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

WEIGHTS AND MEASURES
dB(A) ft km km/h m m3 m2 mgd s Decibel (A-weighted) Feet/Foot kilometre kilometre per hour meter cubic meter square meter million [imperial] gallons per day seconds

LAWS AND REGULATIONS
IEE-EIA Regulations 2000 Pakistan Environmental Protection Agency Review of Initial Environmental Examination and Environmental impact Assessment Regulations 2000 Pakistan Environmental Protection Act 1997 Sindh Local Government Ordinance 2001

PEPA 1997 SLGO 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. 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. Sensitive areas are listed on the Federal EPA website and periodically updated.

2

3

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6.The installation or rehabilitation of sewer lines is not specifically mentioned in the IEEEIA. 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 i) Assess the existing environmental conditions in the areas where the subprojects are located including the identification of environmentally sensitive areas;

9.The objectives of this IEE were to:

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 5

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

6

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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 Sulfur Dioxide Nitrogen Oxides Particulate Matter Less than 10 micron Ozone
Source: TCD CDGK

Minimum 16 17 40 10

Average 57 199 243 35

WHO Guidelines and Targets9 500 (10-minute) 20-125 (annual) 40 annual 200 1-hr 20-70 annual 50-150 24-hr mean 100-250 8-hr mean

110 489 490 92

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 8

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

9

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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 13

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. 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 Population Census Organization Karachi Master Plan Year 1981 1998 1998 2007
Sources:

Population (‘000) 5,438 9,856 11,335 16,401

Annual Growth Rate 4.96% 3.56% 4.42% 4.19%

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 reprovisioning 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

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security, trench barriers, reflective signs and covers to other holes, hoarding plans and any other safety measures as necessary. Contingency Planning 61.It is also proposed that a contingency plan will be put in place before construction commences to cover emergencies in the case of damage to other infrastructure such as wastewater collection and drainage system, water distribution lines, and power cables. With the thorough identification of all utilities and correct planning for rerouting and reprovisioning 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 reprovisioning 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 1 2 3 4 5 6 7 8 9 10 11 12 Noor Muhammad Saeed Khan Wali Muhammad Gohar Zahid Maseeh Dilbar Khan Mohsin Raza Adeel Siddiqui Furqan Imdad Jokhio Imran Afridi Arif Khan Occupation Student Auto Mechanic Businessman Unemployed Sanitary supervisor Driver Banker Computer Engineer Student Visitor/Businessman Private Service Private Service Near Boat Basin 2 Feb Location Near Shaheen Complex Date 2 Feb Issues Raised/Concerns Expressed/Suggestions and Requests/Measures Proposed Appreciated the plan Smell during construction Construction work will affect the smooth flow of traffic Damage to existing utilities and structures should be avoided For public safety, access should not be blocked during construction work Dust and noise during construction are no issues in Karachi because people have adopted both Work should not be stopped in the middle and should be completed in a short time Doodh Patti 29 Feb The reconstruction of road after the last construction (Residential work is pending. It should be completed at the earliest area near Noise and dust should be controlled Pumping Station) Dust and noise control Public safety plan Dust and noise control Action Taken/Proposed Odor control Traffic management plan Utility management plan

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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.

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in the CDGK jurisdiction. The key elements directly relevant to the implementation of the MFF subprojects can be summarized as follows: i) To ensure implementation of environmental protection and preservation measures in all development projects at district level and sensitize government agencies on environmental issues (that can be achieved by following the EARF);

