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Table of content

1 Introduction ............................................................................................................ 2

2 Methodology for hotspots identification and prioritization ....................................... 3 2.1 Baseline assessment ............................................................................................. 3 2.2 Site assessment ................................................................................................... 3 2.3 Preliminary site prioritization ............................................................................. 4 2.4 Preliminary site investigation .............................................................................. 4 2.5 Final ranking and prioritization ........................................................................... 5 2.6 Methodology summary ....................................................................................... 6

3 Institutional framework............................................................................................ 7 3.1 Inter-entity bodies .............................................................................................. 7 3.2 Institutional structure regarding waste in B&H..................................................... 8

4 Legislation and regulation governing waste management ........................................ 10 4.1 General information about EU legislation and regulation regarding waste........... 10 4.2 Waste legislation in B&H.................................................................................... 12

4.2.1 Current laws and special regulations governing wastes and hazardous wastes ........... 12 4.2.2 Waste Management Law in FBiH ......................................................................................................... 12 4.2.3 Waste Management Law in RS ............................................................................................................. 13 4.2.4 GAPs and discrepancies – EU and B&H ............................................................................................. 15

4.3 Legislation - summary ....................................................................................... 19

5 Hotspots management in B&H ................................................................................ 20 5.1 Proposals for improvement of hotspots management in B&H .............................. 20

6 Hotspots identification ........................................................................................... 22 6.1 Hazardous wastes from industry ........................................................................ 22

6.1.1 Influence of Heavy Industry Wastes on the environment ........................................................ 22 6.1.2 Influence of Heavy Industry Hazardous Wastes - Soil................................................................. 22 6.1.3 Influence of Heavy Industry Hazardous Wastes - Water............................................................ 23

6.2 List of identified hotspots .................................................................................. 24 6.3 Hotspots prioritisation ................................................................................................. 34  

 

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1 Introduction  

Environmental issues in Bosnia and Herzegovina and countries in the region of Balkan were not priorities in the last two decades. Pre-war industrial burdens and wastes that were not treated or disposed adequately remained an issue even today. Lack of environmental infrastructure such as wastewater treatment, air-pollution abatement and monitoring, and industrial and communal waste management indicate very poor environmental situation, directly influencing the health of people and ecosystems. Most of countries in the region, including Bosnia and Herzegovina, have no systematic method and approach for identification, addressing and remediation of environmental hot spots. Their number and severity are not known and funding in most of the cases is unavailable. Situation is even more complicated by the change of ownership of these environmental burdens, which in most cases fall into the Federal and RS jurisdiction. Contaminated sites, mostly industrial, represent great threat to the environment and public health. Situation in B&H is becoming even more complicated due to the lack of data and legislation. Environmental impacts of most of the contaminated sites are of regional character and should be dealt with urgently. Their impact is not fully known, clean up costs not systematically estimated. In addition to former and/or ongoing industrial production facilities can conflict related environmental damages been recognized, which are also addressed to the governmental environmental liability. It can also be assumed, that accidents happened in the past, on which environmental liability cannot more be addressed clearly are also part of future governmental activities. Basic policy dealing with environmental issues is a national document NEAP from 2003 within which is not indicated proper action plan or responsibilities. Still, this document can serve as a base for further studies regarding environmental problems since it identifies environmental priorities. Lack of solution to the hotspots problem is generated also by the fact that remediation and cleanup cost estimates are high and have de-motivating effect. Therefore, the environmental issues demand carefully planned approach and regional capacity that would gradually lead to complete hotspots cleanup. As a part of the project “Strengthening capacities in BiH to address environmental problems through remediation of high priority hot spots” priority hotspots are identified, for which are developed project backgrounds and suggested remediation/cleanup. Identification and prioritisation was based on the multi-criteria analysis with respect primarily to the environmental risk, regional impact and cleanup costs.

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2 Methodology  for  hotspots  identification  and  prioritization  

One of the objectives of the project “Strengthening capacities in B&H to address environmental problems through remediation of high priority hot spots” is identification of priority hotspots. Since the national legislation does not recognize term of hotspots and official hotspots list does not exist need for determination of general hotspots identification methodology, within which other spots will be determined, emerged. Although the site identification was performed very professionally, lack of time, resources and investment has set strings to the more detail investigation. Hence, all mentioned sites should be thoroughly studies, before remediation and the list should be updated in the future. The proposed methodology for identification is organized in phases:

1. Baseline assessment 2. Site assessment 3. Preliminary site investigation 4. Site prioritization 5. Development of projects for remediation of contaminated sites.

2.1 Baseline  assessment  

Baseline assessment includes development of questionnaire and organization and attendance at various meetings. All relevant ministries, entity and cantons, are consulted in order to obtain up-to-date and relevant information, as well as official statements. These actions are important due to the validation of presented data and information accuracy. Besides, this phase includes investigation of all documents and reports dealing with the contaminated locations or hazardous wastes inadequately disposed.

The identification of suspected sites in this project is partly based upon a questionnaire, partly upon a list of suspected sites provided by Hazardous waste document1. This report starts the identification of contaminated sites with the development of a questionnaire that is sent to various addresses:

• major industries, • currently operating disposal facilities, • war and post war situation related contaminations, • ministries responsible for waste and environment, • municipalities in which major industries and mines are located.

The obtained data has to be organized and checked for double entries, e.g. from reports and questionnaire. Some information may be difficult to relate to an exact location, and/or in other ways be insufficient or flawed. In such circumstances inquiries for clarification may be addressed to the sources that originally provided the information or other relevant parties. Result of this phase is the list of potentially contaminated and polluted sites than needs to be verified.

2.2 Site  assessment  

In order to rule out mistaken sites, after the preliminary list is determined it is necessary to perform site assessment. The objective of this phase is to verify presence of potentially contaminating sites existing as a result of former activities and presence of hazardous waste. The assessment is based on 1 Environmental protection assessment report for industrial, medical and other hazardous wastes in B&H, 2002-2006, Bosna-S

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the visual inspection and visual identification of polluted site impacts. The inspection should give the opportunity of supplementing the information on the sites on some basic parameters important for the next steps in the process:

• verification of past activities, • usage and state of nearby surroundings, • coordinates of the site, • maps, • photos.

List of contaminated sites is determined based on site inspection and general knowledge on threats of different potentials as well as on site’s history. During this, locations with obvious immediate risks to public health are identified. It may be possible that sites appear to be obviously mistakenly reported and they are therefore to be removed from the list of suspected sites that will determine some future investigations.

2.3 Preliminary  site  prioritization  

Preliminary site investigations will form the basis of ranking of sites for project development, but these investigations may be relatively costly and time consuming. Hence, site prioritization is performed before site assessment, based on the previous phases findings. It is ensured that some basic parameters validating current situation and potential impacts and threats are obtained. These are:

• Former activities – sources and processes • Hazardous risk based on the identified waste • Extent of the impact • Surface of contaminated site • Sensitivity of the site • Potentials for contamination at regional level.

The detailed site ranking and prioritizing can be carried out only after detailed investigations and measurements have been performed. In that case, it is suggested to develop by the simplified risk ranking mechanism.

2.4 Preliminary  site  investigation  

Site investigation implies identification of polluted sites based on the previous phases, where the data on polluted and non-polluted sites is clarified. It considers the sensitivity of the affected or in time potentially affected (threatened) area to estimate human health or ecological risk. A variety of methods may be part of the site investigations depending on the purpose (e.g. geophysical surveys of ground, boreholes, sampling of soil and groundwater, chemical analysis of waste, soil, groundwater and soil gas, etc.). Having in mind the purpose of this project and time and resources needed for such detail investigation, list updating is limited to previous phases and contamination clarification. Moreover, it should be investigated if for some sites remediation projects are already suggested and what is their status.

