IEE Sewer - Mar 29, 2008

Karachi Water and Sewerage Board
City District Government Karachi
Karachi Mega City Sustainable Development Program
Initial Environmental Examination

Dr Ziauddin Ahmad Road Sewer Line
Rehabilitation
Document Stage: Final Report

Document Date: March 29, 2008
The initial environmental examination is a document of the

borrower. The views expressed herein do not necessarily
represent those of ADB’s Board of Directors, Management, or
staff, and may be preliminary in nature.
Karachi Mega City Sustainable Development Program MFF Tranche 1
IEE Report for Dr Ziauddin Ahmad Road Sewer Line Rehabilitation Subproject
Contents
I. INTRODUCTION.......................................................................................5
II. DESCRIPTION OF THE SEWER LINE SUBPROJECT.........................7
III. DESCRIPTION OF ENVIRONMENT....................................................10

Physical Environment.......................................................... .........................10
Biological Environment............................................................................... ...11
Social and Cultural Environment............................................................ .......12
IV. ENVIRONMENTAL IMPACTS AND MITIGATION................................15

Dust Impacts during Construction................................................... ..............16
Silt Disposal..................................................................................... .............17
Odour Impacts during Construction.................................. ............................17
Noise during Construction.......................................................................... ...18
Traffic Disruption.................................................................................. .........18
Public Safety.......................................................................................... .......18
Contingency Planning...................................................................... .............19
Asbestos Management............................................................. ....................19
V. STAKEHOLDERS CONSULTATION.....................................................20
VI. INSTITUTIONAL REQUIREMENTS AND

ENVIRONMENTAL MANAGEMENT PLAN.......................................22
VII. FINDINGS AND RECOMMENDATIONS.............................................29
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
Figure 1: Karachi Drains............................................................................8
Figure 2: Proposed Sewer.........................................................................9
Tables
Table 1: Ambient Air Quality in Karachi (µg/m3)...................................11
Table 2: Population of Karachi................................................................13
Table 3: Summary of Public Consultation.............................................21
Table 4: Environmental Monitoring Plan for Tranche 1 Subproject....27
Table 5: Summary of Estimated Costs for EMP Implementation.........28
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LIST OF ABBREVIATIONS
ACP Asbestos Cement Pipes

ADB Asian Development Bank
AMF Asbestos Management Framework
CDGK City District Government Karachi
CSC Construction Supervisory Consultant
DCO District Coordination Officer
DDC Detailed Design Consultants
DOE District Officer Environment
EARF Environmental Assessment and Review Framework
EDO Executive District Officer
EIA Environmental Impact Assessment
EMP Environmental Management Plan
EPA Environmental Protection Agency
GER Gross Enrolment Rate
GoP Government of the Islamic Republic of Pakistan
IEE Initial Environmental Examination
KMCSDP Karachi Mega City Sustainable Development Program
KWSB Karachi Water and Sewerage Board
MFF Multi-tranche Financing Facility
MMP Materials Management Plan
NEQS National Environmental Quality Standards
NOX Oxides of Nitrogen
Pak-EPA Pakistan Environmental Protection Agency
REA Rapid Environmental Assessment
RoW Right-of-Way
RRP Report and Recommendations to the President
SEPA Sindh Environmental Protection Agency
SO2 Sulphur Dioxide
SR Sensitive Receiver
TA Technical Assistance
WEIGHTS AND MEASURES
dB(A) Decibel (A-weighted)

ft Feet/Foot
km kilometre
km/h kilometre per hour
m meter
m3 cubic meter
m2 square meter
mgd million [imperial] gallons per day
s seconds
LAWS AND REGULATIONS
IEE-EIA Regulations 2000 Pakistan Environmental Protection Agency Review

of Initial Environmental Examination and
Environmental impact Assessment Regulations
2000
PEPA 1997 Pakistan Environmental Protection Act 1997
SLGO 2001 Sindh Local Government Ordinance 2001
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I. INTRODUCTION
1.Government of Pakistan (GoP) has requested the Asian Development Bank (ADB) to
provide a multi-tranche financing facility (MFF) to facilitate investments to support the
proposed Karachi Mega City Sustainable Development Program (KMCSDP, the
Program). The KMCSDP will implement a number of subprojects within seven
components including: support to institutional reform and development; waste supply
and wastewater management; urban roads, traffic and transportation; improvement of
katchi abadi (squatter settlements) and assistance in housing for the poor; public
awareness and outreach; investment program management and engineering support.
2.This Initial Environmental Examination (IEE) presents the environmental assessments
of the 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.
A Environmental Regulatory Compliance

4.Section 12(1) of the Pakistan Environmental Protection Act 1997 requires that “No
proponent of a project1 shall commence construction or operation unless he has filed
with the Federal Agency2 an initial environmental examination or, where the project is
likely to cause an adverse environmental effect, an environmental impact assessment,
and has obtained from the Federal Agency approval in respect thereof.”
5.The Pakistan Environmental Protection Agency Review of Initial Environmental
Examination and Environmental Impact Assessment Regulations, 2000 (IEE-EIA
Regulations 2000) provide the necessary details on the preparation, submission, and
review of the IEE and the environmental impact assessment (EIA). The regulation
categorizes the projects on the basis of anticipated degree of environmental impact.
Project types that are likely to have significant adverse impact are listed in Schedule II of
the regulations and require an EIA. Projects that are not likely to have significant
adverse impacts, are listed in Schedule I and require an IEE, provided that the project is
not located in an environmentally sensitive area3.
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.
B Environmental Category of Sewer Line Subproject

8.Under ADB’s Environmental Assessment Guidelines (2003) the Tranche 1 Sewer Line
subprojects are Category “B” and IEE.
C Objectives and Scope of IEE

9.The objectives of this IEE were to:
i) Assess the existing environmental conditions in the areas where the
subprojects are located including the identification of environmentally sensitive
areas;
ii) Assess the proposed activities, identify and evaluate the potential impacts and
determine their significance;
iii) Propose appropriate mitigation measures that can be incorporated into the
proposed activities to minimize any adverse impacts, ensure that residual
impacts are acceptable and propose monitoring and planning of future projects
in this sector in Karachi.
10.This IEE is based mainly on secondary sources of information and field
reconnaissance surveys and public consultation undertaken specifically for this
subproject.
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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II. DESCRIPTION OF THE SEWER LINE SUBPROJECT
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.
B The Proposed Sewer Rehabilitation

15.CDGK proposes to rehabilitate sewer line between Shaheen Complex and the Clifton
Pumping Station on the Dr Ziauddin Ahmad Road by removing the existing pipeline and
installing a new appropriately sized sewer. The route of the sewer is shown in Figure 2.
The total length of the proposed sewer is about 1.3 km. It will have three segments.
The first segment of 750 m will be laid in the right-of-way of the Dr Ziauddin Ahmad
Road, the second segment of 150 m in the Right-of-Way (RoW) of Moulvi Tamizuddin
Khan Road, and the third segment of 400 m in the RoW of Beaumont Road.
16.The sewer line will have a diameter of 1.8 m. Pipes made from fibre glass, called
Glass Reinforced Plastic (GRP) pipes are proposed for the sewer line. GRP pipes are
corrosion resistant pipes that are now widely used in many countries for water and
wastewater transport. The pipes are reportedly long lasting and particularly good for
corrosive environment. The pipes are relatively light weight; the typical lengths of pipe
section are 6 m or more; and prefabricated elbows and bends are available. These
features make the installation work much efficient and can reduce the total construction
time considerably.
17.In order to install the new pipelines, the old pipeline in the Dr Ziauddin Ahmad Road
section of the road would be removed. The old pipe made of reinforced concrete was
laid more than 25 years ago and has corroded in several places. Its diameter varies
between 1.5 and 1.7 m. The pipe is also silted and was partially desilted recently to
keep it operational. It is estimated that at present it has only about half of its original
capacity.
18.To minimize disruption in wastewater flow, it is planned that first a new trench will be
excavated adjacent to the existing pipeline in which the new pipe would be laid. The
flow will then be diverted from the old pipe to the new pipe. After this has been
successfully done, the old sewer will be removed.
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Figure 1: Karachi Drains
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Figure 2: Proposed Sewer
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III. DESCRIPTION OF ENVIRONMENT
A Environmental Profile of Karachi
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)
Maximum Minimum Average WHO Guidelines and