ii) To assist provincial EPA in discharge of its functions under the Pakistan Environmental Protection Act, 1997; iii) To ensure, guide and assist proponents of new projects in the submission of IEEs and EIAs to the SEPA for approval; iv) To request the Environmental Magistrate or Environmental Tribunal to take cognizance of any offence under the provisions of PEPA 1997; v) To undertake regular monitoring of projects financed from the provincial sustainable development fund and to submit progress reports to the SEPA for publication in its annual report. 75.At present the DOE is alone within the CDGK with sole responsibility for brining environmental issues to the notice of corporate management (District Coordination Officer, DCO and City District Nazim). The most significant challenge is the lack of human and financial resources and necessary infrastructure. In 2006 the Governor of Sindh made a call to establish a separate environment department in the face of growing national and international environmental concerns. The DOE has made a proposal for a separate environment department to the District Coordination Officer (DCO) but as of September 2007 there is no change to the existing CDGM departmental structure. 76.If the terms of reference stated in the SLGO are to be realized then overcoming environmental capacity deficit within the CDGK will need to be addressed. Environmental assessment and coordination with SEPA are both key to CDGKs environmental responsibilities under the SLGO. However although proposals have been made to address this shortfall in environmental capacity by DOE, a response in terms of adequate additional human and financial resources may not materialize for some time. Therefore there is likely to be a period at the start of the KMCSDP MFF when DOE has insufficient resources to carry out the environmental assessment requirements for ADB. The lack of appropriate institutional arrangements may interfere with the KMCSDP attempts to ensure compliance with both GoP and ADB environmental assessment requirements. Therefore it is recommended that the KMCDSP provide an environmental cell of at least two full time environmental specialists to support the DOE and remain in support until such time as the proposed Environmental Department is created or sufficient other resources are made available to DOE in CDGK and the proposed EDO Environment is fully capable of supporting the environmental assessment portfolio of CDGK. At such a time the appointed environmental cell professionals may be absorbed into the EDO Environment in order to retain institutional memory. 77.The EDO will need more staff and training resources if effective quality control is to be provided for the EMP implementation and much of the environmental assessment work may be delegated to consultants. The aspirations of the SLGO objectives, to raise awareness both within Municipal Services Department and more broadly in CDGK, are sound, but at present the awareness level is not high. Specific areas for immediate attention are in environmental assessment and auditing, waste, air, water and noise pollution management and impact mitigation. As a first step CDGK should consolidate DEO as soon as possible and nominate additional suitable staff to work from within the department to monitor and audit progress on environmental management for the MFF.

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78.For the KMCSDP, the environmental cell staff, engaged to support the DEO for the MFF subprojects, must be appointed at the outset of the implementation. At the detail design stage of subproject the cell shall have at least one environmental specialist to assist the DEO to address all environmental aspects in the detailed design and contracting stages and the relevant statutory submissions and approvals. In addition, there needs to be an environmental specialist to cover the implementation of environmental mitigation measures in the construction stage of the subproject packages. The environmental specialists should work as members of the environmental management team with significant proportion of time spent in the field, observing and making recommendations to improve or modify environmental mitigation measures executed by the contractors, as the EMP evolves and the MFF subprojects proceed, to respond to unexpected circumstances. 79.The requisite staff should be appointed prior to the commencement of the tendering for the construction activities to ensure the inclusion of environmental requirements can be translated into contractual works for completion of the pipeline and filtration plants and also respond to unexpected circumstances. Both members of the cell can initially be bolted on to the DEO or within supervising consultant’s team. i) The environmental specialists will: a) Work with DEO to execute any additional EIA and IEE requirements prior to project commencement and review the EMP; b) Work with the project management team(s) in CDGK to ensure all environmental requirements and mitigation measures from the EIAs and IEEs and environmental performance criteria are incorporated in the contracts; and c) Work with contractors to manage the implementation of the project EMP (as revised). ii) Overall implementation of the EMP will become CDGK’s responsibility. Other parties to be involved in implementing the EMP are as follows: a) Contractors: responsible for implementing all measures required to mitigate environmental impacts during construction; and b) Other government agencies: such as UC, Towns authorities, regional EPA and state pollution authorities for monitoring the implementation of environmental conditions and compliance with statutory requirements in their respective areas. 80.Considering the number of government agencies that need to be involved in implementing the EMP, training workshops should be conducted at every six months or twice each year, for the first 3 years, to share experience in the implementation of the subprojects and the monitoring report on the implementation of the EMP, to share lessons learned in the implementation and to decide on remedial actions, if unexpected or uncontrolled environmental impacts occur. 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 prequalification, 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 1 1.1 1.2 1.3 Design Phase Audit project bidding documents to ensure IEE and EMP is included. Disclosure of subproject to SEPA Monitor final site selection (alignment) and its CDGK through environmental compliance with EMP environmental officer Monitor the performance of environmental CDGK through training and briefings and of the environmental officer environmental awareness of project staff and CDGK Construction Phase Regular (monthly) monitoring and reporting (quarterly) of contractor’s compliance with statutory environmental requirements Regular (monthly) monitoring and reporting (quarterly) of contractor’s compliance with contractual environmental mitigation measures Regular (monthly) monitoring and reporting (quarterly) of complaints and responses or environmental mitigation measures Monitor adjustments to the EMP and the thorough implementation of detailed EMP Commissioning phase monitoring of as built equipment and facilities versus environmental contractual performance criteria Operation and Maintenance Phase Observations during routine maintenance inspections of facilities. Inspections will include monitoring implementation of operational mitigation measures versus environmental criteria specified in EMP for operational impacts. Visual monitoring of dust and operational noise from two locations on the RoW. CDGK through environmental officer As per CDGK inspection schedules CDGK through environmental officer CDGK through environmental officer Continuous throughout construction period. Continuous throughout construction period. Continuous throughout construction period. During all phases of the subprojects At commissioning. Prior to CDGK approval of detailed designs. Ongoing, prior to and during implementation of works and operation. CDGK through environmental officer Prior to issue of bidding documents. Implementation Responsibility Implementation Schedule