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2.5 Final  ranking  and  prioritization  

At this final phase all sites will be evaluated and ranked regarding the hazardous risk potentials and priority for remediation. Final numerical value will be calculated based upon the values of different site data. The criteria that will be ranked are:

• Hazardousness (hazard characteristics of disposed waste, leachability of waste, cross border pollution potential, presence of water, land use, etc.) • Environmental risk (potential for contamination of ground and surface waters and soil, contamination of nearby surface, potentials for bioaccumulation, deterioration of land) • Extent of the site • General site characteristic • Potential of regional pollution • Sensitivity of location • Public health risks • Remediation/cleanup costs • Economical issues.

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2.6 Methodology  summary

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3 Institutional  framework  

After signing of the Dayton Peace Accord, under its Constitution (Annex 4), Bosnia and Herzegovina (B&H) became administratively divided into two semi-independent entities: Federation of B&H and Republika Srpska. An additional region in Bosnia-Herzegovina is the District of Brcko, which is independent of both entities. The Federation of B&H (FB&H) is a decentralized entity and consists of ten cantons, which have a high degree of freedom in establishing authoritative functions and their implementation, while Republika Srpska (RS) is a centralized entity. The existing institutional structure in Bosnia and Herzegovina does not include state-level institutions dealing with environmental issues. Under the Dayton Peace Accord, environmental issues are under the jurisdiction of each of the two entities. All government functions and authorities that are not explicitly entrusted to state-level institutions under the Constitution are to be governed on the Entity levels (Paragraph 3 of the same Article). This implies that laws on environmental protection and waste management are passed separately in both entities. Therefore, institutions responsible for environmental protection have been established on the entity level (and cantonal level in FB&H). However, the Constitution has left a possibility that some authorities -under mutual agreement- can be transferred onto joint inter-entity (that is) state bodies and institutions. State –level institutional structure is as follows:

• B&H Parliament (House of Peoples and House of Representatives) • Presidency of B&H (three rotating members) • B&H Council of Ministers • Constitutional Court of B&H • Central Bank

Under the Constitution, Bosnia and Herzegovina's administrative structure is linked to the entity governments (FB&H and RS) through the Council of Ministers.

3.1 Inter-­‐entity  bodies  

The Commission for Coordination of Issues in Water Management Sector is responsible for the cooperation between the ministries responsible for water issues and management in both entities. Its goal is to prevent possible conflicts in the water management sector. The Commission deals with the following issues:

• International contracts related to water management issues; • International water paths; • International water management projects; • Cooperation with Republic of Croatia and Serbia on water related issues; • Harmonization of present and future regulations from the water management field; • Harmonization and monitoring of water quality standards; • Harmonization of solid waste disposal program - protection of water resources; • Harmonization and control of work of laboratories for monitoring of water quality and water streams categorization; • Construction and reconstruction of water management facilities on and nearby the entity line; • Facilities divided by the entity line; • Harmonization of plan documents from the field of water management for facilities divided by the entity line; • Collection and exchange of data (inter-entity and international); • Harmonization of plans for flood protection and other extreme situations.

Another Inter-Entity Body is Environmental Steering Committee, the institution responsible for inter-entity coordination in the field of environment. The Memorandum of Understanding established this inter-entity body, which is under the direct control of their governments. BiH institutions are not responsible, nor affect their operation. Inter-Entity Environmental Steering Committee was founded in 1998. in order to deal with specific environmental issues delegated by the entity. The Board

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consists of eight members. Its secretariat services are provided through the local office of Regional Centre for Education (REC).

3.2 Institutional  structure  regarding  waste  in  B&H    

Under its constitution, the Federation is defined as a decentralized entity where the cantons are given the basic authorities and rights. Article 2(c) in Chapter III of the FB&H Constitution (“Division of authorities between Federal and Cantonal institutions”) defines the environmental protection policy in FB&H and its cantons. The Constitution establishes the sharing of competencies between the Federation and the constituent cantons as follows:

• Institutions at the Entity level in FB&H related to waste management: o Federal Ministry of Urban Planning and Environmental Protection – waste

management planning, legislation and policy, o Federal Ministry of Energy, Mining and Industry - industrial waste management o Federal Ministry of Agriculture, Water Management and Forestry – wastewater

discharge controls, monitoring and management o Federal Ministry of Traffic and Communication - control over transportation of

hazardous wastes o Federal Ministry of Education, Science, Culture and Sports - education and training

in the sector of environmental protection, as well as public information and media support

o Federal Ministry of Health - health-care waste management o Federal Ministry of Justice - penalties for violations of procedures and standards

• Institutions at the Cantonal level in FB&H related to waste management: o Ministries of Reconstruction, Development and Environmental Protection – waste

management plans, legislation and policies o Ministries of Agriculture, Water Management and Forestry - wastewater discharge

controls, monitoring and management o Ministries of Health - health-care waste management o Ministries of Administration and Judiciary - penalties for violations of procedures

and standards • Institutions at the Municipal level in FB&H related to waste management.

Illustration 1 Administrative structure of B&H

The municipal structures supporting waste management are currently integrated with municipal communal services responsible for a wide variety of issues including almost all functions of waste management:

• Communal Services are responsible for waste management plans, legislation and policies at the local level • Municipal companies (public utilities) are responsible for collection and disposal of all urban waste produced in municipalities.

Municipality level  

Cantonal level  

Entity level  

State level   Tripartite presidency  

Federation  

Cantonal governments  

Municipal Assemblies  

Cantonal Assemblies  

Republika Srpska  

Municipal Assemblies  

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Article 35 of the RS Constitution states that: “Every person has a right to live in a healthy environment. Every person is obliged to improve and protect environment as much as possible and in accordance with the law.” The constitutional amendment IV (and XXXII) states that: “Republika Srpska ensures and regulates environmental protection” (among other issues). The constitutional amendment XV states that: “Each municipality ensures and regulates provisions of public communal services through its bodies and in accordance with the law.”

• Institutions at the Entity level in RS related to waste management: o Ministry of Urban Planning, Construction and Ecology - waste management

planning, legislation and policy; o Ministry of Health and Social Care - health-care waste management; o Ministry of Industry, Energy and Mining - wastes from mines and power plants,

industrial waste; o Ministry of Agriculture, Forestry and Water Resources- wastewater discharge

controls, monitoring and management; o Ministry of Transport and Communications - control over transportation of

hazardous wastes; o Ministry of Justice - penalties for violations of procedures and standards; o Ministry of Education and Culture - education and training in the sector of

environmental protection; o Ministry of Science and Technology - research in the field of waste management

and public information and media support. There are no state level institutions dealing with the waste management issues, and jurisdiction is at entity and cantonal level. Development of institutions for efficient management of hazardous waste should be performed through all waste management institutions. The inter-entity body coordinates waste and water management sectors, but does not have authority to proclaim laws and regulations. Under the entities, cantons and municipalities are responsible for environmental issues.