Targets9
Sulfur Dioxide 110 16 57 500 (10-minute)
20-125 (annual)
Nitrogen Oxides 489 17 199 40 annual
200 1-hr
Particulate Matter Less 490 40 243 20-70 annual
than 10 micron 50-150 24-hr mean
Ozone 92 10 35 100-250 8-hr mean
Source: TCD CDGK
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.
Social and Cultural Environment

31.Karachi is the capital of the province of Sindh, and the largest city in Pakistan. The
metropolitan area along with its suburbs comprises one of world's most populated areas
that spreads over 1,000 square kilometers12. The city credits its growth to the mixed
populations of economic and political migrants and refugees with different national,
provincial, linguistic and religious origins, many of whom have come to settle
permanently.
32.The population of Karachi in the 1998 census was reported as 9.86 million, an
increase of 80% from the 1981 census (see Table 2). The present estimate of Karachi
population in the Master Plan is 16.4 million.13 This demonstrates that the population
growth rate has increased from 3.6% per annum in the 1981-98 period to 5.8% since
1998. Part of this phenomenal growth can be explained if the population of Karachi was
under-reported in 1998. The Master Plan estimates that the population in 1998 was
actually 11.335 million. This gives an annual growth rate of 4.42% in the 1981-1998
period and 4.2% since then. According to the Karachi Master Plan, the population of the
city is expected to reach 27.6 million by 2020, almost double that of 2005.
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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Table 2: Population of Karachi
Source Year Population (‘000) Annual Growth Rate

Population Census Organization 1981 5,438 4.96%
1998 9,856 3.56%
Karachi Master Plan 1998 11,335 4.42%
2007 16,401 4.19%
Sources: 1981 district census report of Karachi Division, 1981 district census reports of five districts of
Karachi, Karachi Master Plan 2020
33.The female-to-male ratio in the Karachi population 100:117, as compared to the

national figure of 100:109. Of the total population 37.6% are under the age of 15 years
and 58% are between 15 to 50 years of age. In comparison, the national figures are
42.4% and 44.6%, respectively. These numbers are reflective of the high migrant
population in the city who come here often leaving their families behind in order to earn
their living.
34.Approximately 22% of the present day population consists of migrants. The ethnic
configuration of the metropolis shows that 48% people are Urdu speaking. 14% of
Karachiites are Punjabi speaking, 11% speak Pashto, 7.2% speak Sindhi, 4.3% speak
Balochi and Seraiki is spoken by 2.11% of the population.
35.Literacy rates have been on a constant ascendancy in Karachi, with substantial
reduction in male-female literacy gap. The overall literacy rate in 1998 was 67.4%,
including 62.3% literacy for women. The Pakistan Economic Survey 2005-06 reports
that the gross enrolment rate (GER) in Karachi for the primary schools (age 5-9) is
almost 100%. Furthermore, the GER at the metric level in Karachi is at 79% during the
period 2004-05, and the overall literacy rate of the population (10 years and above) in
2004-05 was 78%. There will thus be a large population ready to enter the work force in
a decade or so requiring employment opportunities.
B Environmental Conditions of the Proposed Route

36.The proposed sewer will be laid within the RoW of Dr Ziauddin Ahmad Road for the
first 750 m. Dr Ziauddin Ahmad Road is a dual-carriageway, four-lane road that has a
width of about 25 m. The major buildings on the road includes: the Shaheen Complex,
the Governor’s House, the Pearl Continental Hotel, and the Sheraton Hotel on the
northern side of the road. The offices of Dawn Newspaper, offices of a paramilitary force,
a sports ground, a commerce college, an abandoned hotel project, and the PIDC House
(an office building), on the southern side of the road. The road is lined with trees on both
sides and also in the median. The number of trees on the road between Shaheen
Complex and the PIDC House is close to 100. The second part of the road is turns at
the intersection with the Moulvi Tamizuddin Khan Road (see Figure 2). It follows the
Moulvi Tamizuddin Khan Road for 150 m. There are two major commercial buildings in
this 150-m stretch. The route then turns around the second commercial building and for
the next 400 m, follows a 7-m wide Beaumont Road. All the buildings on the 400-m
stretch of the Beaumont Road from the turning on Moulvi Tmaizuddin Khan Road to the
pumping station are commercial except one residential quarter in front of the Clifton
Pumping Station. There are about 15 households in this quarter. At the intersection of
the Moulvi Tamizuddin Khan Road and the smaller road there are several small shops
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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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IV. ENVIRONMENTAL IMPACTS AND MITIGATION
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
A Design Related Impacts and Design Principles

39.The key design-related environmental impact relates to the selection of the route and
the removal and disposal of the old sewer pipes. As described in Section 2, the route
follows existing RoW and avoids land acquisition and resettlement.
40.The following design principles will be presented to the design engineers by CDGK at
the commencement of their design commission.
41.The pipeline route will adhere to existing pipeline RoW of the roads. If the RoW of
existing sewer pipe lines or the roads cannot be followed for some unforeseen reason,
this IEE and the accompanying EMP (Appendix B) and mitigation measures will be
reviewed and revised accordingly to take account of any unforeseen impacts and
minimize them to acceptable levels.
42.A survey of all existing services and other utilities including electrical power, gas,
water, telephone, sewerage, and fiber optic cables, will be undertaken during the
detailed design stage for the sewer line and if there is a conflict, either the sewer line will
be rerouted and appropriate revisions to the IEE and EMP will be made or the utilities
will be rerouted and reprovisioned.
43.The detailed designs and costing will make provisions for the realignment and re-
provisioning of other utilities where necessary and work together with and obtain
approval from the authority for all utilities on the routing and construction methods for the
new pipelines. The aim will be to reduce disruption of services to the absolute minimum.
44.Wherever possible the design concept will aim permit the maximum use of
prefabricated materials in order to minimize construction impacts and speed up the
installation and re-commissioning process.
45.The ground surfaces excavated for the installation will be resealed in order to
minimize dust emission. Surplus excavated soil will be stockpiled and reused for
landscaping or disposed of as required by the construction supervision consultant and
as agreed with CDGK.
46.The design will be reviewed by the DOE and environmental cell prior to the
finalization of the design to ensure that all environmental requirements are being met
and that the design will facilitate mitigation of environmental impacts to an acceptable
level. The IEE and EMP will be revised during the detailed design stage and updated to
take account of any new, modified, increased or unexpected impacts.
47.Another key design issue for the sewer line is material of the old pipe. If the old
sewer is made of asbestos cement pipes (ACP), retaining or replacing the old ACP with
new ACP would not be consistent with ADB Environmental Policy 2002 as it would not
be deemed to be environmentally responsible procurement. As a special feature of this
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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.
B Construction Related Impacts