1.4

2 2.1

2.2

2.3

CDGK through environmental officer CDGK through environmental officer CDGK through environmental officer

2.4 2.5

3 3.1

3.2

CDGK through environmental officer

During the life of the 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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Karachi Mega City Sustainable Development Program MFF Tranche 1 IEE Report for Dr Ziauddin Ahmad Road Sewer Line Rehabilitation Subproject

Table 5: Summary of Estimated Costs for EMP Implementation
Item Sub Item Estimated Total Costs [PRS] 500,000 5,000,000 5,500,000 1,000,000 1,000,000 13,000,000 Estimated Total Cost [USD] 8,300 83,300 91,700 16,700 16,700 216,700

Staffing, audit and monitoring 1 persons for 6months Monitoring activities Mitigation measures Transport Contingency Total As detailed under EMP As prescribed under EMP and IEE 1 vehicle for 2 years 5% contingency

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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

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Appendix B: Environmental Management Plan for Sewer Rehabilitation
Environmental Concern DESIGN STAGE 1. Project disclosure Ensure statutory compliance with PEPA 1997 Disclose subproject and design to the provincial environmental protection agency SEPA & clarify that no documents are required to be filed with the Provincial and Federal EPA to ensure compliance with Sec. 12(1) of the PEPA 1997 (as amended). Ensure route is as described in RRP with no land acquisition. OR Review IEE and EMP and confirm findings and recommendations. Submit REA, revised IEE/EIA and EMP to ADB. Complete the environmental assessment process in line with and ADB Guidelines. 3. Air quality (odour) Prevent odour during construction and avoid significant deterioration air quality. Confirm provisions in asbestos management framework are met sufficient to control asbestos waste removal Establish clear plan for efficient excavation of old sewers and rapid disposal of silt and contaminated soil. Ensure contacts include waste management plan to minimize odour exposure of nearby sensitive receivers. ACP condition survey - trial pits to assess condition Completion of and extent of ACM pipes to be removed. detailed design. Review AMF and EMP with CDGK and confirm findings and recommendations. Submit revised AMF and EMP to ADB. Confirm AMF included in tender documents and
CSC=construction supervision consultant DDC = Detailed Design Consultant PMU = Project Management Unit or Similar Page 34 of 65

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement MM

Locations to Resp Resp Implement MM Implement MM Monitor MM CDGK ADB

Commencement The Sewer route Design of detailed consultant/ design. CDGK

2. Subproject boundaries change.

Ensure EMP sufficient to control impacts and compliance with statutory requirements PEPA 1997.

Completion of detailed design.

The Sewer route Design consultant / CDGK

CDGK ADB

During detailed design stage

1. Throughout the Sewer route and for future urban planning improvements.

CDGK with the CDGK design consultant.

