STATE OIL COMPANY OF AZERBAIJAN REPUBLIC ECOLOGICAL...

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AARP III: Large Scale Oil Polluted ENVIRONMENTAL MANAGEMENT PLAN Land Clean-up Project (SOCAR/WB) Ecological Department of SOCAR IQLIM Baku, 2008 STATE OIL COMPANY OF AZERBAIJAN REPUBLIC ECOLOGICAL DEPARTMENT AARP III: LARGE SCALE OIL POLLUTED LAND CLEAN-UP PROJECT ENVIRONMENTAL IMPACT ASSESSMENT Client: ECOLOGICAL DEPARTMENT OF SOCAR Haydar Aliyev avenue, 113. AZ1029 Baku, Azerbaijan Prepared by: IQLIM LTD, Research and Consulting Company B. Bagirova Street, 9/70. Baku, Azerbaijan M.R.Mansimov [email protected] E1824 v3 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized

Transcript of STATE OIL COMPANY OF AZERBAIJAN REPUBLIC ECOLOGICAL...

Page 1: STATE OIL COMPANY OF AZERBAIJAN REPUBLIC ECOLOGICAL DEPARTMENTdocuments.worldbank.org/curated/en/995431468221703092/pdf/E18… · Ecological Department of SOCAR IQLIM Baku, 2008 6

AARP III: Large Scale Oil Polluted ENVIRONMENTAL MANAGEMENT PLAN Land Clean-up Project (SOCAR/WB)

Ecological Department of SOCAR IQLIM Baku, 2008

STATE OIL COMPANY OF AZERBAIJAN REPUBLIC

ECOLOGICAL DEPARTMENT

AARP III: LARGE SCALE OIL POLLUTED LAND CLEAN-UP PROJECT

ENVIRONMENTAL IMPACT ASSESSMENT

Client: ECOLOGICAL DEPARTMENT OF SOCAR Haydar Aliyev avenue, 113. AZ1029 Baku, Azerbaijan Prepared by: IQLIM LTD, Research and Consulting Company B. Bagirova Street, 9/70. Baku, Azerbaijan M.R.Mansimov [email protected]

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TABLE OF CONTENTS ABREVIATIONS ...................................................................................................5 1. Introduction .....................................................................................................6 1.1. General information .......................................................................................6 1.2. Project objectives ...........................................................................................6 1.3. Objectives of Environmental Management Plan (EMP) .................................7 2. LEGISLATION, REGULATING NORMS AND RULES ON ENVIRONMENTAL PROTECTION ..................................................................................................8 2.1. General legislation issues ..............................................................................8 2.2. Legislation of Azerbaijan Republic on Environmental Protection....................8 2.3. Participation in International Environmental Cooperation ............................11 2.4. Regulation of environmental activities in national level ................................12 2.5. Environmental Management in SOCAR ......................................................13 2.6. Standards and rules ………..……………………………………………………14 2.7. Standards and recommendations for soil remediation .................................17

3. ENVIRONMENTAL AND SOCIAL ASSESSMENT IN AREAS WHERE CLEANING WORKS WILL BE PERFORMED .............................................23

3.1. Environment .................................................................................................23 3.1.1. Location of selected areas and their brief review ......................................23 3.1.2. Characteristics of soils …….......................................................................24 3.1.3. Pollution level, types and volume of soils in planned remediation

areas ........................................................................................................26 3.2. Social-economic environment ......................................................................33 3.2.1. General social-economic environment ......................................................33 3.2.2. Social-economic situation in project areas ................................................35 4. SUGGESTED EQUIPMENT AND CLEANING METHODS ………………......37 5. POTENTIAL ENVIRONMENTAL IMPACT ASSESSMENT OF CLEANUP

WORKS ………………….....................................................................40 5.1. Environmental impacts assessment ............................................................40 5.1.1. Emissions ....……………………………………………………........……….41 5.1.2. Liquid waste ......…………………………………………………….………..44 5.1.3. Solid wastes ..…………………………………………………………………44 5.1.4. Noise ...………………………………………………………………………...45 5.1.5. Emergency situations and risks …………................................................47 5.2. Social and economic impacts assessment ………...................................47 5.2.1. Introduction ..............................................................................................47 5.2.2. Social and economic impacts of the project ............................................48

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6. ENVIRONMENTAL MANAGEMENT PLAN ..............................................54 6.1. Introduction. .................................................................................................54 6.2 Measures for minimizing environmental impacts, and waste management...54 6.2.1. Management of hazardous substances thrown into air.............................54 6.2.2. Management of waste waters ...................................................................55 6.2.3. Solid wastes ..............................................................................................56 6.2.4. Management of spills, leakages during transportation and accidents …...56 6.2.5. Management of noise …............................................................................56 6.2.6. Fire safety measures ………......................................................................57 6.2.7. Management of emergency situations ......................................................57 6.2.8. Management of Health and Safety ……….................................................57 6.3. Environmental monitoring plan ....................................................................58 6.3.1. Introduction................................................................................................58 6.3.2. Emissions monitoring plan ………………..................................................58 6.3.3. Soil monitoring plan ..............…………………………………………….......59 6.3.4. Water monitoring plan ...………………………………………………………59 6.3.5. Other monitoring activities ……………………………………………………60 6.4. Consultations ……………………………………………………………………..60 Annex I. Environmental Management Plan ....................................................61 Annex II. Environmental Monitoring Plan .......................................................68 Figures Figure 1. Organizational Structure of Ecological Department of SOCAR ...........14 Figure 2. Polluted areas in Bibihaibat field before and after cleanup ..................15 Figure 3. Location map of areas to be cleaned …………....................................24 Figure 4. Map-scheme of concentration of oil products in water (blue) and soil

(yellow and brown) in Bibihaibat area .................................................27 Figure 5. Distribution graphs of average rates of oil pollution in different sample-

extracting wells (a) and 18 wells (72 samples) ...................................28 Figure 6. Map-scheme of concentration of oil products in water (blue) and soil

(yellow and brown) in Buzovna-Mashtagha area ................................29 Figure 7. Distribution graphs of oil pollution in different sample-extracting wells in

Buzovna-Mashtagha area ...................................................................29 Figure 8. Map-scheme of concentration of oil products in water (blue) and soil

(yellow and brown) in Qala area .........................................................31 Figure 9. Distribution graphs of oil pollution in different sample-extracting wells in

Qala area ............................................................................................32 Figure 10. View of cleanup setup in Binagadi area ………………………............38 Figure 11. MS-1 unit being set up in Bibihaibat area ………………….................38 Figure 12. Construction debris and domestic wastes in Qala area .....................45 Figure 13. Synthetic based drilling cuttings wastes in Bibihaibat area ...............45 Figure 14. Newly built dwellings in the backgound of cleanup pond in Bibihaibat

area .....................................................................................................48 Figure 15. New dwellings nearby polluted areas in Buzovna-Mashtagha area...49

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Tables Table 1. Maximum concentration limits of hazardous substances …..................18 Table 2. Soil quality criteria and maximum limits ................................................19 Table 3. Soil quality standards of Canada …………………….............................19 Table 4. Levels determining pollution norms in Netherlands …………................20 Table 5. Maximum allowable density of hazardous petroleum substances ........20 Table 6. Concentration of heavy metals in oil polluted soils in Bibihaibat area ..28 Table 7. Concentration of heavy metals in oil polluted soils in Buzovna-

Mashtagha area .....................................................................................30 Table 8. Concentration of heavy metals in Qala area .........................................32 Table 9. Main indicators of public health ……………………………….................34 Table 10. Main causes of death among population …………………………….....34 Table 11. Criteria used for environmental impact assessment impacts ..............40 Table 12. Air quality standards in Azerbaijan Republic …...................................42 Table 13. WHO and EU air quality standards ……………………….....................43 Table 14. Emissions to air during remediation works .........................................44 Table 15. Estimated noise level from remediation equipment in cleanup areas..46 Table 16. World Bank standards of noise level in environment ..........................46 Table 17. Social and economic impacts of the use of cleaned lands .................51

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ABBREVIATIONS dB – decibel (measuring unit for sound) dBA – A-frequency decibel EC – European Community ECS – Environmental Control Standard ED – Ecological Department EIA – Environmental Impacts Assessment EMF – Environmental Management Framework EMP – Environmental Management Plan EU – European Union MCLNS – Maximum concentration limit of noxious substances MENR – Ministry of Environment and Natural Resources NGO – None-governmental organization PEE – Public Ecological Expertise SEE – State Ecological Expertise SEP – State Ecological Program SOCAR – State Oil Company of Azerbaijan Republic TLWA – Tolerance Limit of Wastes into Atmosphere TLWW – Tolerance Limit of Wastes into Water UN – United Nations UNDP – United Nations Development Program WB – World Bank WHO – World Health Organization

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1. Introduction 1.1 General Information Production of oil by industrial means has almost 150 years of history in Absheron Peninsula of Azerbaijan Republic. Total amount of produced oil within this period exceeds 1 billion tonnes. Use of primitive technologies in production, storage, transportation and refinery of oil in the late XIX and early XX centuries and importance of oil production to environmental safety in former Soviet Union caused pollution of Absheron Peninsula lands with oil and dirty water. Besides the lands, many lakes and small ponds also have been polluted with dirty water produced from oil wells and drilling fluids, and have become “dead” areas. At the same time, oil storage pits made from earth nearby oil wells are still full with oil and formation water up to day. Around 20-22 thousand ha of lands in Absheron Peninsula is currently polluted with various wastes (oil and oil products, domestic, industrial, construction and other wastes). This is almost 10 per cent of total area of the peninsula (Oily Soil Cleanup Project – MSGP-AZ05-04). 7500 ha of the polluted lands are used by SOCAR, 2800 ha of which are especially badly polluted. Extend of pollution ranges from 1-2% to 30-40%, and depth up to 2-3 meters or more. Full industrialisation of the peninsula and semi-arid natural environment has reduced self-remediation capability of soil to zero. There is no ecosystem in the peninsula. Lately, rapid growth of population wound up in growth of land users and expansion of Baku city and its suburban towns and villages. Demand for land resulted in 8-10 times of growth in land prices in the last 10 years. On the other hand, expansion of polluted lands to big areas restrict the construction of houses, solving social and economic problems of people, and effect negatively to their health, as well as to the environment. (“The National Plan of Actions on Environmental Protection” (NPAEP), Baku. 1998). 1.2. Project Objectives By the decree of the President of Azerbaijan Republic on September 28, 2006 to improve environmental situation in Absheron Peninsula, a decision was made to prepare and implement State Ecological Programme (SEP) which covers complex measures. Most part of the programme is about cleaning and remediation of oil polluted lands of Absheron Peninsula. Programme implementation involves participation of SOCAR and various other ministries. According to this decree, SOCAR management has worked out a Plan of Actions for 2006-2010 years to improve environmental situation in and around oil and gas fields. The plan includes concrete organizational, technological and economic actions to improve environmental situation of air, land and water environments.