48.The proposed pipeline will be within the existing RoW and government lands.
Therefore, no acquisition of private land is anticipated. There are no hawkers or roadside
vendors on the route, except few newspapers hawkers around the PIDC House
(intersection of Dr Ziauddin Ahmad Road and Moulvi Tamizuddin Khan Road). No
significant disruption to them is anticipated. Similarly, no temporary relocation of any
business is anticipated.
Dust Impacts during Construction

49.Among the variety of options to control dust (particulate matter) emissions from
construction sites the most effective is wet suppression. Sprinkling water on exposed
surfaces and soil with adequate frequency to keep soil moist at all times can reduce the
total dust emission from the project by as much as 75%. 14 The following mitigation
measures will be implemented during construction to control emission of dust:
i) Water will be sprinkled daily on all exposed surfaces sufficient to suppress
emissions of dust. The frequency of sprinkling will be increased as necessary
but controlled such that the surface remains just moist at all times, particularly
when wind is blowing towards any nearby SR.
ii) Dust emission from soil and aggregate storage stockpiles will be reduced by
appropriate measures. These will include: (a) covering the pile with tarpaulin or
thick plastic sheets when not in use and at the end of the working day; (b)
erecting windshields / walls on three sides of the piles such that the walls
project 0.5 m above the top of the pile and (c) keeping the material moist by
sprinkling of water at appropriate intervals, to prevent emissions.
iii) All roads within the sewer line route that are to be excavated will be reinstated
and repaved as early as possible after the completion of construction work.
Until the roads are paved, they will be sprinkled regularly to prevent dust
emission.
iv) The construction vehicles will maintain a speed limit of 20 km/h or less on all
unpaved areas within the construction route. Speed limit signposts will be
erected in highly visible positions along the access road and within the route
and maintained for the duration of the construction.
v) Construction materials will be transported to the route and around the route in
trucks securely covered with tarpaulins or equivalent to prevent dust emission
during transportation.
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).
Odour Impacts during Construction

54.As soon as the old sewer pipelines are exposed during the construction phase there
will be considerable potential for odour and health risk if the contaminated materials are
not removed efficiently and handled in a controlled fashion. Therefore the contractor
shall be required in the contracts to include in their waste management plan to cover the
silt disposal requirements and to remove the waste material in no more than 15 days
(say 15 truck loads per day). It is recommended that these disposals should be
separately costed and be milestone payments. Stockpiling of silt and contaminated soil
will not be allowed. The public nearby should be made aware of the unavoidable
disruption but that the duration and methods for the work have been designed to
reduced the odour impacts as far as is practicable.
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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.
Noise during Construction

56.Noise nuisances can be minimized by various measures such as a) preventing as far
as possible construction work during night time 21:00hrs to 06:00hrs within 300 m of SR;
b) prevention of blowing of horns by the project vehicles except in emergencies; c) use
of powered mechanical equipment that is acoustically insulated to reduce noise impacts;
d) tuning and proper maintenance of construction equipment and vehicles. These
measures will all be contractual requirements.
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
29/03/08 Page 18 of 65
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.
C Operations Related Impacts

63.No significant operations related environmental impacts are expected from the
subproject. Some minor impacts may include damage to the pipe and consequent
leakage of sewerage that might cause release of odour hardships to commuters but
these will be dealt with by the routine emergency procedures. Maintenance works
causing disruption of traffic will need to be coordinated with the traffic planning
authorities.
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
65.The objectives of the stakeholder consultation process was to disseminate

information on the project and its expected long-term and short-term impacts among
stakeholders, and to gather information on relevant issues so that the feedback received
could be used to address these issues at an early stages of project design. Another
important objective was to determine the extent of the concerns amongs the community
and recommends means to address these in the project implementation and suggest
appropriate mitigation measures.
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
No. Name Occupation Location Date Issues Raised/Concerns Expressed/Suggestions Action

and Requests/Measures Proposed Taken/Proposed
1 Noor Muhammad Student Near 2 Feb Appreciated the plan Odor control
Shaheen
2 Saeed Khan Auto Mechanic Smell during construction Traffic management plan
Complex
3 Wali Muhammad Businessman Construction work will affect the smooth flow of traffic Utility management plan
4 Gohar Unemployed Damage to existing utilities and structures should be
avoided
5 Zahid Maseeh Sanitary supervisor
6 Dilbar Khan Driver Near Boat 2 Feb For public safety, access should not be blocked during Public safety plan
Basin construction work
7 Mohsin Raza Banker Dust and noise control
Dust and noise during construction are no issues in
8 Adeel Siddiqui Computer Engineer
Karachi because people have adopted both
9 Furqan Student
Work should not be stopped in the middle and should
10 Imdad Jokhio Visitor/Businessman be completed in a short time
11 Imran Afridi Private Service Doodh Patti 29 Feb The reconstruction of road after the last construction Dust and noise control
(Residential work is pending. It should be completed at the earliest
12 Arif Khan Private Service
area near
Noise and dust should be controlled
Pumping
Station)
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VI. INSTITUTIONAL REQUIREMENTS AND

ENVIRONMENTAL MANAGEMENT PLAN
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.
29/03/08 Page 22 of 65
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.
B Environmental Management Plan

81.This IEE concludes that the construction impacts will be manageable if the mitigation
measures are implemented thoroughly. The Environmental Management Plan is based
on the type, extent and duration of the identified environmental impacts. The EMP has
been prepared by close reference to best practices and in line with ADB’s Environmental
Policy (2002) and Environmental Guidelines (2003).
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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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Table 4: Environmental Monitoring Plan for Tranche 1 Subproject
No. Environmental Monitoring Tasks16 Implementation Implementation

Responsibility Schedule
1 Design Phase
1.1 Audit project bidding documents to ensure CDGK through Prior to issue of
IEE and EMP is included. environmental officer bidding documents.
1.2 Disclosure of subproject to SEPA
1.3 Monitor final site selection (alignment) and its CDGK through Prior to CDGK
environmental compliance with EMP environmental officer approval of detailed
designs.
1.4 Monitor the performance of environmental CDGK through Ongoing, prior to
training and briefings and of the environmental officer and during
environmental awareness of project staff and implementation of
CDGK works and
operation.
2 Construction Phase
2.1 Regular (monthly) monitoring and reporting CDGK through Continuous
(quarterly) of contractor’s compliance with environmental officer throughout
statutory environmental requirements construction period.
(quarterly) of contractor’s compliance with environmental officer throughout
contractual environmental mitigation construction period.
measures
(quarterly) of complaints and responses or environmental officer throughout
environmental mitigation measures construction period.
2.4 Monitor adjustments to the EMP and the CDGK through During all phases of
thorough implementation of detailed EMP environmental officer the subprojects
2.5 Commissioning phase monitoring of as built CDGK through At commissioning.
equipment and facilities versus environmental officer
environmental contractual performance
criteria
3 Operation and Maintenance Phase
3.1 Observations during routine maintenance CDGK through As per CDGK
inspections of facilities. Inspections will environmental officer inspection
include monitoring implementation of schedules
operational mitigation measures versus
environmental criteria specified in EMP for
operational impacts.
3.2 Visual monitoring of dust and operational CDGK through During the life of the
noise from two locations on the RoW. environmental officer project
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
Item Sub Item Estimated Total Estimated Total