4. Asbestos management

All WTP & WDM Design facilities consultant / CDGK

CDGK – ADB

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement MM

Locations to Resp Resp Implement MM Implement MM Monitor MM

and disposal and that bidding contractors have capacity to comply comply with ADB with AMF and other safety requirements. ERP guidelines. 5. Waste Disposal Ensure sufficient disposal space for waste materials and avoid fly-tipping. Avoid disruption to large drains nearby at Dr Ziauddin Ahmad Road. Include preliminary designs in contract. 7. Traffic Condition Plan to minimize disturbance of vehicular traffic and pedestrians during construction. 1. Before works commence selected contractor to prepare Waste Management Plan with disposal sites identified for agreement by construction supervision consultants and CDGK. 1. Identify all locations for drains that are to be crossed. 2. Design protection for works in sewer in line with worst case storm predictions. 3. Contracts to specify locations and expected mitigation measures. 4. Include reprovisioning in contracts as payment milestone(s). 1. Within one month of award of contract or earlier. 1. During designing stage no later than prequalification or tender negotiations 2. Include in the contract. The sewer route Design consultant / CDGK CDGK

6. Permanent drainage protection.

Dr Ziauddin Ahmad Road and any other vulnerable locations to be identified during detailed design stages.

CDGK with the sc and design consultant.

CDGK.

1. Avoiding blocking existing roads and access near During detailed the sewer route during construction. design. 2. Design provisional temporary traffic management plan for updating by the construction contractors one month prior to start of works in any given sector. 3. Installation of traffic warning signs, and enforcing traffic regulations during transportation of materials and equipment and machinery. 4. Include plans for conducting awareness programs on safety and proper traffic behavior near sewer construction sites. 5. Plan requirements to assign dedicated traffic

The most Detailed design CDGK important engineer. locations to be identified and listed in revised EMP. Relevant plans to be made available to the Contractor with tenders.

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended 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.

Timing to Implement MM

Locations to Resp Resp Implement MM Implement MM Monitor MM

8. Environmentally responsible procurement

Look for enhancement opportunities in design and construction. Avoid construction and operational environmental pollution.

Choose non polluting or enhancing methods. Contractor to submit Method Statement and schedule of environmental mitigation measures with tender. Enhancements, techniques and machinery selection to minimize impacts and duration of works. Choose non polluting equipment Specify equipment not to contain persistent organic pollutants, asbestos and other hazardous or toxic components.

During detailed design and compiling contracts and during contractor selection, prior to contract signing.

CSC/Tender CSC/Tender evaluators to evaluators check contractors Method Statements include sufficient resources for mitigation measures and correct timing in tender/bids. To cover all the sewer route. Contractor.

CDGK

CONSTRUCTION STAGE 1. Plans to control environmental and associated impacts Avoid impacts from unplanned activities 1. Temporary traffic management plan, 2. Drainage and utilities re-provisioning plan, 3. Materials management master plan, 4. Noise and dust control plan, 5. Waste management plan; should all be deliverable in final form by the contractors one month before construction Prior to construction activity Submission to ADB CDGK.

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Environmental Concern 2. Orientation for Contractor, and Workers and materials management.

Objectives

Mitigation Measures (MM) Recommended commences.

Timing to Implement MM

Locations to Resp Resp Implement MM Implement MM Monitor MM All site agent staff. monthly induction and six month refresher course as necessary until contractors comply / improve. Contractor management with the CSC to check monthly and record details and report monthly in progress reports CDGK & to observe and record success.

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

Contractors tenders shall be required to separate Induction for all clearly the resources and funds to be applied to the site agents and mitigation measures for environmental impacts. above including all CSC staff new Contractors tenders shall identify named staff to staff before supervise and plan, commencement of work. Drainage and utilities re-provisioning Temporary traffic management, Materials management, Noise and dust control, Waste management, Contractual clauses shall be included to tie the implementation of environmental mitigation measures in the above plans to trigger milestone payments. 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 Weekly tool box talks and refreshers at early stages of construction for all construction employees as far as reasonably practicable. Include with safety talks.

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended 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.

Timing to Implement MM

Locations to Resp Resp Implement MM Implement MM Monitor MM

3. Exploitation handling, transportation and storage of construction materials

To minimize and or avoid adverse environmental impacts arising out of construction material handling, transportation and storage. To minimize contamination of the surroundings

Contracts to include specifications for Move bulk materials at site off peak less busy times. Maintain vehicles used in material transport and waste in good condition and covered with tarpaulins. Update materials management plan monthly and include in progress report

Update monthly

1. A list of routes Contractor and of transport of CSC to agree construction material is to be prepared for the contract and agreed one month prior to commencement of construction.