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4 Legislation  and  regulation  governing  waste  management  

One of the prerequisites for accession of Bosnia and Herzegovina to the European Union (and that of other countries in Central and Eastern Europe) is harmonization of its policies and legislation with policies and legislation of the EU as well as establishment of efficient implementation structures. In order to stimulate the countries in Central and Eastern Europe (CEE countries) in their efforts on preparing for accession to the European Union (EU), the Council of Europe adopted a comprehensive preparation strategy in December 1994 inviting the Commission to prepare a White Paper – preparation of the associated countries of central and eastern Europe for integration into the internal market of the union. The White Paper has been prepared and published in Brussels in 1995. It was translated and published in Bosnia in the year 2000 (published by the Ministry of Foreign Affairs of Bosnia-Herzegovina). The White Paper relates to six CEE countries that had signed association agreements already in 1995. However, it will also refer to other countries that are negotiating the signing of the agreements with EU, including Bosnia-Herzegovina. The White Paper is focused on the measures of the Union that create and support internal market and does not cover the full EC legislation and policy. Therefore, the White Paper includes only legislative that directly influences the free movement of goods and services so it does not include most of the provisions for environmental protection. Important parts of legislation related to air and water quality standards and protection of nature have not been included in the White Paper. The waste strategy has been covered to a limited extent. Since environmental protection is of wider public interest for every country, the assessment will cover the basic legislative and regulative governing a wide range of environmental protection issues and not only provisions from the White Paper.

4.1 General  information  about  EU  legislation  and  regulation  regarding  waste  

Significant progression regarding the harmonization of national legislative with EU directive was made after the Law on environmental protection, Law on waste management, Law on air protection, Law on nature protection and Law on environmental protection fund were enforced in the year 2003. Further harmonization was accomplished through the acquisition of enforcement regulations Previously mentioned environmental laws determine the need for acquisition of specific sublegal documents and define responsibilities. Until now, 25 sublegal acts have been proclaimed, while 50 more need to be enforced.

Table 1: Overview of enforced legal acts and those that still need to be enforced

Environmental laws BiH Number of enforced legal acts

Number of legal acts which are waiting for the enforcement

Law on environmental protection 6 17 Law on air protection 9 5 Law on waste management 8 12

Law on nature protection 2 11 Law on environmental protection fund 0 5

TOTAL 25 50

Table 2: Environmental laws - level of harmonization with the EU directives

Law

on

envi

ron

men

tal

prot

ecti

on Directive

Level of harmonization

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Environmental Impact Assessment Directive 85/337/EC, amended by 97/11/EC Directive

87%

Strategic Environmental Assessment Directive 2001/42/EC

3%

Directive 2003/4/EC on public access to environmental information

54%

Hor

izon

tal l

egis

latio

n

Directive 2003/35/EC providing for public participation in respect of the drawing up of certain plans and programs relating to the environment

3%

Integrated pollution prevention and control Directive 96/61EC (IPPC), amended and supplemented with 2003/35/EC, 2003/87/EC, EC 1882/2003, 166/2006

60%

COMAH Directive (Seveso II) for the control of the risk of major accidents involving dangerous substances 96/82 / / EC, which was amended by Directive 2003/105/EC and bylaw EC 1882/2003

64%

Regu

latio

ns

rega

rdin

g in

dust

rial

pollu

tion

Directive on large combustion plants 2001/80/EC 18% Directive on waste 2006/12/EC 32% Directive on hazardous waste 91/689/EC amended by Directive 94/31/EC and bylaw EC 166/2006 26%

Direcive on sewage sludge 86/278/EC amended by Directive 91/692/EC and bylaw EC 807/2003 26%

Directive on packaging waste 94/62/EC amended by Directive 2004/12/EC i 2005/20/EC and bylaw EC 1882/2003 5%

Directive on landfills 99/31/EC amended by bylaw EC 1882/2003 30%

Law

on

was

te

man

agem

ent

Directive on waste incineration 200/76/EC 90% Directive on the conservation of natural habitats and wild fauna and flora 92/43/EC amended by Directive 97/62/EC and bylaw 1882/2003 EC

17%

Law

on

natu

re

prot

ectio

n

Directive on conservation of wild birds 79/409/EC, amended by Directive 81/854/EC i 85/411/EC, 86/122/EC, 94/24/EC and bylaw 807/2003 EC

4%

Framework Directive on air quality /62/EC amended by bylaw 1882/2003/EC 36%

Directive on limiting values for SO2, NO2, NOx, particulate matter and Pb in the air 99/30/EC

14%

Directive on limiting values for benzene and CO 2000/69/EC 20% Directive on ozone 2002/3/EC 22%

Law

on

air p

rote

ctio

n

Directive on arsenic, Cadmus, mercury, nickel and polycyclic aromatic hydrocarbons in the air 2004/107/EC

3%

Framework directive on waters 2000/60/EC amended by Decision 2455/2001/EC 86%

Directive on cities wastewaters treatman 91/271/EC 35%

Regu

latio

ns r

elav

ant

for w

ater

pr

otec

tion

Directive on drinking water quality 98/83/EC 58% Note: The data listed in table 2 are given in the Annual Progress Monitoring Report for B&H, year 2009, prepared by the Ministry of environment and tourism FB&H.

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4.2 Waste  legislation  in  B&H  

4.2.1 Current laws and special regulations governing wastes and hazardous wastes Currently in force are Law on Waste Management of FBiH (Official Gazette FBiH, No. 33/03), which regulates the management of waste, type of waste to be disposed on landfills, etc. and Law on Waste Management of Republika Srpska (Official Gazette RS, nb. 52/02) at the entity level. Following laws and regulations regarding waste exist in B&H:

• Law on Waste Management (Official Gazette of the FBiH, no. 33/03, 72/09) • Law on Waste Management (Official Gazette of Republika Srpska, no. 53/02) • Rules on Special Control Regime of Activities that Endanger or May Endanger the Environment (Official Gazette of SR BiH no. 2/76 and 23/76). Amendments to the law given in Official Gazette of SR BiH 23/82 and 26/88. • Regulation on Financial Guarantees for Insurance of Transboundary Movement of Wastes (Official Gazette of the FBiH, no. 41/05) • Regulation on Obligation of Reporting on the Implementation of Surveillance, Monitoring and Record Keeping Under the Terms of the License for Operators and Waste Producers (Official Gazette of the FBiH, no. 31/06) • Regulation on Selective Collection, Packaging and Labelling of Wastes (Official Gazette of the FBiH, no. 38/06) • Regulation on Financial and Other Guarantees for Covering the Risk of Possible Damage, Remediation and Closure Procedures for Landfill (Official Gazette of the FBiH, no. 39/06) • Rules on Conditions for Transfer of Liabilities from Producers and Sellers to Operators of the Waste Collection System (Official Gazette of the FBiH, no. 9/05) • Rules on Handling of Hazardous Waste that is Not in the Waste Catalogue or Whose Content is Unknown (Official Gazette of the FBiH, no. 09/05) • Rules on Waste Catalogue (Official Gazette of the FBiH, no. 09/05) • Rules on the Content of the Conformance Waste Management Plan for Existing Plants for Waste Treatment or Disposal and Activities Undertaken by the Competent Authority (Official Gazette of the FBiH, no. 09/05) • Rules on Working Conditions for Waste Incineration Plants (Official Gazette of the FBiH, no. 12/05) • Rules on Issuance of Permits for the Activities of Small Business in the Waste Management (Official Gazette of the FBiH, no:09/05) • Rules on Medical Waste Management (Official Gazette of the FBiH, no. 77/05) • Rules on Animal Waste and Other Non-Hazardous Materials of Natural Origin that Can be Used in Agriculture (Official Gazette of the FBiH, no. 8/08) • Rules on Form, Content and Procedure of Informing about Important Characteristics of Products and Packaging by the Manufacturer (Official Gazette of the FBiH, no. 8/08) • Rules on Waste Types and Activities in Waste Management that Require a Permit (Official Gazette of Republika Srpska, no. 39/05, 3/07) • Rules on Waste Categories, Characteristics which Classify it as Hazardous Waste, Activities of Component Recovery and Waste Disposal (Official Gazette of Republika Srpska, no. 39/05) • Rules on Waste Catalogue (Official Gazette of Republika Srpska, no. 39/05) • Rules on the Content of the Conformance Waste Management Plan for Existing Plants for Waste Treatment or Disposal and Activities Undertaken by the Competent Authority (Official Gazette of Republika Srpska, no. 39/05) • Rules on Working Conditions for Waste Incineration Plants (Official Gazette of Republika Srpska, no. 39/05) • Rules on Hazardous Waste Transport (Official Gazette of Republika Srpska, no. 86/05) • Rules on Conditions for Transfer of Liabilities of Waste Management from Producers and Sellers to Responsible Person of the Waste Collection System (Official Gazette of Republika Srpska, no. 118/05) • Rules on Financial Guarantees for Insurance of Transboundary Movement of Wastes (Official Gazette of Republika Srpska, no. 86/05) • Rules on Medical Waste Management (Official Gazette of Republika Srpska, no. 90/06)