Costs Cost
[PRS] [USD]
Staffing, audit and monitoring 1 persons for 6months 500,000 8,300
Monitoring activities As detailed under EMP 5,000,000 83,300
Mitigation measures As prescribed under EMP 5,500,000 91,700
and IEE
Transport 1 vehicle for 2 years 1,000,000 16,700
Contingency 5% contingency 1,000,000 16,700
Total 13,000,000 216,700
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VII.FINDINGS AND RECOMMENDATIONS
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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Appendix A:Selected Photographs
Road Crossing Over an Open Drain
Shaheen Complex
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Residential Area in front of the Pumping Station
Clifton Pumping Station
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Appendix B:Environmental Management Plan
29/03/08 Page 33 of 65
Appendix B: Environmental Management Plan for Sewer Rehabilitation

Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp
Concern Implement MM Implement MM Implement MM Monitor MM
DESIGN STAGE
1. Project Ensure statutory Disclose subproject and design to the provincial Commencement The Sewer route Design CDGK -
disclosure compliance with environmental protection agency SEPA & clarify of detailed consultant/ ADB
PEPA 1997 that no documents are required to be filed with the design. CDGK
Provincial and Federal EPA to ensure compliance
with Sec. 12(1) of the PEPA 1997 (as amended).
2. Subproject Ensure EMP Ensure route is as described in RRP with no land Completion of The Sewer route Design CDGK -
boundaries sufficient to acquisition. detailed design. consultant / ADB
change. control impacts CDGK
OR
and compliance
with statutory Review IEE and EMP and confirm findings and
requirements recommendations.
PEPA 1997.
Submit REA, revised IEE/EIA and EMP to ADB.
Complete the environmental assessment process in
line with and ADB Guidelines.
3. Air quality Prevent odour Establish clear plan for efficient excavation of old During detailed 1. Throughout CDGK with the CDGK
(odour) during sewers and rapid disposal of silt and contaminated design stage the Sewer route design consult-
construction and soil. and for future ant.
avoid significant urban planning
Ensure contacts include waste management plan to
deterioration air improvements.
minimize odour exposure of nearby sensitive
quality.
receivers.
4. Asbestos Confirm ACP condition survey - trial pits to assess condition Completion of All WTP & WDM Design CDGK –
management provisions in and extent of ACM pipes to be removed. detailed design. facilities consultant / ADB
asbestos CDGK
Review AMF and EMP with CDGK and confirm
management
findings and recommendations.
framework are
met sufficient to Submit revised AMF and EMP to ADB.
control asbestos
Confirm AMF included in tender documents and
waste removal
CDGK = City District Government Karachi CSC=construction supervision consultant DDC = Detailed Design Consultant PMU = Project Management Unit or Similar
29/03/08 Page 34 of 65
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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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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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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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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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
29/03/08 Page 39 of 65
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.
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.
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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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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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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
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Appendix C:Asbestos Management Framework
This Asbestos Management Framework (AMF) was prepared for all the
subprojects that will arise in all tranches of the proposed Karachi Mega City
Sustainable Development Program (KMCSDP or the ‘Program’) as required
by ADB. The Asbestos Management Framework focuses specifically on
environmental liabilities with respect to asbestos.
Nothing in this AMF shall be construed to modifying or release the
Implementing Agency (IA) CDGK from any other obligations for
environmental assessment of subprojects as required under the EARF with
regards to the policy, procedures and institutional requirements for preparing
subsequent sub-projects under the MFF loan. The executing agency (EA)
will be the Department of Finance of the Government of Sindh (GoS) and
the implementing agency (IA) will be the City District Government of Karachi
(CDGK).
A Development Activities requiring Asbestos Management

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 or the
‘Program’). Water supply and sewer subprojects are included under the KMCSDP MFF
(Table 1). These subprojects will include replacement of water distribution mains (WDM)
and sewer pipes. Asbestos cement pipes (ACP) are known to have been used to
construct the existing WDM and may also have been used to construct the sewers. The
objective of this AMF is to reduce the risk of exposure of workers that have to handle
asbestos, reduce the environmental liabilities associated with asbestos and also build
capacity in CDGK to manage asbestos related issues.
2.During the course of conducting environmental assessment for the subprojects in
Tranche 1 of the KMCSDP MFF it has been discovered that more than half of the WDM
was constructed from asbestos cement pipes (ACP). The extent of asbestos cement
pipes in the existing sewers is not known. The extent to which the ACP have been
replaced is unknown. ADB Environmental Assessment Guidelines 2003 recommend
environmental responsible procurement (ERP) which that is a fundamental principle for
robust environmental management of subprojects. Asbestos is on the ADB Prohibited
List in the Environmentally Responsible Procurement guidelines (2007)17.
3.Asbestos is recognized internationally as a hazardous material because it can present
a risk to human health. In many jurisdictions asbestos is classified as hazardous and is a
controlled chemical waste or a hazardous waste because if it is mishandled it can
release airborne fibers that are known to cause asbestosis and have also associated
with other lung diseases and cancer. All forms of the asbestos mineral will release
asbestos fibers if broken up and all types of ACM will release asbestos fibers to some
degree if damaged or abraded.
4.Asbestos has been widely used in numerous types of materials, usually because of its
good qualities as a thermal insulation material. Asbestos has also been used extensively
in numerous types of cement materials, pipe insulation plaster and in refractory brick
work. Asbestos is often used because of its good qualities as a thermal insulation
material but it is also useful as a binder to form complicated cement shapes and durable
17 Environmentally Responsible Procurement – A guide to better practice ADB (2007)
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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
Sub- Subproject Asbestos ADB

sector Issue Category
First Tranche – 2008 to 2011
Part A Investment Program Management and Support
Program Management
PRMU AMF–A C
PIU AMF–A C
Program Support
Studies AMF–A C
Capacity Development and Training AMF–A C
Public Awareness and Outreach AMF–A C
Monitoring and Evaluation (M&E)
Independent M&E N/A C
Part B Water Supply and Wastewater
Water Filtration Plants at COD and NEK total 100 MGD capacity AMF-D, ERP B
Water Filtration Plants at COD and NEK total 84 MGD capacity AMF-D, ERP B
Water transmission main of 48" and 36" dia. From Pipri Treatment AMF-D, ERP B
Plant to Korangi Industrial Area and 36" from Pipri Treatment Plant to
Malir Town
Water Distribution Network Improvements in priority zone AMF-D, ERP B
Sewer from Shaheen Complex to Clifton PS AMF-D, ERP B
Part C Urban Transport
Bus Rapid Transit along Route 1: Surjani to Karachi CBD; and Route ERP A/B
3: Orangi Town Extn.
Bus Rapid Transit along Route 2: University Road to Karachi CBD ERP B
(Phase 2)
Urban Traffic Control System – Phase 1 N/A C
Dualization of Link Road between National Highway to Superhighway N/A B
Second Tranche – 2009 to 2012
Part A Subproject Preparation AMF-A C
Part B Water Distribution Network Improvements in additional zones AMF-D, ERP B
Transmission main extensions to Mehmoodabad; from Surjani to 5C AMF-D, ERP B
Chowrangi and Nazimabad
24" Main from Hub Reservoir to Baldia Town and Scheme 42 and 48" AMF-D, ERP B
Main from Board Office to Urdu Cowk
Phase 3 extension of water supply network improvement program AMF-D, ERP B
Trunk sewer replacements and extensions based on JICA-supported AMF-D, ERP B
sewerage Masterplan
Part C Bus Rapid Transit (Routes 4,5,6) ERP A/B
Urban Traffic Control System – Phase 2 N/A C
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Sub- Subproject Asbestos ADB

sector Issue Category
Key link Road Malir Expressway Phase 1 N/A B
Part D Pilot low-income housing plot formation and associated studies and ERP C
assistance
Third Tranche – 2010 to 2013
Part B Further water transmission and distribution network extensions based AMF-D, ERP B
on outcome of water balance and equitable distribution study
Trunk sewer replacements and extensions based on findings of JICA- AMF-D, ERP B
supported sewerage Masterplan
Part D Scaled up social housing fund for low-income plot formation and ERP C
assistance
Fourth Tranche – 2011 to 2015
Part B Further water transmission and distribution network extensions based AMF-D, ERP B
on outcome of water balance and equitable distribution study
Trunk sewer replacements & extensions based on JICA-supported AMF-D, ERP B
sewerage Masterplan
Part C Bus Rapid Transit (Routes 7,8,9,10,11) ERP A/B
Key link roads N/A B
N/A = not applicable = no foreseeable asbestos issues.
ERP = Guidance on Environmentally Responsible Procurement – A reference guide for better practices
2007 that recommends no ACM to be used in new infrastructure. AMF-D = AMF will require waste ACP to
be disposed. AMF A = AMF will raise awareness and included in hazardous waste strategy.
10.The procedures to be adopted are outlined in this framework by reference to known