CDGK

4. Institutional strengthening and capacity

To ensure that CDGK and PMU officials are

Capacity building activities. Consolidation of the DOE or Setting up of a Executive District Officer, Environment Office within
CSC=construction supervision consultant

Initiate during preconstruction and continue

All senior staff in CDGK CDGK at senior engineer and

ADB

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Environmental Concern building

Objectives

Mitigation Measures (MM) Recommended

Timing to Implement MM beyond project completion.

Locations to Resp Resp Implement MM Implement MM Monitor MM above in PMU and related units.

trained to CDGK. understand and Development of a strengthening plan for the EDO. to appreciate and have the resources to apply the EMP. To minimize air impacts effectively and avoid complaints due to odour and airborne particulate matter released to the atmosphere. CONTOL ALL DUSTY MATERIALS AT SOURCE.

5. Air quality

1. Before works The sewer route commence and 1. If works have given rise to complaints over dust, weekly the contractor shall investigate the cause and throughout all review and propose alternative mitigation measures construction before works recommence. works 2. All heavy equipment and machinery shall be 2. Monthly fitted in full compliance with the national and local reporting in regulations. progress 3. Stockpiled soil and sand shall be slightly wetted reports. before loading, particularly in windy conditions. 3. Report to 4. Fuel-efficient and well-maintained haulage trucks allow inclusion in shall be employed to minimize exhaust emissions. PPR to ADB. Smoke belching vehicles and equipment shall not 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

1. The CDGK Contractor should maintain the accepted standards. 2. CSC should monitor dust complaints, wheel washing and surface wetting and other relevant activities. 3. CDGK

6. Removal of 1. To adopt ERP Asbestos Cement in line with ADB Pipes (ACP) requirements.

2. To control the release of harmful asbestos The procedure shall follow the measures indicated
CDGK = City District Government Karachi 29/03/08 CSC=construction supervision consultant

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

Update once a 1. The location of month and report buffer temporary quarterly. store or permanent disposal areas to be identified by

2.CDGK DOE and CSC should supervise and take action to ensure

CDGK/ CSC

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Environmental Concern

Objectives fibres. 3. To control disposal of ACP, a hazardous waste.

Mitigation Measures (MM) Recommended below: Preparation 1. The CONTRACTOR shall implement all the procedures in Appendix 2 of the AMF and make available all the materials in Appendix 3 of the AMF. 2. The CONTRACTOR shall agree to remove and transport all the wrapped asbestos (ACP) from the sites to secure temporary buffer store(s) designated by DOE - CDGK to await disposal. 3. The CONTRACTOR shall provide approved protective clothing to all workers and DOE – CDGK inspector as and when requested. 4. Workers handling the asbestos cement pipes shall wear the personal protective clothing provided. 5. The DOE - CDGK Asbestos Specialist inspector shall visually inspect the preparation before instructing the Contractor to proceed. 6. The DOE - CDGK Asbestos Specialist inspector shall monitor the works and carry out a visual inspection to certify that all the ACP have been removed to a satisfactory standard in line with Appendix 2 of the AMF. 7. The DOE - CDGK Asbestos Specialist inspector will check and record the number of packs of waste transferred to the lorries are the same as those that arrive at the temporary buffer or landfill using a trip ticket system. 8. The DOE - CDGK Asbestos Specialist inspector

Timing to Implement MM

Locations to Resp Resp Implement MM Implement MM Monitor MM detailed design engineer to be prepared at the contract stage for agreement. completion of Contractor’s relevant activities according to environmental standards in the 2. The records of AMF. asbestos abatement activities and audit of waste disposal quantities to be reconfirmed and that disposal area is available as identified by detailed design engineer.

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended 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.

Timing to Implement MM

Locations to Resp Resp Implement MM Implement MM Monitor MM

7. Construction Waste Disposal

To minimize the impacts from construction waste disposal.