4.2.2 Waste Management Law in FBiH The aim of the law (Article 1) is to encourage provision of the most significant conditions for

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prevention of waste production, as well as conditions for re-use and recycling of waste, separation of secondary raw materials and their use for production of energy and the final waste disposal. The Law has 60 articles, while about twenty of them directly or indirectly involve hazardous waste. The law (Article 3) governs: All categories of waste except for:

• Radioactive waste, • Gaseous emissions into atmosphere, and • Waste waters. • All activities, operations and facilities for waste management.

Apart from the key principles, definitions, authority and responsibility, as well as penalties, transitional and final provisions, the law also covers:

• Obligation of planning waste management (Article 6) as well as the general provisions on Waste management strategy (Article 8). • Obligations of administrative bodies and the system of authorization and control for the activities of waste management (Articles 9-11), provisions on content of requests for issuance of permits, and permits (Articles 12 and 13), as well as financial guarantees (Article 14). • Obligation of supervising waste management (Articles 16-19) and record keeping on reports and information sheets important for the supervision over waste producers and waste processing operators (Article 17) amid conditions from permits and/or regulations. • General provisions for waste management activities (Article 15) and environmental responsibility of producers, sellers of goods and waste processing operators (Articles 16-24), as well as special provisions on communal waste management (Articles 25- 28) • General provisions (Articles 29-35) on waste handling (collection, treatment, recovery, transport and final disposal, including incineration of hazardous waste, general provisions on hazardous waste (Article 36) and cadastre of polluters (Article 37). • General provisions (Articles 38, 42-46) on trans-boundary movement of waste (based on the provisions of the Basel Convention), and the sale of waste, transport inside BiH and over the country’s territory (Articles 39 - 41), as well as provisions on notice to be given in cases of inter-entity movement of hazardous waste with the purpose of its final disposal (Article 47). • General provisions on monitoring of waste management implemented by waste producers and operators (Article 48-49) and general provisions on inspection (Article 50 and 51). • Penalties (Articles 52-54), transitional and final provisions (Articles 55 - 60).

Article 58 of the Law lists other articles that require preparation of special regulations aimed at the implementation of the Law. The law identifies the deadlines and specific bodies responsible for passing specific regulations.

4.2.3 Waste Management Law in RS The aim of the law (Article 1) is to encourage provision of the most significant conditions for prevention of waste production, as well as conditions for re-use and recycling of waste, separation of secondary raw materials and their use for production of energy and the final waste disposal. The Law has 61 articles, while about twenty of them directly or indirectly involve hazardous waste. There also exist four annexes to the law:

• Annex I: Categories of waste • Annex II: Properties of wastes which render them hazardous • Annex III: Operations which may lead to recovery • Annex IV: Disposal operations.

The law (Article 3) governs all categories of waste except for:

• Radioactive waste, • Gaseous emissions into atmosphere, and • Waste waters. • All activities, operations and facilities for waste management.

Apart from the key principles, definitions, authority and responsibility, as well as penalties,

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transitional and final provisions, the law also covers:

• Obligation of planning waste management (Articles 7-11) as well as the contracts for handling specific types of waste, including hazardous waste. • Obligations of administrative bodies and the system of authorization and control for the activities of waste management (Articles 12 and 13), as well as provisions on content of requests for issuance of permits, and permits. • Obligation of supervising waste management (Articles 16-19) and record keeping on reports and information sheets important for the supervision over waste producers and waste processing operators (Article 17) amid conditions from permits and/or regulations. • General provisions for waste management activities (Article 20) and environmental responsibility of producers, sellers of goods and waste processing operators (Articles 21-29), as well as special provisions on communal waste management (Articles 30- 33) • General provisions (Articles 34-40) on waste handling (collection, treatment, recovery, transport and final disposal, including incineration of hazardous waste - • General provisions (Articles 43, 47-51) on trans-boundary movement of waste (based on the provisions of the Basel Convention), and the sale of waste, transport inside BiH and over the country’s territory (Articles 44 - 46), as well as provisions on notice to be given in cases of inter-entity movement of hazardous waste with the purpose of its final disposal (Article 52). • Penalties (Articles 53-56), transitional and final provisions (Articles 57 - 61).

Article 60 of the Law lists other articles that require preparation of special regulations aimed at the implementation of the Law. The law identifies the deadlines and specific bodies responsible for passing specific regulations.

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4.2.4 GAPs and discrepancies – EU and B&H Issues RS FBIH EU Comments

Terminology Pollution Yes, defined in Law on

environmental protection, article 4., Law on air protection, article 4, Law on waters, article 4 (direct or indirect introduce of substances, heat, noise, etc. that can be harmful for the environment and health)

Yes, defined in Law on environmental protection, article 4., Law on air protection, article 2, Law on waters, article 9 (direct or indirect introduce of substances, heat, noise, etc. that can be harmful for the environment and health)

Council Directive 96/61/EC (IPPC Directive), art .2.2; (pollution shall means the direct or indirect introduction, as a result of human activity, of substances, vibrations, heat or noise into the air, water or land which may be harmful to human health or the quality of the environment, result in damage to material property, or impair or interfere with amenities and other legitimate uses of the environment

The terms contamination, pollution, emission, dangerous substances, and similar terms have to be clearly distinguished from each other. In the entity laws this term is adopted

Risk Law on environmental protection, article 4

Law on environmental protection, article 4 (possibility of a performance within a specified period or in certain circumstance)

ELD, article 2 Not clearly defined in the national laws.

Recovery Law on waste management, article 4

Law on waste management, (Official gazette FBiH, nb. 33/03): “waste recovery" – means waste recovery and energy from used products or waste within the economy system through use of specific technological process or incineration.