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

12.Best practice asbestos management usually entails several stages. Survey and
investigation are the first steps in which the asbestos specialist will check all structural
elements, fixtures and fittings for fibrous materials that are potentially asbestos. Samples
are taken under controlled conditions and an accredited laboratory analyses the samples
using polarized light microscopy. The asbestos specialist will then assess the type,
location and condition of asbestos and make a hazard assessment. If asbestos needs to
be removed an asbestos abatement plan is usually prepared to cover removal with
detailed work specifications for specialist contractors. In all cases the asbestos should
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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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C Responsibilities / Authorities of Various Agencies

23.Potential environmental liabilities with respect to asbestos associated with
subprojects will be minimized by implementing the requirements of the AMF and by
prescribing the selection of alternative non-asbestos materials (section D and Appendix
2). All measures shall be in line with ADB’s Environment Policy 2002 and ADB
Environmental Assessment Guidelines 2003, the GOP’s regulations and guidelines, the
Environmental Assessment Review Framework and the Guidance on Environmentally
Responsible Procurement1.The subprojects shall only involve asbestos activities that
follow the AMF.
24.The CDGK as IA will be solely responsible for the implementation of all of the
asbestos assessment and review procedures required in the AMF for all subprojects.
This will include, but not be limited to, ensuring that the asbestos control procedures are
strictly adhered to, that preparation of AIR and AMP are carried out in a timely and
efficient manner and included in the construction contracts. CDGK will submit the
asbestos checklist (Table 2) an AIR and an AMP and monitoring reports to ADB for
review.
25.Prior to the submission of the PFR for a Trance of subprojects the CDGK (Asbestos
Specialist) will:
i) Assist CDGK to identify a suitable secure buffer store for waste asbestos.
ii) Prepare an asbestos investigation report (AIR) and checklist to identify any
asbestos issues in any subprojects in each Tranche.
iii) Ensure that adequate sampling and analysis of the existing facilities has
been carried out to ensure all environmental liabilities with respect to
asbestos have been identified, review the asbestos assessments AIR and
AAP and submit the AIR and AAP to ADB.
iv) Prepare the asbestos surveys and investigations prepare asbestos
assessments, AIR and AAP reports including an AMP for inclusion in the
construction contracts.
26.Prior to the commencement of civil works for a subprojects in a Tranche the CDGK
will:
i) Set up the buffer store facility and ensure that all contractors have been
briefed as to the presence of ACM in the subproject works and the nature of
the hazards posed by the type of asbestos present.
ii) Ensure that the contracts have specified the asbestos management
procedure AMP to be used in the construction of the subproject to control
environmental liabilities to acceptable levels.
iii) Ensure that the required mitigation measures during construction and the
AMF are included in the bidding document of the subproject and that the all
bidding contractors have access to the IEEs and EMP.
iv) Ensure that CDGK have identified a suitable secure buffer store for the waste
ACM in lieu of landfill disposal being available and that the contractors know
the location of the buffer store in the bidding documents.
v) Ensure the selected contractor has made adequate provisions (including
human resources, materials methods and training) to carry out works in line
with the AMF as a payment milestone. have access to the IEEs and EMP
27.During the implementation of civil works for a subprojects in a Tranche the CDGK
Asbestos specialist will:
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i) Ensure that the asbestos abatement procedures, including all proposed

mitigation measures and monitoring in Appendix 2 are properly implemented.
ii) Monitor the implementation of AMPs and present its monitoring report.
iii) Ensure that ADB be given access to undertake environmental due diligence
for all subprojects. However, the CDGK shall have the main responsibility for
undertaking environmental due diligence and monitoring of all the
subprojects. The due diligence report as well as monitoring reports on EMP
implementation will be systematically prepared and include asbestos
abatement issues.
Table 2: Proposed preliminary checklist for AMF Implementation on MFF
Subprojects@
Stage Task / Progress Yes / no Date

(comment)
1 Employ Asbestos Specialist (registered /qualified asbestos /
hazardous waste consultant#
2 Prepare asbestos screening checklist. A preliminary review of
asbestos issues by AS. Are ACM / ACP known to have been used
in the system?
3 Have potential locations for ACM / ACP been identified, surveyed,
sampled and investigated by the Asbestos Specialist / qualified /
registered asbestos consultant in line with best practice.
5 Have the potential ACM/ACP bulk samples been analyzed by an
accredited laboratory in line with best practice (Appendix 4).
6 Has the Asbestos Specialist / registered asbestos consultant
prepared an asbestos investigation report including the survey,
sampling locations and confirmed or refuted the presence and
types of asbestos in line with best practice
7 Has the Asbestos Specialist prepared an asbestos management
plan (AMP) including asbestos abatement plan including results of
the asbestos investigation and ACM locations types of asbestos in
line with the AMF procedures and best practice
8 Are the requirements for asbestos management plan including
asbestos abatement plan included in the contracts.
9 Have CDGK provided the necessary buffer storage space or
landfill disposal location for the asbestos.
10 Can the contractors obtain the necessary skills capability and
equipment to carry out the asbestos management in lie with the
AMF.
11 Can the contractors obtain the necessary skills capability and
equipment to carry out the asbestos management in lie with the
AMF.
12 If no to any of the above provide remedial action and detail on
separate sheets
# Link to technical assistance for hazardous waste management strategy - Appendix 1 for
ToR Asbestos Specialist.
@ To be updated at the detailed design stage as necessary.
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.
29/03/08 Page 50 of 65
29.During the MFF ADB will:

i) Review asbestos AIR and AMP as a basis for subproject and Tranche
approvals.
ii) Monitor the AMF and AMP implementation and due diligence as part of MFF
reviews.
iii) Provide assistance to CDGK, if required, in carrying out its responsibilities
and for building capacity for compliance with the AMF.
D Asbestos Control Procedures
1. Minimizing Asbestos Liabilities

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

31.Detailed design work for each additional subproject will include and follow the
recommendations of the AMF. The CDGK will include the requirements of the EMP and
IEE/EIAs (including the AMF) in the bid documents and ensure the detailed designs
include such requirements. Before contracts are finalized certification shall be provided
to ADB by CDGK that the detailed designs comply with IEE/EIAs (including AMP)
29/03/08 Page 51 of 65
recommendations will be required before contracts can be signed and made effective.
The CDGK shall also allocate sufficient resources to recruit and support an Asbestos
Specialist in the DOE of CDGK to monitor the progress of the asbestos management
process for all subprojects under the MFF.
3. Preparation of Construction Contracts