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SOCAR is planning to involve 554 million AZN (or 652 million USD) to realise this plan. Plan also includes remediation of oil polluted soils, and Ecological Department (ED) of SOCAR is commissioned for realisation of these remediation works. World Bank has identified several ways to aid Azerbaijan Republic regarding SEP. Some of these ways include investments on main projects, management and execution of SEP and aiding to preparation of main policies. One of the choices concerns pollution of high priority, “inherited” polluted oil fields as a result of production, refinery, storage and transportation of oil and natural gas in Soviet period. Currently discussed project includes the use of powerful (semi) mobile cleanup technologies in soil remediation which will clean the soil in polluted areas, allow re-use of cleaned soils, and remove impure sediments and water/agents used in cleaning process from cleaned areas. Remediation works within the framework of World Bank investment aids are suggested to be performed in three pilot areas by SOCAR: polluted lands in oil production areas of Bibihaibat; Buzovna-Mashtagha and Qala. 1.3 Objectives of Environmental Management Plan The main purposes of EMP are assessment of environmental situation in polluted areas and effects of soil remediation processes on natural and social environment, and preparation of suggestions and measures to minimise possible negative effects. EMP is prepared according to technical assessment introduced by WB. The content of assessment is as follows:

1. Assisting SOCAR and/or ECOL company in collecting and working out information on EMF and EMP; receiving and archiving data on environmental research;

2. Consulting with technical advisor for obtaining suitable working parameters for soil cleanup equipment (such as power, energy and water requirements of equipment; agents required for cleaning; additional resources; debris; emissions; noise; dust; vibration) from environmental point of view;

3. Preparing draft version of Environmental Management Framework (EMF) and social framework and final version of these documents after consulting with safety specialists of the Client and World Bank;

4. Preparing draft and final versions of Environmental Management Plan in conjunction with preparation of technical-economic assessment and equipment specifications;

5. As required by World Bank operational policies, provision of public information and assistance in informing public;

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6. Assisting to SOCAR and/or ECOL representatives in determining cleanup objectives and standards, conducting professional dialogues with MENR and determining the area and volume of cleanup works;

7. The consultant will assess Azerbaijani and international standards and legislation, and will bring implementation examples from big international project sources;

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2. LEGISLATION, REGULATING NORMS AND RULES ON ENVIRONMENTAL PROTECTION 2.1. General legislation issues The following is the order of legal acts in Azerbaijan legislation:

• Constitution; • Laws adopted in referendums; • Laws (adopted by Parliament (Milli Mejlis) and confirmed by President); • Decrees and directives signed by the President (addendums to laws); • Orders of the Cabinet of Ministers (addendums to laws or decrees of

President); • Regulating norms of central executive bodies (or ministries) regarding the

implementation of above-mentioned norms. International conventions and agreements signed by Azerbaijan Republic are integral part of Azerbaijan legislation system. The right of legislation initiative belongs to the President, members of Parliament, members of Supreme Court of Azerbaijan Republic and members of Supreme Assembly of Nakhchevan Autonomous Republic. Certain public consultations on new legislation can be held with the initiative of Parliament. Current legislative acts on environment adopted in Azerbaijan are based on principles and provisions stated in 1995 Constitution of Azerbaijan Republic; Constitutional Act on Basis of Economic Sovereignty, May 28, 1991, and Constitutional Act on State Independence, October 18, 1991. Environmental issues in Azerbaijan legislation are reflected in a number of framework acts. 2.2. Legislation of Azerbaijan Republic on Environmental Protection Legislation of Azerbaijan Republic on protection of natural environment is based on principles stated in Constitutional Act on State Independence, October 18, 1991; Constitution of Azerbaijan Republic adopted in 1995; Environmental Protection Law of Azerbaijan Republic (1999); Charter of the Ministry of Environment and Natural Resources (Decree of President #583, 2001), and implementation of fees and fines for use of nature and wastes thrown into environment (Order of the Cabinet of Ministers #122, dated to March 3, 1992). At the same time, Water Code, Law on Protection of Atmosphere, Soil Code, Forests Code, Earth Interior Law, Waste Law, acts on flora and fauna and etc., as well as national standards on safety and protection of public health are valid in Azerbaijan territory. The Constitution of Azerbaijan Republic state that environment and all natural resources belong to people of Azerbaijan. Citizens of the country are obliged to protect the nature and its resources. The government, in its turn, is committed to use soil, earth, water resources, flora and fauna efficiently, on scientific bases and protect them, to provide remediation

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of air, growth and restoration of natural resources and improve the quality of environment. Current legislation sets environmental requirements for any economic and other activities. Requirements of environmental protection acts must be met, and any possible negative effect on environment must be identified and stated during technical-economic assessment of any activity. One of the main laws in protection, and regulating efficient use of, environment is Environmental Protection Law (1999). The Law states main principles of preservation of nature, rights and obligations of government, public institutions and citizens in this area; determines objectives of users of nature in conducting environmental monitoring, term of “ecological insurance” for dangerous activities, and establishes volunteer and compulsory environmental audit of economic activities. Basic responsibilities for violation of legislation requirements for environmental safety have been formulated. The law establishes basic standards of environmental quality, environmental requirements for economic activities, and sets requirement for state and local environmental monitoring. Quality of environment is included in environmental standards:

• Maximum concentration limit of noxious substances (MCLNS) in environment;

• Tolerance limits of noxious substances thrown into environment; • Level of radiation safety; • Sanitary-hygienic norms and standards.

Violation of above-mentioned norms and requirements can result in termination or restriction of economic activity. Main goals and objectives of State Ecological Expertise (SEE) and Public Ecological Expertise (PEE) have been identified in Environmental Protection Law. Implementation of recommendations of State Ecological Expertise is compulsory. Public opinion is necessary for making optional or alternative decisions, but different from environmental expertise (EE) and SEE recommendations, this is informative and suggestive. According to Environmental Protection Law users of natural resources must adhere to all environmental and technological requirements, valid standards and quality and quantity norms of environment. According to the 32nd article of the Law, users of natural resources are obliged to take measures for recultivation of lands, to restore and efficiently use natural resources, and to renovate areas and to bring environment into healthy condition.

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Specially Protected Natural Areas and Objects Law (2000) regulates protection and use of specific areas and determines their status. According to Environmental Safety Law (1999) land users are responsible for bringing damaged soils and other natural resources into useful condition for their future use. Radiation Safety of Population Law (1997) establishes requirements for providing radiation safety in industrial entities during their exploitation and main principles of government policy meeting these requirements, as well as environmental norms providing safety of employees and population in areas using radioactive sources and rights of population to claim compensation for damage to their health, property and life during accidents. Sanitary-epidemiological Safety Law (1992) establishes rights and obligations of citizens and national monitoring institutions in provision of sanitary and epidemiological safety; basic principles of establishing sanitary-hygienic norms and standards; sanitary and epidemiological requirements for planning, constructing and exploiting enterprises and other economic activities. According to 39th article of this Law, and Criminal Code of Azerbaijan Republic, violating sanitary-hygienic norms and rules causes criminal responsibility. Protection of Atmosphere Law (2001) establishes norms for managing physical and chemical impacts to atmosphere, as well as legal basis for state registration of negative impacts on atmosphere, provision of control over air protection, solving disputes emerging from pollution of atmosphere. Soil Code (1999) sets compulsory requirement for remediation of all soils after their use, including soils where mining works have been conducted. According to Soil Productivity Law (2000) land owners, leasers and land users must protect productive top layer of soils while conducting remediation of lands. According to the Law, remediation of soils lost their productivity should be performed not later than 3, 3-5 and 5 years depending on specifics of soil. Some negative impacts on natural environment – on water bodies, soil, minerals and earth interior are inevitable during geological exploration and oil production. Therefore, these types of works are regulated by the following legislative acts:

• Radioactive wastes Law (1994); • Water Code (1997); • Industrial and domestic wastes Law (1998); • Soil Code (1999); • Earth Interior Law (1998); • Compulsory Ecological Insurance Law (2002).

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Draft of Oil and Natural Gas Law is currently discussed at the Ministry of Industry and Energy. 2.3. Participation in International Environmental Cooperation International Conventions, contracts and agreements on use of nature and environmental safety signed by Azerbaijan Republic are also main source and integral part of national legislation on environment. There is a special article in every national legislation act which states that if provisions of international agreements are in conflict with that of national legislation, then international agreements take precedence. The following international conventions have been ratified by Azerbaijan Republic:

• Convention on Long-Range Transboundary Air Pollution (Geneva, 1979), ratified in 2002;

• Vienna Convention on Protection of Ozone Layer (1985), followed by Montreal protocol, ratified in 1996;

• Framework Convention of UN on Climate Changes (1992), ratified in 1995;

• Convention for the Prevention of Pollution from Marine Vessels (MARPOL) (1973/78), ratified in 1999;

• Convention on the Protection and Use of Transboundary Watercourses and International Lakes (Helsinki, 1992), ratified in 2001;

• Convention on Environmental Impact Assessment in a Transboundary Context (ESPOO, 1991), ratified in 1999;

• Convention on Access to Environmental Information, Public Participation in Decision Making Process and Access to Justice in Environmental Matters (Orkhus, Denmark, 1998), ratified in 1999;

• Basel Convention on the Control of Transboundary Movement and Management of Hazardous Wastes (Basel, 1989), ratified in 2001;

• Convention on Biodiversity (Rio-de-Janeiro, 1992), ratified in 1998; • Convention on Trade in Endangered Species of Wild Fauna and Flora –

CITES (Rio-de-Janeiro, 1992), ratified in 1998; • The Convention on Wetlands of International Importance (Ramsar, Iran,

1971), ratified in 2001; • Convention on Conservation of European Wildlife and Natural Habitat

(Bern, 1979), ratified in 1999; • International Convention on Protection of World Cultural and Natural

Heritage (Paris, 1972), ratified in 1999; • Stockholm Convention on Persistent Organic Pollutants (2001), ratified in

2003; • Framework Convention for the Protection of the Marine Environment of

the Caspian Sea (Tehran, 2003)