ELD, art 2.15 The exact definition as in the ELD is transposed into B&H regulation

Hazardous substance

Law on waste management, article 4

Law on waste management, article 4 (Means a substance, mixture or preparation of substances determined by implementing regulations, which is present as a raw material, by-product, product, residue or intermediate, including those substances for which it

Directive 1999/45/EC

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Issues RS FBIH EU Comments Terminology

is reasonable to expect to arise in the event of an accident)

Contamination Law on waste management, article 44 (in sense of waste contamination at the dumpsites and landfills) Law on protection of agricultural land, article 19 (in sense of soil contamination through introduction of different solid, liquid and gaseous, as well as radioactive elements, that led to the change in soil quality and accumulation of these substances in plants)

Law on waste management, article 37 (in sense of waste contamination at the dumpsites and landfills) Law on protection of agricultural land, article 8 (in sense of soil contamination through introduction of different solid, liquid and gaseous, as well as radioactive elements, that led to the change in soil quality and accumulation of these substances in plants)

Several directives; Soil protection Act should clearly define the concept of pollution versus contamination

Hotspots National environmental action plan, Environmental protection assessment report for industrial, medical and other hazardous wastes in B&H 2006. (no definition, just indicative mentioning of locations)

National environmental action plan, Environmental protection assessment report for industrial, medical and other hazardous wastes in B&H 2006. (no definition, just indicative mentioning of locations)

“Hotspots” are point pollution sources which may affect human health, ecosystems, biodiversity, sustainability, or economy.

The legal definition of Hotspot does not exist and it is recommended to use term contaminated site

Damage Law on protection of agricultural land, article 25: (in a sense of field damage, crops and plants) Law on nature protection, article 69 (damage of nature and its components in the form of any changes or pollution of nature (or its components), or the use of nature (or its components) to the extent that there is no possibility of restoration of damaged nature (or its components) and return to

Law on protection of agricultural land, article 8: (Damage to land includes destruction of physical, chemical and biological properties of soil, and reflects through the following forms: infections, pollution, degradation and destruction); Law on nature protection, article 6 (damage of nature and its components in the form of any changes or pollution of nature (or its components), or the use of nature (or its components) to the extent that there is no possibility of

ELD; Art. 21 & 2.2

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Issues RS FBIH EU Comments Terminology

the natural or original state (quality), which has a negative impact on flora and fauna)

restoration of damaged nature (or its components) and return to the natural or original state (quality), which has a negative impact on flora and fauna)

Remediation Law on agricultural land, Article 30 and 31 (in a sense that recultivation project for the damaged soil should be performed)

Law on agricultural land, Article 8: (Soil remediation/recultivation system includes technical, agro technical and biological measures and procedures which puts back soil/land to its original purpose)

ELD2 art. 2 -‘remedial measures' means any action, or combination of actions, including mitigating or interim measures to restore, rehabilitate or replace damaged natural resources and/or impaired services, or to provide an equivalent alternative to those resources or services as foreseen in Annex II Proposal for a EU soil directive: “Remediation”: actions on the soil to remove, control, contain or reduce pollutants so that the contaminated site no longer poses any significant risk to human health or the environment, taking account of its current use and approved future use

It is proposed that the definition of remediation be included both in the Soil protection Act and through an amendment to the Environmental Protection Act.

Legislation Polluter pays principle

Law on environmental protection, Article 11; Law on waste management, Article 5; Law on environmental protection fund

Law on environmental protection, Article 11; Law on waste management, Article 5; Law on environmental protection fund

Diff. directives

Liability Law on waste management, Article 5;

Law on waste management, Article 5;

Yes – the ELD

2 Environmental Liability Directive (ELD) - Directive 2004/35/CE of the European Parliament and of the Council of 21 April 2004 on environmental liability with regard to the prevention and remedying of environmental damage

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Issues RS FBIH EU Comments Terminology

Law on environmental protection, article 9

Law on environmental protection, Article 2, 9, 11

Soil Law on protection of agricultural land

Law on protection of agricultural land

Yes, diff. directives – new directive on soil in preparation, see: “Proposal for a Directive of the European Parliament and of the Council establishing a framework for the protection of soil and amending Directive 2004/35/EC”

Funding for remediation and closure

Only fund for environmental protection

Only fund for environmental protection

Yes ELD No precise direction on remediation funding except for the “polluters pay” principle. Hence, “inherited” hotspots, without legal owner are responsibility of government.

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4.3 Legislation  -­‐  summary    

The legislation overview shows the current situation regarding the harmonization of national regulations and EU directives indicating the level of conformity. The 25 legal environmental acts are enforced and 50 is still waiting for the enforcement. The presented legal assessment identifies existing gaps with the current entities legal framework and recommendations for improvement such as adding of new required definitions, deleting of synonyms, development of an soil protection act and incorporating of remediation within different legislation.

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5 Hotspots  management  in  B&H  

Environmental hotspots in Bosnia and Herzegovina represent burdens left behind by the industry that has by now been mostly privatized. During the after-war period B&H was focused on the reconstruction, privatization and movement towards free market economy, so the unsolved environmental issues remained behind. Namely, within the process of privatization, old environmental burdens by state-controlled industry i.e. problems that were once (theoretically) the governments have now been transferred over to new owners, in most cases without clear specification of environmental responsibility. In most of the cases, unsolved waste management issues and existing hot spots became a problem of the state and under its jurisdiction. It can also be assumed, that accidents happened in the past, on which environmental liability cannot more be addressed clearly are also part of future governmental activities. Contaminated sites, mostly industrial, represent great threat to the environment and public health. Situation in B&H is becoming even more complicated due to the lack of data and legislation. Environmental impacts of most of the contaminated sites are of regional character and should be dealt with urgently. Basic policy dealing with environmental issues is a national document NEAP from 2003 (mentioned earlier) within which is not indicated proper action plan or responsibilities. Still, this document can serve as a base for further studies regarding environmental problems since it identifies environmental priorities. The national Environmental plan from 2003/2004 identifies 100 environmental projects presenting the potential hotspots. In the year 2006 Federal Ministry of Environment and Tourism produced the Environmental Assessment Protection report on Industrial, Medical and other Hazardous waste in Bosnia and Herzegovina containing information about the waste producers and locations at which hazardous waste is disposed improperly endangering the environment and representing high risks locations. The new Waste Management Strategy for the Federation of B&H from 2008 deals with the hazardous waste only, without going into detail of hotspots risk assessment or remediation.

Most of the hotspots noted in the documents referred earlier have not been studied in more detail; nor is there proposal for the solution of their remediation. Moreover, even the term “hotspots” is not legally recognized.

5.1 Proposals  for  improvement  of  hotspots  management  in  B&H  

In general, the problem of hazardous waste has been neglected for various reasons. An adequate waste management system does not exist in BiH. Legislation and regulation is not harmonized with the European Union demands and existing provisions are not fully implemented. Supervision of waste flows is not efficient. Most of industrial waste, mostly containing hazardous wastes ends up on illegal dumpsites or is discharged into rivers. For the Environmental issues in B&H are responsible entity governments that have separate laws and neither of the entity has laws or bylaws regulating hotspots. Namely, hotspot as a term in national legislation is not recognized and their identification procedures are not defined. Most of the industrial waste, representing the biggest environmental burden, was inherited from the past and new industry owners and operators are facing problem of its removal and devastated infrastructure. Lack of wastewater treatment systems, air-pollution abatement and monitoring, and industrial and communal waste management creates critical environmental situation with significant number of indentified/recognized hotspots. Due to the geographical position of Bosnia and Herzegovina and its connectedness with the other Balkan countries, risk of significant cross border impact as a result of pollution in B&H is high (rivers, lakes). Remediation of these sites and investment in financially demanding infrastructure would prevent further pollution and will attract new investments from private sectors, banks or donors.