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

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

36.The AMF will have both internal and external monitoring. The Asbestos Specialist at
the local level will be responsible for internal monitoring of the AMF implementation, and
will forward quarterly progress reports to CDGK. The reports will contain progress made
in AMF implementation with particular attention to compliance with the principles set out
29/03/08 Page 52 of 65
in the AMF. The CDGK will submit a brief annual monitoring report to ADB at least once
per year.
29/03/08 Page 53 of 65
APPENDIX 1 DRAFT TERMS OF REFERENCE FOR ASBESTOS

SPECIALIST
This TOR to be modified depending on the management details.
37.
Qualifications
1.The Asbestos Specialist shall preferably be a registered asbestos consultant or
member of a recognised waste management association in an ADB member country
and/or have work experience and familiarity with all aspects of asbestos management
and/or have attended a recognised full time training course on all aspects of asbestos
management. Candidates with broad experience in the field of asbestos management or
hazardous waste management will be preferred. The Asbestos Specialist shall at least
be a graduate in environmental science, environmental engineering or a related
discipline with significant experience in asbestos management or hazardous waste
management and monitoring of projects and implementation of mitigation measures and
engineering controls to minimise risks associated with control of asbestos or hazardous
wastes in the environment.
2.The general scope of work will be:
i) To plan asbestos investigations and arrange for bulk sampling of potential
asbestos containing materials (ACM) and prepare asbestos investigation
report for all subprojects to confirm the extent or refute the presence of ACM.
ii) Prior to controlled landfill disposal facilities being available, to assist CDGK to
identify a suitable buffer store to stockpile ACM collected up from subprojects
and prepare an asbestos management plan (AMP) for the buffer store and
future landfill.
iii) Monitor the management of stockpiled ACM in the buffer store buffer store
and subsequently monitor the management of waste ACM in the controlled
landfill disposal facilities.
iv) When controlled landfill disposal facilities are available, to assist CDGK to
monitor the implementation of necessary controls on asbestos disposal and
to monitor the controlled handling, transfer and disposal of the stockpiled
ACM from the buffer store.
3.If ACM is identified:
v) To prepare asbestos management plans (AMP) including asbestos
abatement plan (AAP) for CDGK DOE for all subprojects and to report
directly to the Head of CDGK if the progress with the AMF is insufficient to
support PFR to ADB.
vi) To review and verify the progress in AMP implementation for each subproject.
vii) To assess whether robust asbestos management practices have been
achieved and /or improved continually on all subprojects.
viii) To assess efficiency and effectiveness of asbestos management practices
and engineering control measures that have been implemented, their impacts
(positive as well negative) and sustainability, drawing both on policy and
practice and to suggest any corrective measures, if necessary.
4.The Asbestos Specialist will be involved in ongoing monitoring of the AMF
implementation for the CDGK. The major tasks expected are:
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i) To Compile and report on preparation of AMP for all subprojects and to notify
PMU and Head of CDGK if the progress in AMP is insufficient to support PFR
to ADB;
ii) Compile and report results of bulk sampling and monitoring and verify results
through random checking at the field level to assess whether AMF objectives
have been generally met;
iii) Identify the strengths and weaknesses of the AMF objectives, approaches,
implementation strategies and identify any unexpected locations of ACM ;
and
iv) Review and verify the progress in AMF implementation of each subproject
and every six months prepare reports for CDGK and ADB.
29/03/08 Page 55 of 65
APPENDIX 2 ASBESTOS ABATEMENT PROCEDURES
Removal of Asbestos Cement Pipes (ACP)

Principle
The principle will be that asbestos cement pipes shall be carefully
excavated, lifted on to plastic sheets for wrapping, wrapped in polythene
and sealed with duct tape and then lifted and lowered on to the transport
lorry for transport to the designated storage area or landfill.
The procedure shall follow the measures indicated below:
Preparation
1.The CONTRACTOR shall make available the materials in Appendix 3.
2.The CONTRACTOR shall be prepared and agree to remove and transport, on
lorries covered with tarpaulins, all the wrapped asbestos cement pipes ACP and
fractured ACP that is in drums, from the site to the secure temporary buffer store
designated by DOE - CDGK to await disposal.
3.The CONTRACTOR shall provide approved protective clothing to all workers. The
CONTRACTOR shall also provide approved protective clothing to the DOE – CDGK
inspector as and when requested. Protective clothing shall consist of an approved
disposable full body coverall, with head cover. Hard hats and boots shall also be
made available to all workers by the CONTRACTOR.
4.Workers handling the asbestos cement pipes shall wear approved half face dust
masks protective coverall and goggles. The CONTRACTOR shall ensure all workers
wear the protective clothing provided.
5.The DOE - CDGK Asbestos Specialist inspector shall carry out a visual inspection
to check that the preparation has been carried out satisfactorily and instruct issue a
written certification to the Contractor to proceed.
Abatement Method
6.First of all the ground / pipe trench shall be excavated carefully using hand tools to
expose the old ACP. Any accidentally excavated loose pieces of asbestos cement
shall be picked up and stored in plastic bags or barrels and sealed.
7.The ACP shall be removed in sections carefully using manual labour and hand
tools to expose the old ACP so that it can be lifted carefully to avoid cracking as far
as possible. Any accidentally fractured loose pieces of asbestos picked up and
stored in plastic bags or barrels and sealed.
8.The drums / barrels to contain the fractured pieces of asbestos cement pipe shall
be made of plastic or metal. If made of some other material the drums / barrels shall
be lined with two layers of 0.15mm polythene sheeting. When the drums are full the
plastic lining shall be folded over the pipe segments and secured in place with duct
tape and the lid placed on the drum and secured in place with duct tape.
9.Before commencing with the removal of the ACP the surface of the asbestos shall
be wet. Any dry areas of exposed existing asbestos cement pipes shall be sprayed
with water (preferably containing a wetting agent) to reduce fibre release. The
wetting agent shall be of a correct mix and concentration in accordance with the
manufacturer’s instructions as specified under materials (Appendix 3).
10.The wetting solution (amended water) shall be sprayed using equipment capable
of providing a ‘mist’ application to reduce the release of fibers. The existing asbestos
29/03/08 Page 56 of 65
material shall be sufficiently saturated to wet it thoroughly. The existing asbestos