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In addition, Azerbaijan Republic also participates in European Strategy on Environment and Landscape Diversity directed at protection of ecosystems, plant and animal species, their genetic diversity and European landscapes through European Environmental Network. 2.4. Regulation of environmental activities in national level Environmental impacts in Azerbaijan are regulated with guiding documents and rules established by Azerbaijan Government, Ministry of Ecology and Natural Resources (MENR). Some documents on methods and standards have been issued during Soviet period and some of them are still valid in all post-soviet countries, including Azerbaijan. According to above-mentioned acts, use of natural resources and activities impacting environment should be controlled by state expertise and these activities should be monitored in accordance with the requirements of current legislation. Environmental impacts assessment (depending on specifics of activity, state control can also be required), as well as preparation of relevant documents about state control shall be carried out on the basis of existing sanitary-hygienic and environmental norms for conducting such works. These documents mainly include Ecological Passport (for existing institutions) and Environmental Impacts Assessment (EIA – for planned works). Tolerance Limit of Wastes into Atmosphere (TLWA) and Tolerance Limit of Wastes into Water (TLWW) are established and approved accordingly to identify waste standards or temporarily agreed waste limits for noxious substances thrown into atmosphere and water. Environmental Impacts Assessment (EIA). In 1996, Azerbaijan Government adopted amended EIA procedures corresponding to the systems applied in other countries. New rules have been described in the Regulations for Conducting Environmental Impacts Assessment in Azerbaijan Republic (UNDP/State Environmental Committee, 1996). These Regulations state that “works on assessing wastes thrown into environment should start in the beginning, i.e. in the planning stage and before technical-economic reasoning.” 2.5. Environmental Management in SOCAR Special groups, departments and offices managing and regulating health, safety and environment exist in main departments and subsidiary companies of SOCAR, as well as in auxiliary services. The Company has internal procedures and monitoring system in these areas. Ecological Department (ED) was created in SOCAR system by the Decree of President on “Improving Organizational Structure of the State Oil Company of Azerbaijan Republic” dated to September 14, 2006 to carry out environmental assessments and take complex measures corresponding international standards

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and existing norms on improving environmental situation; to solve problems while providing environmental safety in oil and gas production and refinery processes; to assess environmental impacts of plants; and to eliminate other problems. Organizing environmental protection in subsidiary organizations and institutions within SOCAR; preparing and implementing environmental programmes within SOCAR; recultivation of polluted lands and cleaning polluted waters; providing maximum efficiency of funds allocated to these areas; monitoring activities of organizations under SOCAR; and establishing single environmental policy within SOCAR are priority issues facing ED. SOCAR ED has expedition groups, technical facilities, laboratories, soil remediation plants and equipment and relevant infrastructure for conducting environmental monitoring in both onshore and offshore oil and gas fields (Pic. 1). ED is currently implementing constructive plans on organizing soil cleanup operations in compliance with international standards using modern technology; waste management; and minimizing negative environmental impacts. Currently ED is carrying out cleaning of 526 ha of oil polluted lands in Bibihaibat field. Given the wide area of polluted lands and high level of pollution, ED will need quite long time to clean soils with this pace. Therefore WB aid to SEP is sound and in-time decision, and will be great contribution to cleanup operations conducted by ED. ED management has determined to monitor safety, health and environmental protection rules as follows:

• Adherence to the requirements of the laws and rules of Azerbaijan Republic related to safety, environment and quality, including the related standards,

• Application of modern equipment and technologies for development and regular improvement of quality, environmental and the safety systems in full compliance with the requirements of international standards, such as: ISO 9001, ISO 14001 and OHSAS 18001,

• Reducing all effects having potential impact on and not causing any damages to human safety, environmental pollution and quality to minimum.

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Fig. 1. Organizational Chart of Ecological Department. 2.6. Standards and rules Sanitary-hygienic and environmental standards are used to monitor the status of environment. Maximum Concentration Limits of Noxious Substances (MCLNS), i.e. norms defining density of noxious substances per area unit of air, water, food and soil, or skin, respiratory organs within certain time limit which does not affect health and does not generate undesirable results in human genetic, are used as standard. MCLNS is different for settlements and work places, as well as for recreation areas. To allow certain amount of noxious substances thrown into atmosphere, water and soil, MCLNS is identified according to below mentioned norms and standards. Sanitary-hygienic and environmental norms determine the quality of environment regarding human health and status of ecosystems, but they do not indicate the source of impact and do not regulate its effects. Special requirements for identifying source of impact reflect scientific and technical norms. Scientific and technical norms include technological, construction, architecture norms and rules which, in their turn, include requirements for throwing noxious

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substances into air and water (TLWA, TLWW), as well as for environmental protection.

Fig. 2. Polluted areas in Bibihaibat field before and after cleanup. The following principles are the basis of scientific and technical norms:

• Amount of any additive in water, air and soil should correspond to the requirements of sanitary-hygienic norms, and all enterprises in the region should adhere to these norms;

• Devising TLWA and TLWW intends applying restrictions in work of industrial enterprises regarding environmental pollution, in other words, identifies tolerance limits of allowable amount of noxious substances thrown into air, water and soil from impact sources;

• Institutions are required not only to follow one or another MCLNS, but also adhere to maximum concentration limit of noxious substances defined for the entire institution or for particular sources within it. Although expected growth in TLWW is usually sign of not following limits, it doesn’t necessarily mean any violation in environment;

• TLWW and MCLNS for wastes thrown into air, water and soil is calculated for all sources and approved by relevant authorities. Fees for use of natural environment are defined and applied on the basis of approved TLWW and MCLNS.

The list of standards and norms considering specifics of pollution means and elements, valid in Azerbaijan and CIS region is given below:

• “Rules for protecting surface water sources form impure water contamination”. State Committee on Environment and Control over Use of Natural Resources. Baku, 1994;

• Resolution #206 of the Cabinet of Ministers of Azerbaijan Republic on “Preparing and Implementing rules for use of water” dated to October 15, 1998.

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• “Standardizing rules for Use and protection of water sources”, Resolution #2006 of the Cabinet of Ministers of Azerbaijan Republic, October 15, 1988, article 8;

• “Rules for state registration of noxious substances thrown into, and negative impacts on, atmosphere” Resolution #112 of the Cabinet of Ministers of Azerbaijan Republic, July 13, 2002;

• Resolution #63 of the Cabinet of Ministers of Azerbaijan Republic on “Rules for protecting atmosphere by corporations having chemical, physical and biological impact sources to atmosphere”, April 15, 2002;

• “Establishing draft version of MCLNS standards for enterprises applying technical standards and tolerance limits of waste, and recommendations on its content”. State Environmental Committee, 1994;

• “Rules for licensing units refining noxious wastes”. Resolution #112 of the Cabinet of Ministers of Azerbaijan Republic, June 29, 1999;

• “Rules for transportation of noxious wastes by vehicles”. Resolution #10 of the Cabinet of Ministers of Azerbaijan Republic, January 27, 2000;

• “Inventory rules for noxious wastes”. Resolution #41 of the Cabinet of Ministers of Azerbaijan Republic, March 31, 2003;

• “Handbook for inventory and classification of wastes produced in industry and services”, Ministry of Justice, Certificate #419, July 1, 2003;

• State Standard #17.2.1.03-84. Environmental Protection. Atmosphere. Terms and definitions for pollution control. Moscow, 1984;

• State Standard #3223-85. “Sanitarian standards of allowable levels of noise at work places”, Moscow, 1984;

• State Standard #27535-87 “Internal and external horns of vehicles. Allowable levels and measuring techniques”, Moscow, 1987;

• ECS-86 State Committee of Hydrometeorology. Methods for calculating concentration of substances thrown into atmosphere with wastes by enterprises. Hydrometeopress, 1987;

• State Standard #17.2.3.01-86. Atmosphere. Rules for controlling the air quality in settlements. 1986;

• Handbook 52.04.52-85. Waste cleanup in unfavourable weather conditions. Hydrometeopress, 1987;

• State Standard #17.2.3.02-78. Environmental Protection. Rules for identifying allowable norms of noxious substances thrown into atmosphere by enterprises. Moscow, 1978;

• State Standard #12.1.005-88. Labour safety standards system. General sanitary-hygienic requirements for air in working zone. Moscow, 1988;

• Handbook for standardizing concentration of noxious substances thrown into atmosphere and water bodies. State Environmental Committee of USSR. Moscow, 1989;

• State Standard #17.0.0.04-90. Recommendations for filling and updating environmental passport of an enterprise. State Environmental Committee of USSR. Moscow, 1990;

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• State Standard #17.0.04-90. Environmental Passport. Baku, 1990; • State Standard #17.0.0.04-90. Environmental passport of an enterprise.

Mission statement. State Environmental Committee of USSR. Moscow, 1990;

• Standards for protecting environment and using natural resources efficiently. State Environmental Committee. 1994;

• State Standard #17.5.1.03-86. Environmental Protection. Soils. Biological recultivation of soils and taxonomy of dumps;

• State Standard #17.5.3.06-85. Environmental Protection. Requirements for norms of removing productive top layer of soil during ground works;

• State Standard #17.5.1.02-85. Environmental Protection. Taxonomy of soils disturbed for recultivation;

• State Standard #17.4.3.04-85. Soils. Protecting from pollution and overall control;

• State Standard #17.4.01-84. Environmental Protection. Soils. Recultivation of soils;

• State Standard #17.5.1.05-85. Environmental Protection. Recultivation of soils. General requirements for soils;

• State Standard #17.5.4.02-84. Environmental Protection. Recultivation of soils. Methods for calculating and measuring total amount of toxic salts in exposed rocks and dumps;

• State Standard #17.5.3.04-83. Environmental Protection. General requirements for recultivation of soils;

• State Standard #17.5.1.01-85. Environmental Protection. Recultivation of soils. Definitions and terms;

• State Standard #17.4.2.02-85. Environmental Protection. Soils. Nomenclature of characteristics of disturbed productive layer of soils.

2.7. Standards and recommendations for soil remediation. Maximum concentration limit of noxious substances (MCLNS) in soils polluted with oil and oil products is not defined by some countries, including Azerbaijan. Because it depends on some factors: the type and structure of soil and rock, climate, oil composition, vegetation type, character of the use of soil. These norms have been established on the basis of considerable information about particular soil types and areas considering impacts on ecosystems and human health. Complexity of oil separation, bio climate, landscape, different geochemical conditions don’t allow establishing these norms in CIS countries, including Azerbaijan. According to the rules established by state standards and guiding documents valid in Azerbaijan and CIS countries, recultivated soils should be cleaned to their original natural form before pollution. But in reality, cleaning soil to its original degree is impossible and many years are required to do this. Therefore

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concrete standards for soil cleaning are not applicable. According to these rules, pollution level of soil means excessive concentration of chemical elements in a soil type which exceeds maximum concentration limit of dangerous substance defined by sanitary norms. On the basis of ecological and geographical cartography works in 1994, the following criteria for determining soil pollution levels have been established in Russian Federation, using standards for identifying concentration of petroleum hydrocarbons in soil in Netherlands (Methodical recommendations for evaluating soil pollution level. Moscow, 1994):

• Allowable concentration or tolerance limit - 50 mg/kg; • Slightly dangerous and dangerous from 50-100 mg/kg to 100-1000 mg/kg; • Extremely dangerous 1000-5000 mg/kg.

