COD and low dissolved oxygen concentration. These waters are very aggressive. “Then a table with data from 2006 is given.

Therefore, these data are very outdated and since that period the situation has remained unknown.

25. Data on noise measurement is not relevant. 

 The Environmental Impact Assessment Study, in Noise and Vibrations, on page 13, states: “The measurements of the existing environmental noise on the site of TPP Pljevlja were made in 2008, when the Rulebook on Limit Values of Environmental Noise Level was valid (Official Gazette 75/06). Since Rulebook on Limit Values of Environmental Noise Level, Manner of Determining Noise Indicators and Acoustic Zones and Methods for Estimating Harmful Noise Impacts (Official Gazette 60/11) is in force, the measurement results cannot be directly compared to the current Rulebook. “

From the above mentioned it is clear that the data on the noise measurements which is shown in the document is not relevant.

26. The Environmental Impact Assessment Study does not tackle at all the issue of cross-border impact of the construction of Unit II of the thermal power plant in Pljevlja.

It is unknown why the authors have not explored the issue of cross-border impact of the construction of Unit II of the thermal power plant.

MANS INVESTIGATION CENTER
Coordinator Ines Mrdovic
Podgorica, 17 November 2016