material shall be sprayed repeatedly during the removal processes to maintain a wet
condition and to minimize asbestos fibre dispersion.
11.The fixed asbestos cement pipes shall be carefully separated and prized off any
supporting brackets and separated from any attached asbestos cement pipes or
cement screed base and taken up in manageable sections taking care not to drop,
crack, break or damage the asbestos cement pipes. POWERED MECHANICAL
EQUIPMENT (such as backhoe) SHALL NOT BE USED TO REMOVE THE
ASBESTOS PIPES because this will increase the risk of cracking and fibre release.
12.The asbestos cement pipes shall then immediately be wrapped in two layers of
polythene or smaller pieces can be double bagged and goose neck tied with duct
tape and the polythene shall be wet wiped clean.
13.The bottom 10cm of soil below the old ACP shall be assumed to be contaminated
with asbestos fragments or fibers and shall be loosened and shoveled or picked up
and stored in plastic bags or barrels and sealed as ACM.
14.The bottom 5cm of soil below the old ACM pipe, loose debris and rubble will be
removed to create a level floor to the trench and to designate the completion of the
removal work
15.The exposed surfaces of the partially wrapped pipes and the surface of the trench
to be sprayed with adhesives (PVA) to be used as “lock down” on surfaces during the
final clean up of the area. This is to bind any traces of asbestos fibre which may
remain on exposed surfaces.
16.All wrapped asbestos cement packs shall be transferred to the lorries for
immediate transportation to the temporary buffer store to await disposal. All wrapped
asbestos cement packs shall remain at the temporary buffer store and not be
removed
17.The workers shall immediately wet wipe down the overalls and mask and wash
hands and face and any accidentally exposed areas of skin to decontaminate. The
dust masks and overalls, gloves, wet wipes and any other litter shall then
immediately be double bagged and goose neck tied for disposal as asbestos waste.
18.The DOE - CDGK Asbestos Specialist inspector will then carry out a visual
inspection to certify that all visible asbestos cement pipe and fragments have been
removed to a satisfactory standard. If the visual inspection indicates a satisfactory
standard all the asbestos cement packs shall be counted and picked up and
transferred to the lorries for transportation to the temporary buffer store to await
disposal.
19.The DOE - CDGK Asbestos Specialist inspector will then carry out a reassurance
visual inspection to certify that all remaining polythene packs and equipment and
visible asbestos has been removed to a satisfactory standard and proper
decontamination of tools and equipment has taken place.
20.The DOE - CDGK Asbestos Specialist inspector will then check and record the
number of packs of waste transferred to the lorries are the same as those that arrive
at the temporary buffer or landfill using a trip ticket system.
21.The DOE - CDGK Asbestos Specialist inspector will monitor and periodically audit
the buffer store and landfill security to ensure no pilfering or theft of the stockpiled
waste.
22.The Asbestos Specialist inspector will report on the progress of all the asbestos
abatement works under the MFF twice per year to ADB.
29/03/08 Page 57 of 65
APPENDIX 3 MATERIALS AND EQUIPMENT and ASBESTOS

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

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

mask and sprayer handling
drummed high
risk friable
asbestos
29/03/08 Page 59 of 65
29/03/08 Page 60 of 65
APPENDIX 3 continued - LABORATORIES IN PAKISTAN WITH

CAPABILITY TO IDENTIFY ASBESTOS
1.
Pakistan Council of Scientific & Industrial Research
PCSIR Labs Complex
Off University Road
Karachi
Tel#: +92-21-8141841
Fax#: +92-21-8141847
2.
National Physical and Standards Laboratory (NPSL), Islamabad
Plot No.16, Sector H-9
Islamabad
Tel#: +92-51-9257459, 9257462-7
Fax#: +92-51-9258162
3.
Pakistan Council of Scientific & Industrial Research
PCSIR Labs Complex
Ferozepur Road
Lahore
Tel#: +92-42-9230688-95,9230704
Fax#: +92-42-9230705
29/03/08 Page 61 of 65
APPENDIX 4 REVIEW OF ADB PROJECTS WITH ASBESTOS
Asbestos issues for Karachi Mega city Sustainable Development MFF

subprojects.
1. Asbestos is internationally recognized as a hazardous waste. Many
developed and some developing countries have statutory controls on the
manufacture, use, handling, removal, storage and disposal of asbestos
containing materials (frequently referred to as ACM).
2. Whereas ACM were often materials of choice for many applications and
used widely in the second half of the 20th century, these materials have
generally been removed from most applications in developed countries
because of the hazard and replaced with materials with equivalent or better
performance (e.g. asbestos cement pipes replaced with high density
polyethylene or UPVC).
3. Friable forms of asbestos (e.g. woven gaskets, acoustic plaster and
thermal plaster pipe insulation - high risk) can readily release asbestos into
the environment with potential carcinogenic effects in the lung and less
commonly in the gastrointestinal tract. All forms of asbestos (including
cement and resin based ACM – low risk) can potentially release asbestos if
they are deliberately disturbed or abraded. Therefore controls are placed on
all forms of asbestos manufacture, use, handling, removal, storage and
disposal to reduce the release of asbestos fibres into environment to reduce
the risk.
4. The engineering controls that need to be in place for non-friable (so-
called) low risk ACM (including cement based ACM) for handling, removal,
storage and disposal, do not require high-tech solutions and need not be
expensive or difficult to introduce. The controls will however require some
other administrative controls to identify and track the ACM waste “cradle to
grave” to further reduce the risk.
Main concern for asbestos in Pakistan relevant to Karachi Mega City MFF
subprojects
5. Typical of many developing countries Pakistan uses asbestos for many
industrial and commercial purposes. Best professional judgment suggests
that at this stage asbestos cement pipes have been typically been used in
50% to 70% of the Karachi water supply pipe system which extends over
thousands of kilometres. Much of this system will be replaced by ADB
supported project in the immediate future and in a rolling programme over
several years. There may well be other residual asbestos waste entering the
solid waste management work stream.
6. There are as yet no statutory controls on hazardous waste in Pakistan.
The Hazardous Substances Rules were drafted in 2003 but were never
brought into force. Asbestos waste is listed in the draft Hazardous
Substances Rules 2003 (HSR). If enacted the HSR would require an entity
licensed under the Pakistan Environmental Protection Act (1997) to have a
waste management plan for any listed hazardous substance.
SWM in Karachi Mega City MFF
7. The solid waste management Roadmap envisages one goal as “an
effective regulatory framework for the environmentally safe and healthy
29/03/08 Page 62 of 65
management of all municipal and hazardous solid wastes generated in

Karachi”
8. Therefore although hazardous waste management (HWM) in Karachi is in
its infancy, with no regulatory or legislative framework, and no institutional
capacity or funding at the Government level, the need for a HWM system
has been recognized.
9. ADB may well be involved in HWM (therefore waste asbestos
management) corollary to the development of SWM in Karachi Mega City
MFF. (N.B. Another ADB initiative, the RETA on Hazardous Wastes
Management, covering Nepal, India, Bangladesh and Bhutan is now
underway).
10. The lack of a functioning HWM system in Karachi is of serious
concern, as many of the wastes are presumably being disposed of also
through illicit dumping methods throughout the city. This would presumably
be the fate of any asbestos waste from the MFF Tranche 1 projects if
disposal of ACM is not controlled.
Standards for asbestos issues arising in Karachi Mega City MFF
11. ADB standards are guided by the World Bank Pollution,
Prevention and Abatement (PPAH) that requires asbestos disposal should
be carried out in line with host country regulations or following best
12. Therefore as there are as yet no local standards for asbestos
control in Pakistan, any known asbestos waste requiring removal should be
disposed of following best international practice. In the recently published
ADB Guidelines on Environmentally Responsible Procurement (2007)
asbestos fibres are on the prohibited list but asbestos cement sheets with
less than 20% asbestos are exempted.
Way forward
13. In line with best international practice, a dedicated Asbestos
Management Plan in IEE / EMP for relevant subprojects for Karachi Mega
City MFF should be developed. As far as can be anticipated, dovetail the
AMP with future developments in SWM and HWM for Karachi and other
MFFs in Karachi and other ADB experience and lessons.
14. Recommend that Under Karachi Mega City MFF TA (Option 1) or
extend existing ToR of international consultant (Option 2) to develop an
interim an Asbestos Management Plan for the Tranche 1 subprojects in
Water Treatment and Supply and SWM subprojects under the MFF.
Some projects mentioning Asbestos from ADB website
15. Asbestos has been identified as a concern in several projects in
the table below (this is not necessarily a complete list of all projects an
exhaustive list.
Short I.d. Comment ADB website disclosure reference
Korangi RRP Not mentioned in SIEE http://www.adb.org/Documents/RRPs/PAK/rrp-
R15897.pdf
PAK PCR Mentions AC http://www.adb.org/Documents/PCRs/PAK/pcr-pak-
replacement as a 22302.pdf
benefit, no issues
flagged.
29/03/08 Page 63 of 65
Malaysia: AC pipes referenced, http://www.adb.org/Documents/PCRs/MAL/in7_02.pdf