Other pollution standards in Russian Federation are calculated according to MCLNS considering natural background. For example, MCLNS for heavy metals is suggested in the following concentrations (Table 1).

Table 1 Maximum concentration limits of hazardous substances

(SRN 2.1.7.1287-03 “Sanitarian-hygienic requirements for quality of soil” confirmed by state sanitary doctor of RF, April 16, 2003)

Element MCLNS (mg/kg) considering

background Maximum overall sanitarian limit

Stibium (antimony) 4,5 50 Manganese 1500 1500 Vanadium 150 150 Lead 30 30 Arsenic 2 10 Mercury 2 5 Lead+mercury 20+1 30+2 Copper 55 - Nickel 85 - Zinc 100 - Terms like “Soil quality criteria”, “Soil standards criteria” are used more often in European Union countries (Directive 86/278/EEC, 1986). For example, Soil quality criteria in Denmark are evaluated according to Table 2 and maximum limits of pollution are suggested. Quality standards for soils have also been established in Canada depending on purpose for which the soil is used. “Background level” system has been adopted in Netherlands as an initial condition of soil, and this is based on assessment of background level of toxic elements and substances specific for different regions of the country.

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Background level is the minimum limit of pollution – 1st alarm level. 2nd level is considered high level of pollution, and pollution dynamics observations, studying its reasons and eliminating them is required. 3rd level is considered very high level of alarm: soil and groundwater must immediately be cleaned. Concentration of oil products and polyaromatic hydrocarbons has been identified for these levels (Table 4).

Table 2 Soil quality criteria and maximum limits, mg/kg

(DEPA, 1998, Remediation of contaminated sites, guideline no. 6) Hazardous substance Quality criteria Maximum limit Arsenic 20 20 Cadmium 0.52 52 Chlorine 500 1 Chrome 20 Copper 500 500 Lead 40 400 Mercury 1 3 Nickel 30 30 Polyaromatic hydrocarbons 1.5 15 Benzo(a)pyrene 0.12 12 Dibenz(a,h)anthracene 0.12 12 Zink 500 1 000

Table 3 Soil quality standards of Canada

(Canadian Environmental Quality Guidelines. Canadian Council of Ministers of the Environment, 1999, updated 2001, 2002, 2004 and 2006)

Purpose of use of soil

Element Dwellings Parks, beaches, boulevards and forest parks

Industrial parks Agriculture

Polyaromatic hydrocarbons 10 1,0 10 0,1

Arsenic 12 12 12 12 Cadmium 22 10 22 1,4 Chlorine 87 64 87 64 Chrome (VI valent) 1,4 0,4 1,4 0,4

Copper 91 63 91 63 Lead 260 140 600 70 Mercury 24 6,6 26 6,6 Nickel 50 50 50 50 Benzo(a)pyrene 0,7 0,7 0,7 0,1 Zinc 360 200 360 200

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Table 4 Levels determining pollution norms in Netherlands

Alarm levels Soil, mg/kg Subsoil waters, mg/l Hazardous substances

I II III I II III PAH 1.0 20.0 200.0 - 10.0 40.0 3,4 – Benzopyrene 0.1 1.0 10.0 0.005 0.2 1.0 Oil products 50.0 1000.0 5000.0 50.0 200.0 600.0 Soil is considered polluted in the U.S. if hydrocarbon concentration in soil is 1000 mg/kg (or 1000 ppm THP). Depending on type of the oil or oil product, maximum allowable tolerance limit of their concentration is formulated (Table 5).

Table 5 Maximum allowable concentration of hazardous petroleum substances

(Maximum concentration limits for soils containing hazardous concentrations of petroleum hydrocarbons, organic and inorganic compounds, metal, and

pesticides for MSW landfills with subtitled liners. Addendum no. 1 to order no. 93-86. California Regional Water Quality Control Board, San Diego Region, on June

7, 1999) Hazardous petroleum hydrocarbons

Maximum concentration limit

Gasoline and other final products of light hydrocarbons

1000 ppm THP 1000-5000 ppm THP/RCB 96 hours

(C4-C12) Diesel, kerosene, reactive fuel (C8-C22)

3000 ppm THP 3000-15000 ppm ÜHQ/RKY 96 hours

Motor oils, other petroleum wastes (heavy fraction) (≥C22)

3000 ppm THP 3000-15000 ppm ÜHQ/RKY 96 hours

Note: THP – means total hydrocarbon potential.

RCB – means reactivity, corrosion dynamic, and burning risk of wastes within 96 hours.

Because of the lack of norms and standards, assessment of oil polluted soils is conducted on the basis of guiding documents and sanitary norms left from Soviet period. According to existing rules, soils should be cleaned to the level matching with physical and chemical characteristics of soil typical for the landscape of area. But it is impossible to clean soils to background level achieved by modern technologies, and within short period of time. On the other hand, background level and its criteria have not been established for Azerbaijan’s soils, including Absheron soils, i.e. there is no methodical and scientific assessment. Currently oil polluted soils are evaluated according to the following criteria:

• Slightly polluted soils – 0-3, 0 g/kg (0-0, 3%) • Less polluted soils – 3, 0-6, 0 g/kg (0, 3-0, 6%)

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• Medium polluted soils – 6, 0-25 g/kg (0, 6-2, 5%) • Highly polluted soils – more than 25 g/kg (more than 2, 5%)

Concentration of other hazardous substances, including heavy metals in oil polluted soils and waters, is evaluated on the basis of sanitarian and waste standards. These standards are based on smaller figures than those in EU countries, United States and Canada, and used in all CIS countries, including Russian Federation at the moment (look at Table 1). Recommendations on standards. Establishing standards within a single country is difficult and complicated. On the other hand, national standards should comply with international system of identified standards. Many companies operating in Azerbaijan use not national, but international norms and standards. Azerbaijan Republic is member of international organizations on environment and standardization. Partnership and Cooperation Agreement (PCA) between European Union member countries and Azerbaijan (signed on April 22, 1996 in Luxemburg) became effective from June 22, 1999, which indicates high level of cooperation between the two sides (http://www.mfa.gov.az/az/international/ organizations/union.shtml.). According to article 50 of this agreement, Azerbaijan should attempt to “Promote use of technical rules of the Union in this area and application of European standards and compliance evaluation methods” within “Cooperation in the area of standards and compliance evaluation”. Under article 50 of the Agreement – “Environment” Azerbaijan has taken commitment to “Improve national legislation on the basis of European standards”. European Commission recommendation on involving South Caucasus countries in European Neighborhood Policy (ENP) was confirmed in Brussels Summit of heads of states and governments of European Union countries held on 17-18 June, 2004 (http://www.mfa.gov.az/az/international/organizations/union. shtml). Within the framework of European Neighborhood Policy “European Union - Azerbaijan Joint Plan of Actions” was signed in 2006. The following are recommended to Azerbaijan in this document:

• Integrating into EU and international legislation and management practices in the area of standards, technical regulations and evaluation of compliance;

• Improving procedures and institutes for evaluating factors affecting environment, including adopting and applying relevant laws;

• Preparing framework legislation and main procedures, and providing the planning for main environmental sectors, especially for air quality, water quality, management of wastes, protection of environment classified in

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national plan of actions on environment, and continuing the process pf adapting to European requirements.

With regard to above-mentioned recommendations, using European Union standards for evaluation and remediation of oil polluted soils and adapting them to Azerbaijan environment is more suitable. Analysis also show that most of the oil polluted soils in Azerbaijan can be classified as high and very high polluted soils, if European criteria are applied. Application of European norms and standards can also facilitate the comparison of conducted assessments and accelerate Azerbaijan’s integration into international systems in the area of improving environmental situation and sustainable development. Conducting relevant researches and assessments, implementing organizational improvements in national level and taking initiatives by government is required for applying international norms and standards in Azerbaijan and adapting them to local circumstances. SOCAR should widely cooperate with relevant executive and legislative authorities of Azerbaijan.

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3. ENVIRONMENTAL AND SOCIAL ASSESSMENT IN AREAS WHERE CLEANING WORKS WILL BE PERFORMED 3.1. Environment 3.1.1. Location of selected areas and their brief review Areas selected for cleanup works are situated within the area of two local Oil and Gas Production Departments of SOCAR. Bibihaibat area represents the same department, and Buzovna-Mashtagha and Qala areas are situated within the Oil and Gas Production Departments named after Z. Taghiyev. Bibihaibat area is located in south of Baku city, on Caspian Sea. The area has flat landscape and consists of two parts – Bibihaibat valley and part of Baku bay which was filled with earth. Bibihaibat valley is surrounded with hills on three sides. The area is situated 3-4 meters above the sea level. Absheron and Akchagyl depositions played main role in formation of geological structure of the area. Formations close to surface consist of clay and sand. Groundwater is in Caspian Sea level and has been exposed to pollution. Oil production in the area by industrial means started in 1873. Area of the field is 817 ha, 48.6 ha of which are very high polluted areas. As the area has totally been exposed to anthropogenic impact, there is no natural layer of soil and vegetation. Ponds polluted with wax and oily waters, swamped oil storage pits can be seen everywhere in the field. Air of the field is highly polluted because of different gases emitting from polluted soil, wells and formation fluids constantly flowing through surface streams and constantly emits foul smell. Buzovna-Mashtagha area is situated 40 km north-east of Baku city (Fig. 3). Oil production in the area has started in 1940. The area is located between Buzovna and Mashtagha settlements. Relief is flat, geological structure is formed by Neogenic and Anthropogenic depositions. The landscape has been exposed to anthropogenic impacts, and oily ponds and swamps are wide spread. Gray-brown semiarid soil types are typical for the area. Vegetation consists of semiarid bushes (coltsfoot, wormwood and etc.) and ephemers. These soil types are morphologically salty, and their mechanical composition is mainly clayey. Because the soils haven’t developed very well, they degrade quite fast when exposed to anthropogenic impacts. Soils of the area have been polluted by oil wells, waste waters, solids from oil wells and domestic wastes. Total area of the field is 588 ha, 72.35 of which are highly polluted. Qala area is situated 32 km north-east of Baku city, around Qala settlement (Fig. 3). Oil production in this area started in 1932. The area is located in relatively higher part of Absheron peninsula and formed from Absheron level depositions (sand, clay, and marlite) of Neogenic system. Gray-brown semiarid soil types are

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wide spread in the area. Because of intensive anthropogenic impacts, soils in the area have degraded and been polluted by oil wells, waste waters, solids from oil wells and domestic wastes. Besides oil wastes, domestic and construction wastes are also encountered everywhere in the area. There are small ponds and lakes in the area built out of earth barriers polluted with oil wastes, used as oil storages before. The biggest one among them is the man-made lake into which formation waters are disposed from branches no. 1 and 2 of Oil and Gas Production Department named after Z. Taghiyev. Area of this lake, very highly polluted with formation waters and petroleum hydrocarbons, is 50 ha. Qala area has total 400 ha of area, 125 ha of which is polluted with oil.