Lack of solution to the problem hotspots is generated also by the fact that remediation and cleanup cost estimates are high and have de-motivating effect. Therefore, the environmental issues demand carefully planned approach and regional capacity that would gradually lead to complete hotspots cleanup. Careful design of initial steps based on environmental priority and present risk, as well as high benefit to cost ratio by necessity also requires general solutions and wider distribution of

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environmental, social and economic benefits. These solutions must be made on agreement with the stakeholders and public in order to plan future environmentally oriented activities or infrastructure.

With that in mind, we recommend the following:

• To pass an act (regulation, instruction) on hotspots, within which the term itself, the methodology for identification of hotspots and the risk assessment would be regulated (responsibility of Entity governments); • Prepare regulations (instructions, guidelines etc) on types of waste and hazardous waste that would also include detailed information for better understanding of the hazardous waste list (in accordance with Decision 94/904/EC). The main objective of such regulations is to establish a controlled system of hazardous wastes management in BiH; • " Develop Hazardous Waste Management System in Bosnia and Herzegovina, i.e. prepare hotspots identification matrix, assessment and investigation process (identification process, site assessment, liability clarification and site prioritization, preliminary site investigation); • Collect data and analyze options for use of existing industrial and power producing combustion facilities with the aim of using available energy potentials of certain types of waste. Incineration of certain types of hazardous wastes (e.g. used oils, oiled waters, used tires etc.) in cement kilns.

Development of institutions for efficient management of hazardous waste should be observed through entire development of institutions for waste management. More funds and trained personnel are required in order to establish a comprehensive institutional structure necessary for development and application of entity, regional and local waste management plans and policies. It is important that the institutional structures for implementation of laws and standards in the area of waste management are coordinated from the top governmental authority. This is the basic prerequisite for local (cantonal and municipal) implementation of harmonised laws, politics and standards that are in effect in entire B&H.

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6 Hotspots  identification  

Identification of the hotspots was primary based on a comprehensive list of industrial facilities and power producing facilities that generate considerable quantities of hazardous waste. List of industrial facilities - potential generators of hazardous wastes:

• thermal-power plants and heating plants of thermal capacity over 50 MW • facilities for production and processing of oil and natural gas • production of raw iron, steel and iron alloys • production of precious and non-ferrous metals • production of chemicals, chemical products and artificial fibres • production using hazardous substances in products • cement production • cellulose production • paper and cardboard production • hazardous waste storages • communal and technological waste treatment facilities with capacity of over 10,000 tons/year • wastes from the war period.

Wastes from these industries are very different in terms of methods of their generation, type of industry, technological process, raw materials, used substances, composition, concentration of hazardous substances, physical state, etc.

6.1 Hazardous  wastes  from  industry    

A significant portion of hazardous wastes generated in mines, metallurgy, thermal power plants, basic chemical industry, etc. are often called heavy industry hazardous wastes. An important feature of this type of waste is that the generators themselves carry out treatment and disposal of the wastes. Practically all heavy industry facilities have specially designed and constructed disposal sites where this waste is disposed. The location of each of the disposal sites was selected during the period of construction of these facilities according to the regulations present at that time.

6.1.1 Influence of Heavy Industry Wastes on the environment While investigating waste and its influence on the environment, it is required to identify several effects. The following effects are especially important:

• Waste is disposed on the surface of soil, thus excluding the soil and the immediate surrounding areas are from use in agriculture and foresting; • Waste often contains some toxic materials, and it aggravates the characteristics of soil; • Presence of waste on the surface of soil can lead to contamination of drain and underground waters. This will appear as a result of filtration by precipitation waters;

Under the influence of wind, some particles of waste are often spread around the area. This specially happens with particles of silt (these particles have dimensions ranging from 0,05 to 0,002 mm) that are disposed on leaves of agricultural and forest cultures leading to their decay.

6.1.2 Influence of Heavy Industry Hazardous Wastes - Soil The influence of heavy industry hazardous waste disposed on special sites that are located in the close vicinity of the waste generator itself, can be classified as follows:

• Soil infection • Soil contamination • Soil degradation

Soil contamination in the narrow meaning of the word itself stands for contaminating the soil by different harmful, i.e. toxic matters. When we talk about soil, the following causes are especially important: heavy metals, organic pollutants, pesticides, mineral fertilizers, radionuclide and acid

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rains. They enter the soil in all three aggregate states: solid, liquid and gaseous. Production of many different pollutants is increased in the world today, which is a consequence of industrial and technological development. The process of contamination is not related to the soil only, and these consequences are also seen in other members of eco systems, such as water, vegetation and animal world. Any material, which causes inadequate changes in the soil, is dangerous waste. These changes in soil are manifested through their physical, chemical and biological changes. Consequences are reflected on the food quality and health of people and animals. Moreover, the production of high quality "healthy" food is especially endangered. Harmful materials can come from different resources in gaseous, liquid or solid state, that is, they can enter the soil in one of these states. Whether these materials will intoxicate soil depends on their quantity and the time period they take to react. For example, small quantities of rare elements such as Mn, Cu, Zn, Cr, Cd, Pb, Mo etc. in soil are necessary for plants as their nourishments, (see Table 2). However, in one relative overdose these 85 elements can be toxic, especially when marginal concentrations of these elements are exceeded.

6.1.3 Influence of Heavy Industry Hazardous Wastes - Water Many industrial wastewaters in B&H contain toxic materials, most often heavy metals, cyanides, phenols, mineral oils and emulsions, organic solvents (metal finishing industry) and other various toxic materials (basic organic chemistry, textile and leather processing industry). If discharged directly in river it will have numerous hazardous impacts on the river ecosystem. On the other hand, if treated, in the process of wastewater treatment these toxic materials are transferred to sludge that is most often uncontrollably disposed on open dumps. This type of sludge, containing various toxic materials falls into the category of hazardous waste and its practiced disposal methods has direct impact on water quality in rivers and groundwater, through leaching of water borne toxic substances or microorganisms from the waste matrix. Another type of hazardous wastes generated by various industries is the leftover from the production processes. Process leftovers are usually stored above ground in containment areas or ponds. If improperly secured, contaminants in waste can leach out into surface and groundwater causing serious pollution that can last for many generations. This is applicable to e.g. leather processing industries where leachate containing chromium compounds and organic matters leach from the piles of dumped leather leftovers or metal finishing industry where used oils and emulsions are filled in steel drums exposed to open air and vulnerable to corrosion. Unfortunately, until today, no environmental impact study was done to assess the impacts of hazardous wastes on water resources in B&H. Therefore, it is not possible to determine the individual effects hazardous waste disposal sites may have on water streams in B&H. However, it is possible, and as it was being done in the past, to determine cumulative pollution of water streams represented by pollution from direct municipal and industrial wastewater discharge, landfills, and other human activities. Bosnia and Herzegovina was one of the leading countries in the 80’s in the field of pollution control. At that time, a lot of progress has been made on development of legislation on pollution control and wastewater treatment and monitoring activities. Unfortunately, the war (1992-1996) has turned B&H back to the 70’s so that the monitoring concept is based only on monitoring of industrial pollution (effluent monitoring) and surface water monitoring, a control system dealing with the needs of the receiving environment. As a result of war activities, surface water-monitoring network is destroyed, so that current monitoring activities are brought to a minimum. A 75% of total industrial wastewater generated in B&H is discharged in river Bosna and its tributaries. According to the data from 1991, the total wastewater quantity generated in this region was 29.8 m3/s, of which 17.7 m3/s was discharged in Bosna River being classified as of IV class. The biggest industries and mining sites, as well as the biggest settlements are located in Bosna river basin having great influence on water quality. The greatest emission is from Tuzla region (chemical industry, coke production) and from mines and metal industry in Zenica. Wastewater generated in these two locations requires 71.3% of total water quantity needed to dilute toxicity in rivers of B&H. The heaviest individual industrial polluters are located in regions of Zenica (RMK Zenica), Tuzla and Lukavac (TPP Tuzla, soda industry, polyurethane industry and coke-chemical industry). In order to