nothing flagged
Manila Water: referencing replacing http://www.adb.org/Documents/RRPs/IND/rrp-35068-
old AC pipes as a ind.pdf
benefit, nothing
flagged
India RRP mentions AC pipes but http://www.adb.org/water/actions/phi/Manila-Water-
doesn't flag any issues Reducing-NRW.asp
in handling
Cook Islands asbestos roofing: has http://www.adb.org/Documents/PPARs/COO/ppa-coo-
RRP # one footnote 24331.pdf
BAN RRP # Mentions AC pipes http://www.adb.org/Documents/Environment/BAN/36297-
and has Text below as BAN-SIEE.pdf
mitigation (?)
measures.
# see comments below
One other power sector project for ADB Bangladesh Project
16. A contractor (demolition and construction) in Bangladesh working
under ADB funded Power plant project was looking for an asbestos
demolition and disposal Specialist/firm/inspector having license as it was
apparently a requirement under ADB funded project (personal approach to
David Green as asbestos consultant mid 2007). The asbestos handling
contractor/Specialist/ Inspector was needed to work or supervise a team
for1-2 months engaged in demolition and disposal of asbestos in an old
power plant. No other details could be found on the ADB website
17. In the following paragraphs the text located at the specific location
is quoted and reviewed and [CONSULTANT OBSERVATIONS IN CAPS and
SQUARE PARENTHESES]
BAN RRP: http://www.adb.org/Documents/Environment/BAN/36297-BAN-
SIEE.
18. Mitigation measures include: (i) damaged AC pipes will be left in
place and the replacement PVC pipes [THIS IS NOT MITIGATION BY
INTERNATIONAL STANDARDS] whenever possible will be laid parallel to
the existing AC pipes [THIS IS NOT RESPONSIBLE PROCUREMENT AS
IT DOES NOT PROVIDE ANY CONTROL TO DEAL WITH THE RESIDUAL
ACM IF OTHERS HAVE TO DIG THE TRENCH LATER];
19. Adequate space will be provided between the proposed and
current alignments, so that the excavation of trenches for the replacement
PVC pipes will not expose the AC pipes. [HOW CAN THIS BE ASSURED]?
Left buried [IS NOT IN LINE WITH BEST PRACTICE], impacts due to
exposure to airborne asbestos fibers are eliminated; and [BUT FUTURE
EXPOSURE CANNOT BE RULED OUT, THEREFORE NOT ELIMINATED]
20. Maintenance workers will be made aware that the old pipe is still
there through appropriate documentation and a marker layer. [OPTIMISTIC
APROACH AT BEST – IN BEST PRACTOCE AN ASBESTOS
MANAGEMENT PLAN WOULD BE PUT IN PLACE TO MAKE SURE THE
ACM WAS MANAGED].
21. An asbestos management plan will be prepared by a qualified
international asbestos management consultant as part of the Project
Consultants. Exposure to asbestos can be prevented by containment,
regular inspections, and proper precautions when working around or with
29/03/08 Page 64 of 65
the material. [ACCEPTABLE BUT WHO WILL INSPECT - DOUBTFUL IF

ANY EXPERIENCED CONSULTANT WOULD RECOMMEND
DELIBERATELY LEAVING MATERIALS IN THE GROUND WHEN THEY
COULD BE REMOVED EASILY AND STOCKPILED EVEN IF DISPOSAL IS
LATER].
22. [THE PROPOSED MEASURES ARE NOT IN LINE WIT BEST
INTERNATIONAL PRACTICE.]
Cook Islands RRP: http://www.adb.org/Documents/PPARs/COO/ppa-coo-
24331.pdf
23 Asbestos cement sheeting is generally not hazardous if it is intact.
But if it is broken or damaged (e.g., during removals), it can become friable
and release asbestos fibres, which are a respiratory hazard and are
respiratory and gastrointestinal carcinogens. Precautions need to be taken
during removal. [OK APPROPRIATE RESPONSE WOULD BE TO HAVE AN
ASBESTOS MANAGEMENT PLAN PREPARED BY A QUALIFIED
REGISTERED ASBESTOS CONSULTANT IN LINE WITH RECOGNISED
CODES OF PRACTICE ON SAFE HANDLING OF LOW RISK ACM].
24 The consultant could not identify reference text for asbestos
in any of the other reports
29/03/08 Page 65 of 65

IEE Sewer - Mar 29, 2008

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Karachi Water and Sewerage Board

City District Government Karachi

Karachi Mega City Sustainable Development Program

Initial Environmental Examination

Document Stage: Final Report

The initial environmental examination is a document of the

II. DESCRIPTION OF THE SEWER LINE SUBPROJECT.........................7

III. DESCRIPTION OF ENVIRONMENT....................................................10

IV. ENVIRONMENTAL IMPACTS AND MITIGATION................................15

VI. INSTITUTIONAL REQUIREMENTS AND

VII. FINDINGS AND RECOMMENDATIONS.............................................29

Figure 1: Karachi Drains............................................................................8

Figure 2: Proposed Sewer.........................................................................9

Table 1: Ambient Air Quality in Karachi (µg/m3)...................................11

Table 2: Population of Karachi................................................................13

Table 3: Summary of Public Consultation.............................................21

Table 4: Environmental Monitoring Plan for Tranche 1 Subproject....27

Table 5: Summary of Estimated Costs for EMP Implementation.........28

ACP Asbestos Cement Pipes

WEIGHTS AND MEASURES

dB(A) Decibel (A-weighted)

LAWS AND REGULATIONS

IEE-EIA Regulations 2000 Pakistan Environmental Protection Agency Review

A Environmental Regulatory Compliance

B Environmental Category of Sewer Line Subproject

C Objectives and Scope of IEE

II. DESCRIPTION OF THE SEWER LINE SUBPROJECT

B The Proposed Sewer Rehabilitation

Figure 1: Karachi Drains

Figure 2: Proposed Sewer

III. DESCRIPTION OF ENVIRONMENT

A Environmental Profile of Karachi

Maximum Minimum Average WHO Guidelines and

Social and Cultural Environment

Table 2: Population of Karachi

Source Year Population (‘000) Annual Growth Rate

33.The female-to-male ratio in the Karachi population 100:117, as compared to the

B Environmental Conditions of the Proposed Route

IV. ENVIRONMENTAL IMPACTS AND MITIGATION

A Design Related Impacts and Design Principles

B Construction Related Impacts

Dust Impacts during Construction

Odour Impacts during Construction

Noise during Construction

C Operations Related Impacts

65.The objectives of the stakeholder consultation process was to disseminate

No. Name Occupation Location Date Issues Raised/Concerns Expressed/Suggestions Action

VI. INSTITUTIONAL REQUIREMENTS AND

B Environmental Management Plan

Table 4: Environmental Monitoring Plan for Tranche 1 Subproject

No. Environmental Monitoring Tasks16 Implementation Implementation

Item Sub Item Estimated Total Estimated Total

VII.FINDINGS AND RECOMMENDATIONS

Appendix A:Selected Photographs

Road Crossing Over an Open Drain

Residential Area in front of the Pumping Station

Clifton Pumping Station

Appendix B:Environmental Management Plan

Appendix B: Environmental Management Plan for Sewer Rehabilitation

Appendix C:Asbestos Management Framework

A Development Activities requiring Asbestos Management

Sub- Subproject Asbestos ADB

Sub- Subproject Asbestos ADB