Fig. 3. Location map of areas to be cleaned. 3.1.2. Characteristics of soils Specifics of soils. Gray-brown and gray soils are wide spread in Absheron peninsula. These soils are young and have been formed on alluvial and proluvial depositions. Soil profiles are less dynamic and horizontal difference is weak. Light color indicates less organic matters in the soil. Amount of humus is between 1.5-2.0%. Mechanical compositions are clays, sand and heavy clays.

Buzovna -Maştağa

Qala

Bibiheybət

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The negative characteristic of these types of soils is their intact and dry profile. The only way to develop these types of soils is phytoreclamation. Saline soils are popular in central parts of Absheron peninsula, including low areas of selected pilot areas and surroundings of salty lakes. Excessive concentration of lightly dissolvable salts in the surface of soils is typical. Salt concentration is more than 3% and contends chlorine, sulfate and chlorine-sulfate. Saline soils form a complex in some areas. Their mechanical contend consist of clay and clay loam. Saline soils can be improved through reclamation and washing. Use of soils. Up until recently, most of the lands of Absheron peninsula have been used for agriculture – gardening, grapegrowing, cattlebreeding. Essential changes occurred in use of soil after land reforms, changing ownership, migration of people from other regions of Azerbaijan to Absheron. Now all lands belong to private ownership, local municipalities and Baku city executive power, except lands used for industrial purposes. 30 thousand ha of land are in use under oil fields of Absheron. All of these lands have been exposed to pollution to certain extent. According to classification of soils for their industrial use, soils are divided into three categories (Absheron High Pressure Gas Pipeline Project. EIA. GeoGlobe/Roc Enterprises Inc. 2000). Different levels of pollution are typical for first category soils both in area and in depth:

• Slightly polluted soils (up to 10 cm) 900 ha; • Medium polluted soils (up to 25 cm) 2000 ha; • Highly polluted soils (deeper than 25 cm) 3356 ha; • Soils entirely covered with oil wastes 4690 ha; • Soils totally left under bitumen layer 197 ha.

Second category soils are the ones covered with industrial, construction and domestic wastes (dumping-grounds). This category of soils occupy 1000 ha area. Third category soils occupy 8615 ha area and consist of open caves dug for different opencast sites (quarries, sandpits, and etc.), pipeline, etc. Pollution level of soils is 50-60 times higher than their background level, and heavy metal concentration in soil is higher than international standards: lead – 8 times; cadmium – 3 times; copper – 10 times; and zinc – 50 times.

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3.1.3. Pollution level, types and volume of soils in planned remediation areas. Bibihaibat area. This field is one of the oldest oil fields. As mentioned above, area of the field is totally exposed to anthropogenic impacts. There is no natural soil in the area. Ecological Department of SOCAR continuously monitors pollution in soil and surface waste waters. General physical and chemical analyses of water and soil samples have been conducted in laboratories, concentration of phenol, polyaromatic hydrocarbons and petroleum products has been determined, as well as radioecological situation of the area has been assessed. Conducted monitoring covers all sites of the area. The area is divided into four sites, and 18 sample-extracting wells have been drilled and 108 samples have been taken by ED of SOCAR to study oil pollution. Distribution of pollution across the area is reflected in the map introduced by ED (Fig. 4.). As shown in the map, variation range of oil concentration in waters of ponds located among oil wells is very high, changing from 0,1-1,20 g/liter to 30,0-45,0 g/liter. Soil pollution ranges from 140 g/kg (or 14%) to 260 g/kg (or 26%) in most sites of the area, oil concentration fluctuates between 2, 0-7, 0 g/kg in the rest of the area. Depth of the soil pollution also varies across the area. Maximum pollution is determined 1.5 meters deep. But likelihood of deeper pollution levels (approximately 2.5-3 meters deep) is not so difficult to assume (Fig. 5.). According to evaluations of SOCAR ED, there are:

• 169 ha of medium polluted (6,0-25 g/kg or 0,6-2,5%); and • 137 ha very highly polluted (higher than 25 g/kg or 2, 5%) soils in

Bibihaibat area. Data analyses and evaluations show that there are averagely 81, 4 kg of oil products in 1 m3 of soil. Soil cleanup works will cover down to 2 meters in depth, average depth is 1 meter. Total volume of cleaned soil will be 1.37 million m3. Other hazardous substances typical for oil polluted areas are polyaromatic hydrocarbons, phenols and heavy metals. Their concentration is proportional to oil pollution level of soils. According to data provided by central laboratory of ED of SOCAR, concentration of the most of heavy metals is 3-20 times higher than MCLNS (Table 6.). Cleanup of other hazardous substances should certainly be in the focus of attention as well.

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Fig. 4. Map-scheme of concentration of oil products in water (blue) and soil (yellow and brown) in Bibihaibat area. a)

0

50

100

150

200

250

300

350

20 40 60 80 100 120 140 160Depth, sm

Con

cent

ratio

n of

oil

pollu

tion,

g/k

g

St. 1 St. 2St. 3 St. 4

b)

0

20

40

60

80

100

120

140

160

10 30 50 70 90 110 130 150

Depth, sm

Con

cent

ratio

n of

oil

pollu

tion,

g/k

g

Fig. 5. Distribution graphs of average oil pollution rates in different sample-extracting wells (a) and 18 wells (72 samples).

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Table 6 Concentration of heavy metals in oil polluted soils in Bibihaibat area

(Data provided by laboratory of ED of SOCAR) Ar

seni

c

Bariu

m

Cad

miu

m

Chr

ome

Cop

per

Iron

Man

gane

se

Mer

cury

Lead

Zinc

Maximum concentration limit (mg/kg)

No.

2 2 6.0 3.0 500 2.1 6 23 1 7.5 570 0.37 16.9 60.0 13500 474 0.07 42.2 76.2

2 7.8 354 0.08 28.4 29.9 15600 485 0.03 14.3 52.1

Buzovna-Mashtagha area. The area is located in previously called “oil storage site” of Oil and Gas Production Department named after Z. Taghiyev (Fig. 6). Area of the site is 50 ha, 21 ha of which is medium and very high polluted areas. The site is not used as an oil storage at the moment. The area had been used as a site for vaporizing formation fluids for long times, therefore there are many oil ponds around. In-depth distribution of oil pollution has been studied down 1.5 meters and described in Fig. 7. Concentration of heavy metals is shown in Table 7.

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Fig. 6. Map-scheme of concentration of oil products in water (blue) and soil (yellow and brown) in Buzovna-Mashtagha area.

0

50

100

150

200

250

20 40 60 80 100 120 140 160

Depth, sm

Con

sent

ratio

n of

oil

pollu

tion,

g/k

g

St. 1 St. 2St. 3St. 4

Fig. 7. Distribution graphs of oil pollution in different sample-extracting wells in Buzovna-Mashtagha area.

Table 7

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Concentration of heavy metals in oil polluted soils in Buzovna-Mashtagha area (mg/kg)

(Technical Final Progress Report. Oily Soil Cleanup Project (MSGP-AZ05-04)/Nov2005)

Ars

enic

Bar

ium

Cad

miu

m

Chr

ome

Cop

per

Iron

Lead

Zinc

Maximum concentration limit (mg/kg)

No.

2 2 6.0 3.0 6 23

1 10,5 95,5 1,13 7,04 11,9 482 4,32 18,8

2 4,8 78,5 0,80 11,1 8,49 571 3,21 19,1

3 6,9 83,7 0,64 14,5 8,81 722 5,23 19,1

4 12,1 81,2 0,12 22,1 13,8 467 8,74 16,7

5 2,6 85,1 0,48 23,5 9,85 945 6,93 15,76

Pollution level ranges from 140-200 g/kg in top layer, of soil and to 17-22 g/l in oily ponds. There is averagely 70,8 kg of oil products in 1 m3 of soil in high pollution areas. Total volume of oil polluted soils is 420 thousand m3. Qala area. Qala area occupy 464 ha of lands, 140 ha of which is oil polluted areas (Fig. 8). There are also many ponds and lakes filled with oil wastes and formation waters (50 ha). According to information provided by ED of SOCAR, there are:

• 21 ha of medium polluted (6,0-25 g/kg, or 0,6-2,5%); and • 25.5 ha of very high polluted (more than 25 g/kg, or 2,5%) soils in the

area. Pollution of top layer of soil ranges from 50 to 300 g/kg, petroleum hydrocarbon concentration in oily ponds fluctuates between 80-110 g/liter (Fig. 8). Depth of pollution is estimated 1.5 meters and is described in Fig. 9.

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Fig. 8. Map-scheme of concentration of oil products in water (blue) and soil (yellow and brown) in Qala area. There is averagely 66, 2 kg of petroleum hydrocarbons in 1 m3 of soil in high pollution areas. Soil cleanup works will cover 2 meter depth and total volume of soils to be cleaned is 910 thousand m3. Petroleum hydrocarbons and formation waters have beeing flowed into a manmade lake located in the area for almost 80 years. Heavy layer of hydrocarbon depostions have settled in the bed of the lake and surface is totally covered with oil wastes. Depth of the lake is approximately 3 meters. Pollution level is 37,3 g/liter. Fluid level in the lake drops approximately 1 meter in summer and fall seasons. There is averagely 160 kg of petroleum hydrocarbons in 1 m3 of qround. 3 meter of layer of lake volume is polluted, including depositions in the bed. The volume of soil to be cleaned in this area is 1.5 million m3. Therefore the volume of soil which will be involved in soil cleanup process in Qala area is 2.41 million m3.

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0

50

100

150

200

250

20 40 60 80 100 120 140 160

Depth, sm

Con

cent

ratio

n of

oil

pollu

tion,

g/k

g

St. 1 St. 2St. 3St. 4

Fig. 9. Distribution graphs of oil pollution in different sample-extracting wells in Qala area. Concentration of heavy metals is given in Table 8.