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be able to dilute the toxic effects produced by industries located in Tuzla region only, it would be necessary to provide 46 % of water required for while for all water streams in B&H is 692 m3/s). Additionally, the water quantity required for these two tributaries is greater than their minimum monthly flows. According to data from 1991, majority of industries have constructed plants for only pretreatment and/or complete treatment of wastewaters. The greatest number of wastewater treatment plants is constructed in metal finishing industries, of which only several were functioning properly. Steel industry in Zenica, one of the greatest polluters in the country, does not have an adequate treatment or removal of heavy metals from their wastewater. The potential producers of heavy pollution, aluminium-producing industries do have facilities for treatment of red sludge. The Sarajevo wastewater treatment plant needs to be reconstructed and upgraded comparing to the pre-war capacities, which will mostly mitigate the impacts of municipal and industrial wastewaters from this region on Bosna river. However, it should be noted that, although the wastewater treatment plants solve the problem of wastewater and the direct discharge of heavy metals and other toxic substances into the rivers, the problem of wastewater treatment solid product, sludge, remains. Therefore, it is very important to ensure a proper handling and disposal of sludge formed in the process of industrial wastewater treatment. Collection, transport and final disposal of toxic sludge must be regulated so not to impair the quality of surface and groundwater. Another very serious problem is toxic pollution generated by active and abandoned mining sites. Each stage of the mining process has the potential for different impacts of various degrees. The impacts will depend on the sensitivity of local terrain, the type of technology employed, the skill and knowledge of the company and the ability to monitor and enforce compliance with environmental regulations.

6.2 List  of  identified  hotspots  

When defining and choosing locations having possible and dominant influence upon the environment, , the main criteria for choice of waste types was expanded by including the term - harmful, which accounts for pollutants that are not hazardous by themselves, but their presence in excess has negative side effects upon the soil, water and air. Data on potential hotspots was collected primary through the meetings with relevant entity ministries, upon which inquiring letters were sent to all cantons, selected municipalities and industries. Consultant needs to point out that back-information was not received from most of the subjects. Moreover, findings from the site visits and meetings show the lack of information and motivation regarding the hotspots sanitation and cleanup. Environmental problems are present, but there is no significant effort to solve them. Hazardous waste issues are under direct jurisdiction of Entity Ministries that do not posses, or they were not willing to give, information on potential hotspots. Nevertheless, consultant has managed to identify couple of hotspots whose sanitization would lead to the significant improvement of state of the environment and human health.

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Nb Project (title) Reconstruction of wastewater treatment plant: line for neutralization – former military industry Bratstvo, BNT Novi Travnik

Project description The former state owned military industry «Bratstvo» has been privatised after the war. One of its successors is public-private company BNT TMH (51% of the company is state owned). The company produces machines and hydraulics (steel welded constructions, thermal processing of steel and metals, surface protection by electrochemical and chemical processes, as well as painting, and mechanical and chemical cleaning of metal surfaces, etc.) and as a result of processing, significant amounts of chemicals and galvanization residuals are produced. All hazardous wastes, including polyvalent Chromium, Mercury and Zink, in significant concentrations, are being discharged into the river Grlovnica without any treatment. These elements stay suspended in rivers endangering the life in rivers and life of people living near the polluted areas. From river Grlovnica, pollutants flow to river Lasva and Sava, making this problem of regional significance. Pre-war toxic waste remains from the process of galvanisation wastewaters treatment were disposed and stored inadequately for a long period. Recently, the agreement for its removal has been made. However, the wastewater treatment line (line for neutralization), which was destroyed during the war, has not been rehabilitated to present time. Reconstruction of the wastewater treatment system would significantly improve state of the environment in wider area of Novi Travnik and Middle-Bosnian Canton, as well as the environmental conditions downstream of river Lasva, and basin of river Sava.

Contact: Mr. Emir Perenda, Executive director of BNT THM Novi Travnik, M. Spahe 1, 72290 Novi Travnik, email: bnt-thm@B&H.net.ba

1.

Duration 6 months Costs 300.000 KM

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Nb Project (title) Adaptation of SASE-Srebrenica industrial dump for protection of river Drina

Project description The Srebrenica SASE mine is the site at which the lead/zinc mining is performed. There are currently tenths of locations where contaminated mine waters exit to the surface and flow into local waterways. Pollution apparently ranges from iron contamination to the full suite of heavy metals that can be associated with lead/zinc ores. Polluted water runs into Krivaja river, which soon after flows into the Drina river at the Serbian border. Previous acute accidents are associated with the area - a tailing dam reportedly failed in the 1970s causing transboundary pollution. In general, lead-zinc mining and beneficiation leads to concerns with geotechnically unstable tailings wastes that can generate Acid Rock Drainage (ARD) with a pH 3 containing sulphates, Pb, Zn, Cu, Fe, Zn, Cd. In addition particulates pollution as blown dust and mine water effluents can be an issue. All mining residuals, around 3,5 millions of tons have been disposed at the barren on the area of 16,25 ha, at the mines exploitation field. The supportive dam of the barren is in a bad shape and in case of an eventual collapse of the barren barriers incidental pollution is highly probable. Hence, there is the urgent need for the site adaptation and construction of supportive dam.

Contact: Ms. Radmila Kostic, senior adviser, Ministry of Physical planning, civil engineering and ecology of Republika Srpska, tel: 051 339 653, email: r.kostic@mrg.vladars.net

2.

Duration Not known Costs 2.500.000 KM or USD 2 mil

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Nb Project (title) Clean-up of old leather waste dump yard– Leather industry KTK Visoko

Project description Leather industries in B&H process hides and perform their tanning with chromium compounds. As a result of processing of the raw hides, significant quantities of waste are produced. This waste is composed of meat trimmings and hair taken off the raw hide. The wastewater generated from the chemical tanning process is highly toxic comparing to the wastewater produced in the natural tanning. The sludge resulting from the wastewater treatment contains high concentrations of chromium that is very toxic to living organisms. Waste is disposed of in uncontrolled manner, mostly on landfills located within the plant, and sometimes on municipal landfills. Therefore, from the aspect of environmental protection, the leather industry has much more impact on the environment than the textile industry. The EWC code for this type of waste disposed at mentioned location is 040108. It is estimated that disposed leather occupies 9.000 m3 of space at an area of 0,3 ha.

Contact: Mr. Asmir Hodzic, KTK Visoko, tel: +387 32 738 111

3.