WASTE MANAGEMENT PLAN TO BE Update once a 1. A list of SUBMITTED TO THE CSC AND APPROVED ONE month and report temporary MONTH PRIOR TO STARTING WORKS. quarterly. dumping areas identified by 1. Estimating the amounts and types of construction detailed design waste to be generated by the project. engineer to be prepared at the 2. Identify opportunities for waste to be reused in contract stage the project or by other interested parties. for agreement. 3. Identifying potentially safe disposal sites close to 2. The list of the project. OR THOSE DESIGNATED SITES IN waste sites to be THE CONTRACT. reconfirmed and 4. Waste shall not be burned - under any that dumping circumstances. areas is available as OPEN BURNING IS CONTRARY TO GOOD identified by ENVIRONMEMTAL PRACTICE. detailed design engineer.

1. Contractor 2. CSC should supervise and take action to ensure completion of Contractor’s relevant activities according to environmental standards.

CDGK/ CSC

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended 1. Providing adequate warning signs. 2. Providing workers with waterproof boots, skull guard or hard hat, mask, gloves and overalls. 3. Contractor shall instruct his workers in health and safety matters, weekly, and require the workers to use the provided safety equipment. Special focus on handling 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.

Timing to Implement MM During construction

Locations to Resp Resp Implement MM Implement MM Monitor MM Relevant Contractor and canteen and CSC worker sanitation facilities Base height as for equipment yards above HFL. CDGK/ CSC

8. Safety To ensure safety Precautions for of workers and the Workers and equipment. first aid.

9. Traffic Condition

Minimize disturbance of vehicular traffic & pedestrians during haulage of materials, spoil, equipment & machinery.

Submit temporary traffic management plan one month prior to start of works in any given sector. - Formulation and implementation of a construction related traffic management plan . Assign traffic control personnel.. - Conducting awareness programs on safety and proper traffic behavior in densely populated areas near the construction sites. Plan to consider 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

Day time

The most important locations to be identified and listed. Relevant plans of the Contractor on traffic arrangements are available.

Contractor and Engineer

CDGK/ CSC

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Environmental Concern

Objectives

Mitigation Measures (MM) Recommended 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

Timing to Implement MM

Locations to Resp Resp Implement MM Implement MM Monitor MM

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
Subsector Subproject Asbestos Issue ADB Category

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

AMF-D, ERP AMF-D, ERP

B B

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Subsector

Subproject Key link Road Malir Expressway Phase 1

Asbestos Issue N/A ERP

ADB Category B C

Part D

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

Third Tranche – 2010 to 2013 Part B Further water transmission and distribution network extensions based on outcome of water balance and equitable distribution study Trunk sewer replacements and extensions based on findings of JICAsupported sewerage Masterplan Part D Scaled up social housing fund for low-income plot formation and assistance AMF-D, ERP AMF-D, ERP ERP B B C

Fourth Tranche – 2011 to 2015 Part B Further water transmission and distribution network extensions based on outcome of water balance and equitable distribution study Trunk sewer replacements & extensions based on JICA-supported sewerage Masterplan Part C Bus Rapid Transit (Routes 7,8,9,10,11) Key link roads AMF-D, ERP AMF-D, ERP ERP N/A B B A/B 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 1 2 Task / Progress Employ Asbestos Specialist (registered /qualified asbestos / hazardous waste consultant# Prepare asbestos screening checklist. A preliminary review of asbestos issues by AS. Are ACM / ACP known to have been used in the system? 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. Have the potential ACM/ACP bulk samples been analyzed by an accredited laboratory in line with best practice (Appendix 4). 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 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 Are the requirements for asbestos management plan including asbestos abatement plan included in the contracts. Have CDGK provided the necessary buffer storage space or landfill disposal location for the asbestos. Can the contractors obtain the necessary skills capability and equipment to carry out the asbestos management in lie with the AMF. Can the contractors obtain the necessary skills capability and equipment to carry out the asbestos management in lie with the AMF. 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. Yes / no (comment) Date

3

5 6

7

8 9 10

11

12

28.ADB will be responsible for regular review and timely approval of subproject AMF checklists (Table 2). Technical guidance will be provided by ADB to the CDGK as needed. ADB will also be responsible for reviewing regular monitoring reports and officially disclosing the any aspects of on the ADB website if required.