Table 8 Concentration of heavy metals in Qala area (mg/kg)

(Data provided by laboratory of DE of SOCAR)

Ars

enic

Bar

ium

Cad

miu

m

Chr

ome

Cop

per

Iron

Man

gane

se

Mer

cury

Lead

Zinc

Maximum concentration limit (mg/kg)

2 2 6.0 3.0 500 2.1 6 23

5.8 730 0.28 20.4 67.1 16500 380 0.04 27.2 60.7

3.2. Social-economic environment 3.2.1. General social-economic environment Absheron peninsula is most socially and economically developed region of Azerbaijan. 60-62% of Gross Domestic Product (GDP) is produced in this region. Major areas of economic potential are oil and gas industry, petrochemical engineering, metal manufacture, manufacturing, transportation, construction and food industry. The biggest industrial enterprises are situated in this region. Cattlebreeding, poultrybreeding, vegetablegrowing and vinegrowing are main

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areas of agriculture in the surrounding towns and villages. The region is the biggest transport hub in the country. The biggest educational, cultural, sport and health centers in the country are located in this region. Almost 40% of Azerbaijan population live in Absheron peninsula, density of population is twice as that of country average. Natural population growth is 1.01% per year. But population growth is higher in recent years due to migrations from other regions of the country and from Georgia (2-2.5% per year). According to population census in 2000, population of Absheron peninsula, including Baku City (1.8 million) is 3.1 million (excluding internally deported people, refugees and temporarily registered workers). Urbanization level of the region is 80%. People mainly work in industry, trade, construction, transport areas and various services. There is unemployment problem, too. Most of the population of sorrounding towns and villages go to Baku for employment. Development in construction industry in the last 10 years promoted rapid growth of settlements in Absheron peninsula. Also new dwellings have developed in suburban areas, unused and previously farmed lands have been sold to people for housing, gardening and for building recreation centers. Most of the settlements have combined with each other. Such a situation is due to people’s demand for land and their migration to Baku and its suburban areas for permanent inhabitation. Some people have even occupied lands belonging to industrial entities and built houses and inhabited there. Health. Current situation of health care can be charactarized as follows: former centralized free health care system has been replaced with free, partially free and private paid medical service. Overall economic situation, low income rate of most part of the population and unemployment issues restrict their access to paid private medical service. Public health is charactarized by statistics given in Table 1.

Table 9 Main indicators of public health (per 1000 men)

Indicators 1985 1990 1997 2005 Marriage coefficient

10,5 10,5 9,0 9,8

Divorce coefficient

1,2 2,0 2,0 2,1

Births 26,6 26,3 22,1 23,4 Deaths 6,8 6,1 7,6 7,2 Child death 29,4 23,0 25,0 24,0 As shown in Causes of deaths among population in Absheron peninsula (Table 2), number of people died in accidents per 1000 men has grown in the last 20 years.

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Table 10 Main causes of death among population (per 1000 men)

Indicators 1985 1990 1997 2005 Total deaths 6,77 6,14 7,6 7,2 Heart diseases 3,22 2,97 3,07 3,12 Cancer 0,74 0,70 0,71 0,70 Accidents 0,43 0,46 0,47 0,49 Respiratory systems

1,08 0,84 0,87 0,85

Because of the lack of statistics about direct or indirect impacts of pollution on death among people living nearby polluted areas, relevant evaluation is impossible. According to existing scientific sources, if hazardous substances from areas polluted with petroleum hydrocarbons regularly enter human body through air, water and plants, they cause neurotoxic skin and respiratory diseases (DEPA (1998) Remediation of contaminated sites, guideline no. 6; Directive 86/278/EEC (1986) “European Council Directive on the protection of the environment, and in particular of the soil, when sewage sludge is used in agriculture”). But surveys among people show that most of the times people build dwellings on, farm polluted lands and do other ground works without understanding its negative effects on health. Poisonings by various gases, diseases of respiratory system, and various infections are encountered among people living in and nearby swamped and oil polluted areas. This kind of situation is even more unfavorable and dangerous for public health when there is no sewer system and other sanitarian systems. Areas having direct contact with dwellings are pilot areas in the project. These areas are in direct neighborhood of 20th Area, Shikhov, Buzovna, Mashtagha and Qala settlements of Baku city. In north-west of Bibihaibat area people have built dwellings in immediate neighborhood of oil wells, and no health and safety rules are followed in this area. Like other communities in Absheron peninsula, Buzovna, Mashtagha and Qala settlements have largely grown and became closer to the areas of oil fields, in some areas even lands belonging to oil field have been occupied illegally. Azerbaijan government has taken number of critical measures to develop rural areas in Absheron peninsula and improve environmental situation. Projects and programs have been prepared to meet people’s demands for drinking water and natural gas, and implementation of these projects and programs will be finished in 2008. Restoration of old, and construction of new, infrastructures (roads, communication systems, schools, hospitals, tourist centers) in all villages and towns is carried out. Besides cleanup of lands polluted with petroleum hydrocarbons, Program on improving environmental situation in Absheron peninsula launched by the Decree of the President of Azerbaijan Republic signed

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on September 28, 2006 includes recycling and utilization of industrial and domestic wastes, construction of health centers (hospitals and recreation centers), gardening works and etc. 3.2.2. Social-economic situation in project areas Bibihaibat area is surrounded by Bibihaibat and 20th Area settlements of Baku city and is located in Sabayil administrative district. All kinds of infrastructure exist in the area, main industries are: oil production, dockyard, sea port, manufacturing, trade, services and etc. Big educational, cultural institutions, sports and health centers are located in this area. In north-west of the area people have built dwellings in immediate neighborhood of oil wells, and no health and safety rules are followed in this area. Buzovna-Mashtagha area is surrounded by Mashtagha settlement in the north and north-west and by Buzovna settlement in the east. Population of Buzovna settlement is 23.6 thousand. The town is well-known as a recreation center. There are many sanatoriums, health resorts and summer recreation centers in the town. There are also manufacturing and gas compression equipment plants, car repair centers in the town. Historical buildings consist of Hasrani Mosque (XXVII century), Ashaghi Mosque (XVIII century) and Mausoleum built in 1641. There are 4 high schools, apprenticeship and boarding schools, library and hospital in the town. Mashtagha settlement is one of the old and big suburban towns of Baku. Population is close to 40 thousand. Agriculture and metal manufacturing are main industries. There are 7 high schools, music school, 2 libraries and an art center in the town. Historical buildings include Bath (XVII century); Agylbaba Sepulcher; Khoja Aslan, Hassan bay, Pershad (XVII century), Gazykhana and Khoja Karbalai Mosques; Reservoir (XIX century), and are still used up to day. Qala settlement was established in XIV century as a fort. Population is close to 3000 today. There are 3 high schools, a club, a library, kindergartens and 3 medical stations in the settlement. Population is mainly employed in oil industry, farming and cattle-breeding and in various services. There are “Mohammed Imamate” sepulcher (1624-1625); Reservoir built in 1655; 3 mosques (XVIII century) and cemetery (XVIII-XIX centuries) in the settlement. Like other communities in Absheron peninsula, Buzovna, Mashtagha and Qala settlements have largely grown and became closer to the areas of oil fields, in some areas even lands belonging to oil field have been occupied illegally. All three towns are situated in Azizbayov administrative district.

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4. SUGGESTED EQUIPMENT AND CLEANING METHODS One of the main directions of SOCAR Policy on cleanup of oil polluted soils is to perform cleanup works in areas which are very highly polluted and have become crisis zones environmentally, and improve the environment. German technical consulting company HPC suggests to SOCAR the following equipment for remediation of oil polluted lands in Absheron peninsula:

• 1 stationary soil remediation steam recirculating washing unit, with 600 m3 of soil cleaning capacity;

• 2 semi mobile soil remediation steam recirculating washing units, with 150 m3 of soil cleaning capacity;

• 4 semi mobile soil remediation steam recirculating washing units with magnet separator, with 150 m3 of soil cleaning capacity.

It is planned to locate a stationary unit in Bibihaibat are, a magnet separator unit in sandy soils of Buzovna-Mashtagha area, and both types of units in Qala area. Recycle of final products of cleanup processes is intended as follows:

• Recultivation of lands; • Boiler houses; • Fuel in cement plant; • Fuel in power stations.

Suggested equipment provides mechanical means for soil remediation by removing petroleum hydrocarbons from soil by steaming. Depending on mechanical composition of soil, magnetic separation method will also be utilized. Units will be set up nearby very high polluted areas. Use of water-agent mixture is intended for oil polluted soils cleanup. Soil remediation technology includes the following works:

1. Extraction/Decanting: Pumping and excavation of the content of the soil ponds by conventional construction methods.

2. Soil washing. Mechanical washing of the contaminated soil into solids, pasty and liquids. Separation of petroleum hydrocarbons from minerals.

3. Processing/recycling. Cleaning pond should have a closed round shape suitable for multipurpose recycling, and should have minimum impacts on environment.

4. Recycling final products of cleanup processes. It should be noted that SOCAR is currently exploiting a soil remediation unit in Binagadi area with cleaning capacity of 15 m3/hour (Fig. 10). A new MS-1 unit is being set up in Bibihaibat area with cleaning capacity of 15 m3/hour as part of local cleanup project of ED (Fig. 11).

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Fig. 10. View of cleanup setup in Binagadi area.

Fig. 11. MS-1 unit being set up in Bibihaibat area.

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Information about the remediation equipment, cleanup methods and technical assessment is provided in the report prepared by HPC consulting company (FEASIBILITY STUDY. Development of Clean-up Strategies and Procurement of Plant and Equipment for the Remediation of Oil-polluted Land, Absheron Peninsula, Azerbaijan).

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5. POTENTIAL ENVIRONMENTAL IMPACTS ASSESSMENT OF CLEANUP WORKS 5.1 Environmental impacts assessment This section talks reviews environmental and social impacts of cleanup operations in the projected areas. Environmental impact is influence of the activity to anything, i.e. any receiver which is not actively linked to work. Receiver could be environment (air, soil or water bodies) and bioenvironment dependant on them (human health and society, flora and fauna). The following criteria are used to assess environmental impacts (Table 11).

Table 11 Criteria used for environmental impact assessment

Category Terms

Scope of impacts

Exact 100 %

Possible 50 %-dən cox, 100%-dən az

Expected 10 %-dən cox, 50 %-dən az

Occurance potential

Not expected 10-dən az

Continuous Constant

Many times Once or more a day

Few Less than once a day

Recurrence

Once Ad hoc occurance

Regional Farther than 10 km (for instant, absheron peninsula)

Province Within 10 km radius

Local Outside sanitary zone

Occurance distance

Direct Within sanitary zone

Continous Over explotation period

Long-term During explotation period

Medium-term More than 1 year

Occurance duration

Short-term Less than 1 year

Very high 200% more than allowed

High Up to 200% more than allowed

Medium As much as allowed

Low More than 50% of allowed

Indicator of impacts on receiver

Very low Less than 50% of allowed

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Environmental and social impact assessment of cleanup equipment and operations include the following areas:

• Emissions from remediation equipment and transports; • Waste waters produced by remediation equipment as a result of technical

processes; • Solid wastes; • Noises and vibrations created by remediation equipment, heavy

equipment doing ground works (bulldozers, excavators), power and steam generators and trucks;

• Emergency situations (overflow of waste ponds, fire, accidents); • Social and economic impacts; • Impacts on health.