Duration Not known Costs Not known

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Nb Project (title) Rehabilitation of the Jajce industrial and municipal landfill

Project description During the pre-war period the arc furnaces of “ELEKTROBOSNA” Jajce actively produced ferrous silicate. Smelting activities of this kind generated pollution via emission of Ni, Cr, Fe, Cu and Zn and total ferrochrome dust to the atmosphere. Environmental concerns also include depositional soil contamination, waste/slag dumps and chemicals from the process. These pollutants also contribute to surface and ground water pollution. The waste/slag, at the time, was disposed of at the municipal landfill Zelenac at which the municipal waste is still being disposed of. Very limited data is available for this site at the present time and there is no data about the amount of waste/slag disposed, although it has consistently been reported as an environmental and health risk concern. Environmental risk is even more increased by the facts that stream Kraljevac flows directly through the dump while the dump is located near by river Vrbas. Inadequate waste management and disposal puts significant pressure on the environment and endangers the health of inhabitants downstream of river Vrbas.

Contact: Mr. Emir Zjajo, Jajce municipality, tel: +387 30 658 011

4.

Duration 6 months Costs 1.500.000 KM

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Nb Project (title) Sanitation of ashes disposal site - Kakanj TE

Project description Ashes created as a side product of combustion of coal in furnaces and boilers in TE Kakanj are disposed using dry disposal at the site near the Plant. Although classified as nonhazardous, this waste can contain radioactive elements as well as different metals. Estimations are that around 17.000.000 tones of ash are disposed until now at an area of 30,6 ha. EWC code of the waste disposed there is 100103. Until now, waste disposal was performed without any plan. Recently, adaptation plan and preliminary rehabilitation project for this industrial landfill is developed. Significant amounts of disposed waste create large pressure on the environment and underground waters. Investments needed for sanitation and adoption demand major investments are and additional financing is necessary.

Contact: Mr. Sahbaz Velispahic, Head of environmental managing section, tel: 032 771 162, email: s.velispahic@elektroprivreda.ba

5.

Duration 2 years Costs 25.000.000 KM

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Nb Project (title) Decontamination of soil contaminated by PCB oils from transformer stations in the vicinity of factory Incel Banja Luka

Project description Transformation stations used until 90es, in Incel factory (manufacture of pulp, paper and wood - chlorine bleaching process) ,upon their withdrawal from use, were inadequately stored in metal barrels in the area of Incel factory. in order to identify potential hotspots, regarding the inadequate usage and disposal of oils containing PCBs, a pilot project was performed by the company RECETOX . Result of the research was confirmation of soil contamination by PCB oil from transformation stations (measurements made in the year 2006 by Institute for ecology protection and informatics Banja Luka). During the years, surface of the barrels within wich the oil was, have suffered corrosion and oil have leaked contaminating the soil. Level of PCBs on several sampling sites in Banja Luka was as high as 400000 ngg-1 of the dry soil sample, which are two orders of magnitude higher than on any other investigated site performed by UMASA.RECETOX. Due to the findings, this site should be in the centre of attention of the following studies as all other hot spot sites and hence is proposed within this project.

Contact: Incel d.d. Banja Luka, Velka Mladenovića bb, Banja Luka, Tel: 051 450 104

6.

Duration Not known Costs Not known

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Nb Project (title) Cleanup of sites where are disposed bottoms and reaction residues – locations of factory DITA-Tuzla (2/3 of dumpsite surface) and Polihem (1/3 of dumpsite surface)

Project description Waste identified at the location of factories DITA and Polihem is product emerged from manufacturing processes of isocyanides chemistry - former Chlorine Alkali circuit - HAK II. EWC code of the disposed waste is 070108* and is highly toxic waste. Since the DITA and Polihem are not producers of this waste, financial solutions for site cleanup need to be searched for from potential donors. Amounts of the disposed waste are very significant. Liquid waste, produced during the process of TDI regeneration, was packed in tin barrels of 200 l placed on the PVC foil, around, which was places crude waste. Now the overall waste occupies the volume of 4.500 m3. Based on the type of the waste, there are two possible ways of final disposal: thermal processing or storage with pre-conditioning. Since in FB&H do not exist any facilities for this type of decontamination, only possibility is export.

Contact: Goran Misic, Ministry of spatial planning and environmental protection TK, email: goran.misic@gmail.com

7.

Duration 6 months Costs 5.000.000 KM

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Nb Project (title) Remediation/cleanup of waste oil lagoons - municipality of Modrica

Project description Oil waste streams generated by the Oil refinery in Modrica have been stored in oil sludge lagoons near the refinery for approx. 30 years. More than 30,000 tons of liquid and semi-liquid hazardous waste that were disposed of in 5 unprotected pits located near residential area (2 km away), represent sources of significant risks for public health in Modrica municipality and the environment - especially because of (i) uncontrolled emissions of organic vapours from the surface of the lagoons, (ii) contamination of groundwater by oil products, (iii) heavy soil contamination around and beneath the lagoons, (iv) risks arising from accidental contact of people (especially children), animals and other organisms with toxic waste stored in the unprotected lagoons. Sources of funding for the cleanup of the lagoons are not available. Government of RS and Ministry of Physical planning, civil engineering and ecology of Republika Srpska, currently cannot financially support the site remediation.

Contact: Ms. Radmila Kostic, senior adviser, Ministry of Physical planning, civil engineering and ecology of Republika Srpska, tel: 051 339 653, email: r.kostic@mrg.vladars.net

8.

Duration Not known Costs 11 000 000 KM

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Nb Project (title) Reconstruction of wastewater treatment plant – former military industry Pobjeda Gorazde

Project description In the area of former state company «Pobjeda» exist four public-private companies “Pobjeda Rudet”, “Pobjeda Sport”, “Tvornica Alata” and “Unis Ginex”. Companies are registered for production and turnover of chemicals, igniting and initiating means and production of machines and hydraulics (steel welded constructions, thermal processing of steel and metals, surface protection by electrochemical and chemical processes, as well as painting, and mechanical and chemical cleaning of metal surfaces, etc.) and as a result of processing, significant amounts of chemicals, explosive remains and galvanization residuals are produced. The prewar company has been established and started its production in 1951. It is world known manufacturer of initial means for military and civil (commercial) use. All hazardous wastes, including Chrome and Zink in significant concentrations, are discharged into the river without any treatment. Amounts for reconstruction are significant and company itself could not finance it. Companies posses environmental permit, which is in a phase of expiring and its reissuing depends on the reconstruction on wastewaters treatment plant. Reconstruction of the wastewater treatment system would significantly improve state of the environment in wider area of Gorazde and Gornjo-podrinjski Canton, as well as the environmental conditions downstream of river Drina.

Contact: Hasan Đozo, director Pobjeda Rudet, tel: 038 221 150

9.

Duration/status: 6 months, preliminary project design exists

Costs: 1.200.000 KM

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6.3 Hotspots  prioritisation  

In order to identify the hotspots priorities, methodology for prioritisation is developed, within which are used several criteria:

• Environmental and social criteria • Economic criteria • Sustainability and liability criteria.

Improvement of environmental and social conditions will lead to the improvement of quality of life and biotic systems in the area surrounding the location as well as in wider region. The impact and benefits can be measured through several indexes:

Affected population: population that directly or indirectly benefit from the environmental improvement. This index will consider number of people affected by the current environmental state. To the location with the greatest number of people will be assigned highest number (5) (other locations would than be given a mark proportionally).

Improved quality of life: an index that needs to be quantified through improved living conditions, improved ecosystem functionality, healthier population. Location that has highest impact on there’s quantifying indexes will be given mark 5.

The main criteria for hotspots identification are economic criteria. These criteria set out the effectiveness of sanitization that would ensure widest spread of environmental, social and economic benefits. Through this criteria should be affected the highest pollution load (that needs to be removed) possible, to the amount of money that is available and expected impact of project on development activities.