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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 international practice. vii) All measures shall be in line with ADB’s Environment Policy 2002 and ADB Environmental Assessment Guidelines 2003, the GOP’s environmental assessment regulations and guidelines, the Environmental Assessment Review Framework and the Guidance on Environmentally Responsible Procurement1. viii) The subprojects shall only involve asbestos activities that follow the AMF. 2. Preparation of Detailed Design

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)

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recommendations will be required before contracts can be signed and made effective. The CDGK shall also allocate sufficient resources to recruit and support an Asbestos Specialist in the DOE of CDGK to monitor the progress of the asbestos management process for all subprojects under the MFF. 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

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

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APPENDIX 1 DRAFT TERMS OF REFERENCE FOR ASBESTOS SPECIALIST This TOR to be modified depending on the management details. 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.

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

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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.

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APPENDIX 3 LABORATORIES

MATERIALS AND EQUIPMENT and ASBESTOS

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 deenergized 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, mask and sprayer

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

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

1. Asbestos is internationally recognized as a hazardous waste. Many developed and some developing countries have statutory controls on the manufacture, use, handling, removal, storage and disposal of asbestos containing materials (frequently referred to as ACM). 2. Whereas ACM were often materials of choice for many applications and used widely in the second half of the 20th century, these materials have generally been removed from most applications in developed countries because of the hazard and replaced with materials with equivalent or better performance (e.g. asbestos cement pipes replaced with high density polyethylene or UPVC). 3. Friable forms of asbestos (e.g. woven gaskets, acoustic plaster and thermal plaster pipe insulation - high risk) can readily release asbestos into the environment with potential carcinogenic effects in the lung and less commonly in the gastrointestinal tract. All forms of asbestos (including cement and resin based ACM – low risk) can potentially release asbestos if they are deliberately disturbed or abraded. Therefore controls are placed on all forms of asbestos manufacture, use, handling, removal, storage and disposal to reduce the release of asbestos fibres into environment to reduce the risk. 4. The engineering controls that need to be in place for non-friable (socalled) 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

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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 international practice. 12. Therefore as there are as yet no local standards for asbestos control in Pakistan, any known asbestos waste requiring removal should be disposed of following best international practice. In the recently published ADB Guidelines on Environmentally Responsible Procurement (2007) asbestos fibres are on the prohibited list but asbestos cement sheets with less than 20% asbestos are exempted.
Way forward

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

15. Asbestos has been identified as a concern in several projects in the table below (this is not necessarily a complete list of all projects an exhaustive list.
Short I.d. Korangi RRP PAK PCR Comment Not mentioned in SIEE Mentions replacement benefit, no flagged. AC as a issues ADB website disclosure reference http://www.adb.org/Documents/RRPs/PAK/rrpR15897.pdf http://www.adb.org/Documents/PCRs/PAK/pcr-pak22302.pdf

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Malaysia: Manila Water:

India RRP

Cook Islands RRP # BAN RRP #

AC pipes referenced, nothing flagged referencing replacing old AC pipes as a benefit, nothing flagged mentions AC pipes but doesn't flag any issues in handling asbestos roofing: has one footnote Mentions AC pipes and has Text below as mitigation (?) measures.

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

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

# see comments below

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-BANSIEE. 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

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Karachi Mega City Sustainable Development Program MFF Tranche 1 IEE Report for Dr Ziauddin Ahmad Road Sewer Line Rehabilitation Subproject

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-coo24331.pdf 23 Asbestos cement sheeting is generally not hazardous if it is intact. But if it is broken or damaged (e.g., during removals), it can become friable and release asbestos fibres, which are a respiratory hazard and are respiratory and gastrointestinal carcinogens. Precautions need to be taken during removal. [OK APPROPRIATE RESPONSE WOULD BE TO HAVE AN ASBESTOS MANAGEMENT PLAN PREPARED BY A QUALIFIED REGISTERED ASBESTOS CONSULTANT IN LINE WITH RECOGNISED CODES OF PRACTICE ON SAFE HANDLING OF LOW RISK ACM]. 24 The consultant could not identify reference text for asbestos in any of the other reports

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