5.1.1 Emissions Requirements for pollution level of atmosphere in Azerbaijan are regulated by standards shown in Table 12. World Health Organization and European Union standards are given in Table 13 for comparison. Sources of dangerous gases thrown into atmosphere during remediation works are the following:

• Emission vaporized from remediation ponds; • Gases emitted from remediation equipment during washing and

recirculation; • Gases emitted from steam and power generators; • Gases emitted from heavy equipment (bulldozers and excavators) and

trucks. The following list is based on substances traditionally considered in oil and gas industry. The list includes dangerous substances in air having potential impact on environment and human health:

• Dust; • Nitrogen oxides (NOx); • Carbon dioxide (CO2); • Sulphur dioxide (SO2); • Vaporizing light organic substances (VLOS); • Carbon monoxide (CO); • Methane (CH4).

These are gases emitted during the cleanup process. Only methane is not considered during the assessment of motorized equipment emissions. Emission coefficient used for characterizing each emission source relates emission volume to particular process. This relation can be formulated as follows:

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E = ER x A, where E is emission intensity, ER is emission standard and A is process intensity.

Table 12 Quality standards of air in Azerbaijan Republic

Maximum concentration limit, mg/kg Dangerous substances

Ad hoc maximum

concentration limit

Daily average limit

Dust 0.5 0.15

Sulphur dioxide 0.5 0.05

Carbon monoxide 3.0 1.0

Nitrogen dioxide 0.085 0.04

Nitrogen monoxide 0.4 0.06

Hydrogen sulphide 0.008 0.008

Smoke (soot) 0.15 0.05

Solid fluorine compounds 0.2 0.03

Hydrogen fluoride 0.02 0.05

Chlorine 0.1 0.03

Iodine 2 3

Mercury - 0.0003

Ammonium 0.2 0.04

Nitric acid 0.3 0.1

Formalin 0.035 0.003

Hydrocarbons - 25

Benzopiren - 0.1 mkg/m3

Furfural 0.05 0.05

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Table 13 WHO and EU air quality standards

(Guidance of the World Health Organization on air quality and The Instructions by an estimation and management of air quality. 96/62/Standards of the EU)

Dangerous substance Measured concentration per

hour, mkg/m3

Average annual concentration mkg/ m3

Nitrogen dioxide 400 40

Sulphur dioxide 300 50 (20 for ecosystems)

The following heavy equipment is estimated to be involved in cleanup operations in pilot areas:

• 22 tipper trucks; • 7 excavators; • 8 bulldozers; • 5 power generators; • 5 steam boilers; • 7 graders; • 7 septic vacuum pumps mounted on trucks.

Estimated amount of emissions from heavy equipment to be used by ED of SOCAR during soil remediation works is given in Table 14. These emissions will be produced directly at cleanup areas, and can have local effects in stable weather conditions. As remediation equipment and pumps are powered by electric power, they do not produce direct emissions. Dust emission is inevitable during cleanup works. Dust will pollute the air during excavation and transportation of soil with heavy transport in dirt roads as well. Dust pollution level could be higher in windy weather and it may spread beyond the remediation area. Amount of gases causing greenhouse effect is very small comparing to Azerbaijan’s total emissions (60.8 million tons/year; Initial National Communication of Azerbaijan Republic on Climate Change. Baku, 2000)

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Table 14 Emissions to air during remediation works, tons/year

Amount of emission, t/year No. Emission source Dust CO NOx CxHy СО2 Soot

1 Bulldozers 0 4,56 12,6 3,2 0,72 1,12 2 Excavators 0 3,99 11,0 2,8 0,63 0,98

3 Graders 27 4,01 12,2 3,1 0,98 1,15 4 Loading and unloading soil from trucks 61 0 0 0 0 0 5 Transportation of soil with trucks ( within 2-5

km radius) 13,7 1,1 0,66 0,44 0,22 0,22

6 Power generators 0 0,15 0,07 0,07 0,84 0,05 7 Steam boilers 0 0,35 0,14 0,07 0,95 0,06 8 Septic vacuum pumps mounted on trucks 0 0,47 0,53 0,21 0,12 0,12

5.1.2 Liquid wastes Initial pollution level of cleanup areas with formation waters is very high. Despite the lack of information about groundwater pollution, their pollution possibility is very high. Waste water polluted with petroleum hydrocarbons and heavy metals is produced during soil remediation. A water cleaning unit is planned for use during soil cleanup process. Therefore emission of waste waters into environment is not foreseen. These waters will be either reused or secured. As project pilot areas are located in oil and gas production areas, waste formation waters in the surface will be pumped to water injection facilities and be re-injected into wells to keep formation pressure. 5.1.3 Solid wastes Final hydrocarbon products of remediation processes will be recycled as mentioned in Section 3. Cleaned soil will be hauled back to its original place for soil remediation and reused. In this stage, remediation of soil will be completed in 3-5 years through phytoreclamation. There too much construction debris and domestic wastes in cleanup areas which have been accumulated in a course of many years and still continue by local people. Their geographic range is very big and can be seen everywhere. Domestic wastes pollute both the air and the area, and are main source of infections. Impacts of these wastes are local, and affect surrounding dwellings, especially Qala, Mashtagha and Buzovna settlements and landscape negatively.

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Fig. 12. Construction debris and domestic wastes in Qala area Besides general wastes, very big amount of synthetic based drilling cuttings is accumulated in Bibihaibat area. These wastes rich with toxic substances, including heavy metals impact air and already polluted environment in this area negatively.

Fig. 13. Synthetic based drilling cuttings wastes in Bibihaibat area 5.1.4. Noise Noise is disturbing sounds. It is measured by energy or pressure intensity unit and measured in decibels (dB). Noise level is proportional to audio-frequency range of human ear and is called A-frequency or dBA. Main sources of noise in cleanup processes will be the following:

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• Remediation units; • Pumps; • Bulldozers and excavators; • Tipper trucks; • Steam boilers and power generators.

Noise level from these units in 15 meter distance is given in Table 15.

Table 15

Estimated noise level from remediation equipment in cleanup areas Equipment

Maximum estimated noise level in 15 m distance (dBA)

Bulldozers and excavators 87 Crane 86 Cleanup units 90 Welding equipment 73 Generators 92 Tipper trucks 87 Concrete mixers 87

According to standards valid in Azerbaijan, noise level should be as follows:

• 65 dBAs in daytime; • 45 dBAs in night time.

These standards are very close to that of World Bank (Table 16). Disturbance caused by noise will cover cleanup areas only, therefore will affect only people working in entities situated within soil cleanup areas. Ineffective vibrations will be generated during work and movement of cleanup and heavy equipment. These vibrations will have no impact either on environment or on people.

Table 16 World Bank standards of noise level in environment

(Guidance of World Bank on prevention and release of pollution, 1997)

Maximum allowed noise level (per hour), dBA Receiver Daytime (07:00-22:00) Nighttime (22:00-07:00

Dwellings, organizations, education centers

55

45

Industry, business

70

70

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5.1.5. Emergency situations and risks. Possible emergency situations and risks during can be the following:

• Spill of petroleum hydrocarbons and waste waters over the area by overflow of cleanup ponds;

• Accidents, and fires caused by carelessness of working personnel. Overflow of cleanup ponds can happen only when their level is not balanced well, or because of landslides, hard rains, and etc. This kind of situation is very dangerous for environment and can cause double pollution and serious environmental issues. Fire risk in oil ponds and cleanup facilities in remediation areas is very high. Any carelessness or accident can cause fire within a short period of time. Lots of fire substances, poisonous gases and smoke can be emitted to atmosphere. Depending on scale of fire, its impacts can be local or regional. Air pollution level can be very high in areas where fire spread. 5.2. Social and economic impacts assessment 5.2.1. Introduction The purpose of this section is to determine possible social and economic impacts, evaluate their outcomes, as well as work out relevant recommendations for eliminating or minimizing negative effects (if there is any) during soil cleanup and remediation operations by ED of SOCAR. Description of the project above shows that this kind of projects can have the following social and economic impacts:

• National, regional or local impacts; • Direct or indirect impacts.

National impacts of the projects are the following:

• This project is the first biggest project in soil remediation, and match up with programmes on environmental improvement policy adopted by Azerbaijan Government;

• Successful implementation of programme is very important to remediation of polluted lands in other regions of Azerbaijan, as well as to spreading Caspian region experience.

• The project will assist SOCAR to implement EDP and facilitate its execution;

Local impacts are positive effects on:

• Improvement of environmental situation in pilot areas which are in Absheron peninsula and around its big communities;

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• Public health and people’s life; • Employment; • Inhabitation.

Direct and indirect impacts of the project are also improvements in environmental, social and economic situation in south of Baku city (Shikh, 20th Area and Badamdar), Mashtagha, Buzovna and Qala settlements. 5.2.2. Social and economic impacts of the project. As the project includes environmental remediation works only, it does not have negative impacts. Various direct and indirect impacts can be observed in oil polluted areas in the following areas as a result of project implementation. Employment. Equipment purchased for the project will be used in other areas of Absheron peninsula for soil remediation in the future. Local people will be involved in cleanup work and approximately 120-150 people will get a permanent job. Indirect employment impact is creation of new work places in cleaned areas after soil remediation operations. These could be cement plant, bitumen and asphalt plants and others. For example, for using final petroleum products of soil remediation in cement plant as an alternative fuel, certain personnel will be required to setup and utilize special equipment for transportation and processing of crude oil. Use of soils and Inhabitation. 600-700 ha of very high polluted lands are expected to be cleaned in pilot areas suggested by SOCAR. There is shortage of land in Baku city and its suburb at the moment, and despite bans, people have partially occupied polluted lands in Bibihaibat area (Fig. 14).

Fig. 14. Newly built dwellings in the backgound of cleanup pond in

Bibihaibat area.

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Newly built dwellings have come closer to oil polluted areas in Buzovna-Mashtagha area, too (Fig. 15) and this situation can be observed anywhere in Absheron peninsula.

Fig. 15. New dwellings nearby polluted areas in Buzovna-Mashtagha area High natural growth level of population and internal migration increased demand for land in Absheron peninsula. If all polluted lands in the peninsula (approximately 20 thousand ha) cleaned and returned to use, they can be used for various purposes:

• Selling to people for building dwellings; • Using for agricultural purposes; • Building parks and recreation centers; • Constructing plants and factories for various industrial purposes.

At the moment, options for future use of cleaned soils have not been identified yet. Oil polluted lands currently belong to SOCAR and most of them are under oil wells. Because Bibihaibat is very old oil field, exploitation of oil wells in this field could no more be economically profitable. As an example, oil production in Badamdar area of Bibihaibat field has been stopped in the last 10 years, lands have been sold to people and a big settlement has been founded.

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There are lands in Buzovna-Mashtagha area which are not under oil wells. Productivity of oil wells in this field is also low, and their exploitation may become economically unprofitable in the future as well. Currently land prices in Absheron peninsula are very high compared to other regions of Azerbaijan, and there is land shortage. Land prices change as you get farther from Baku city. Analysing prices to real estate (“Market” and “Birja” newspapers; www.neweuropa.az; www.bakililar.az), the following estimation can be concluded for land prices in dwellings nearby pilot areas:

• Nearby Bibihaibat area – 200-300 thousand USD per ha; • Nearby Mashtagha area – 80-100 thousand USD per ha; • Nearby Buzovna area – 150-200 thousand USD per ha; • Nearby Qala area – 80-100 thousand USD per ha.

With regard to above-mentioned prices, land sales to people can be economically profitable after soil remediation, renovation and infrastructure development in oil polluted areas. However, selling lands to people is not appropriate everywhere. As noted above, options for use of soil are not identified yet, therefore potential impacts can be assessed in a number of different versions (Table 17). Impacts on activities of local population. Generally cleanup areas suggested in the project are situated among producing wells, hence project activities will not have any impacts on activities of local population, transportation, etc. Borders of the cleanup areas will be marked with wire fence and entrance of people will be prohibited. Remediation equipment, auxiliary units and cleanup ponds will be located as far from dwellings and settlements as practicably possible. New roads will be built to connect remediation areas with highways, and some of these roads may be used by local people. Impacts on public health. Remediation of oil polluted lands and renovation of these areas will improve environmental situation in nearby settlements and reduce risks of pollution related infections among people, such as neurotoxic respiratory and skin infections.

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Table 17 Social and economic impacts of the use of cleaned lands

Options for use of soil

Remain under SOCAR and used as is

Sales to people for dwellings

Agricultural purposes

Recreation areas, parks, forests

For industrial purposes

Recommended options

Remediation areas

1 2 3 4 5

Bibihaibat area Use of the area for this purpose is not aprropriate after its remediation. Can be exposed to re-pollution. Results are negative.

As the area is located inside Baku city, multistorey dwellings can be built. A park can be developed in 300-500 m wide area along the coast.

Impacts: - to meet people’s demand for housing, - new jobs in newly developed infrastructures and services, - good condition for healthy growth and entertainment - new incomes to budget.

The area can not be used for agriculture purposes. Location in vicinity of the city and closeness of groundwater to surface restricts the use of soil for this purpose.

Azerbaijan Government plans to build a park-boulevard complex in this area. Construction of hotels, recreation, sports and entertainment centers

Impacts: - positive impacts on public health and entertainment of young generation. - new jobs in entertainment centers, hotels and other services, - taxes from new services

Not recommended. Industrial enterprises will impact the environment negatively.

2; 4

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Table 17 (continuation)

Options for use of soil Recomme

nded options

Remain under SOCAR and used as is

Recommended options Agricultural purposes

Recreation areas, parks, forests

For industrial purposes

Remediation areas

1 2 3 4 5

Buzovna-Mashtagha area

İmpacts: -Re-pollution after soil remediation if not used, - potential erosion and degradation of lands

Development of relevant infrastructure, such as potable water, power, natural gas and sewer systems and construction of roads to fit dwelling purposes of Baku population. Impacts: - to meet people’s demand for summer cottages, - incomes to state budget from land sales, - taxes and incomes to local municipality budgets, - development of new services and jobs.

Lands can be used for development of gardening (grapes, olives), greenhouses, fodder plantations and enclosed cattlebreeding or poultrybreeding. Impacts: - partial development of local practices, - partial satisfaction of employment demands, - insignificant amount of taxes to state budget.

Forests can be fostered in cleaned areas by planting evergreen trees (pine trees, cypresses, olive trees). Impacts: - clean environment, - nice scenery and beautiful landscape, - excursion and picnic place for people.

Not recommended, because the surrounding settlements are used as gardens and recreation areas for population, as well as developing industrial areas in places where oil industry had negative impact on environment can increase pressure on environment.

2; 3

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Table 17 (continuation)

Options for use of soil

Remain under SOCAR and used as is

Sales to people for dwellings

Agricultural purposes

Recreation areas, parks, forests

For industrial purposes

Recommended options

Remediation areas

1 2 3 4 5

Qala area Only oil production sites of the area can be used for this purpose. Impacts: - re-pollution of lands after remediation if not used, - potential erosion and degradation of lands, - re-salinity of soils

Impacts: - to meet people’s demand for summer cottages, - incomes to state budget from land sales, - taxes and incomes to local municipality budgets, - development of new services and jobs.

Lands can be used for development of gardening (grapes, olives), greenhouses, fodder plantations and enclosed cattlebreeding or poultrybreeding. Impacts: - partial development of local practices, - partial satisfaction of employment demands, - insignificant amount of taxes to state budget.

Forests can be fostered in cleaned areas by planting evergreen trees (pine trees, cypresses, olive trees). Impacts: - clean environment, - nice scenery and beautiful landscape, - excursion and picnic place for people.

Not recommended, because the surrounding settlements are used as gardens and recreation areas for population, as well as developing industrial areas in places where oil industry had negative impact on environment can increase pressure on environment.

2; 3

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6. ENVIRONMENTAL MANAGEMENT PLAN 6.1. Introduction Ecological Department of SOCAR has established a reliable working system for following all technical conditions of soil remediation process, adhering to all valid regulating norms and standards on environment, health protection and safety. Main objective of the environmental management is to minimize negative impacts on natural and social environment, reduce environmental risks, adhere to all safety rules and provide implementation of current and strategic plans directed at health protection during soil remediation operations in pilot areas of the project. Main components of the system identifying SOCAR ED environmental management on project are the following:

• Roles, duties and responsibilities of ED management; • Assessment of soil pollution and management of soil remediation; • Assessment and management of wastes and risks; • Data and information; • Exploitation of plants and heavy equipment, provision of technical

services; • Management of changes; • Services of other institutions; • Investigation of accidents and incidents and analysis and elimination of

their results; • Reporting to local communities; • Increasing and assessing reliability of planned operations.

6.2. Measures for minimizing environmental impacts, and waste management 6.2.1. Management of hazardous substances thrown into air As the most modern and newest soil remediation technologies will be employed during the implementation of this project financed by World Bank, amount of emitted gases from these equipment will be competent with technological processes. Other equipment and technical devices used within the framework of project implementation will also be fairly new and competent with standards. Impacts of emissions from auxiliary (power and steam generators, pumps, etc.) and construction equipment and trucks on environment will also be minimal:

• These are local impacts on chemical composition and pollution level of atmosphere;

• Greenhouse effect is insignificant compared to that of other industrial wastes;

• Wastes will spread and disappear within short period of time.

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Management of emissions depends on proper use of equipment and technologies in compliance with their technical characteristics and standards.

The following are measures for emission and dust management:

• Due services to bulldozers, graders, excavators and trucks will be performed in compliance with their exploitation standards, use of recommended fuel will be controlled;

• Regular check of technical condition of all equpment Programme will be prepared and carried out regularly;

• Dirt roads will be watered in arid seasons to prevent dust pollution; • 30 km/h speed limit will be set for movement of vehicles on dirt roads; • Ground works, loading/unloading and transportation of soil will be stopped

when wind speed exceeds 11m/s; • Transported loads will be covered if there is any people and dwellings at

300 m or closer distance. 6.2.2. Management of waste waters There are too much waste waters in all remediation areas. Most of these are formation waters. Flow of waste waters will be stopped first in preparation phase for cleanup works before their removal from remediation areas. Waste water management plans are the following:

• All waste water sources will be eliminated before starting cleanup works. Formation waters flowing into areas will be conveyed to water injection facilities through enclosed concrete channels. Communication of these waters with groundwater and oily ponds will be prevented;

• Sewage and waste waters flowing into Bibihaibat area will be directed to Baku city sewer system;

• Waste water generated by soil remediation equipment will be cleaned through water recycling units and reused. Active coal and filter wastes generated by soil remediation units will be hauled to dangerous waste landfills;

• Waste waters from mobile lavatories used by personnel during soil cleanup operations will be accumulated in septic tanks and removed from the area by sewage trucks;

• Special areas will be built for washing heavy equipment and waste waters from these stations will be cleaned in water processing units, or conveyed to sewer system;

• Fluid level sensors will be set up in remediation ponds to control fluid level in ponds;

• Rain waters will be removed from area through temporary drainage systems to prevent overflow of cleanup ponds caused by rain water flowing down the slopes.

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6.2.3. Solid wastes As mentioned before, there are construction debris, industrial and domestic wastes accumulated in cleanup areas in a course of many years. Removal of these wastes in preparation stage of soil remediation operations is necessary. Solid wastes existing in areas and generated by cleanup processes will be managed in the following manner:

• Boundaries of soil remediation areas should be marked and “no waste”, “no entrance” warning signs should be erected in the area;

• Metal wastes shall be collected and taken to metal processing plants; • Construction debris can be used for filling deep ditches and trenches; • Domestic wastes mainly consisting of paper, polyethylene bottles and

other food containers, domestic devices and etc, will be collected and hauled to Balakhani waste landfill;

• Crude oil, bitumen and other petroleum hydrocarbon products generated in soil remediation processes will be removed from areas by their users (cement and bitumen plants, power stations, etc.) following all safety procedures;

• Domestic wastes (polyethylene, paper, glass and metal food containers, leftover food and etc.) generated by personnel will be accumulated in special trash bins located in the area and hauled to waste landfills.

6.2.4. Management of spills, leakages during transportation and accidents The following proactive measures will be taken to prevent spills and leakages during transportation of wastes and accidents:

• Technical condition of transports will strictly be checked; • Regular technical service and control to heavy equipment will be carried

out; • Personnel will be trained accordingly; • Special procedures will be applied to transportation of wastes within and

outside the areas; • Waste transporting vehicles will be distinguished with special marks.

6.2.5. Management of noise The following actions are planned to reduce noises:

• Equipment and heavy transport will not be used at night time, on Saturdays and Sundays;

• Noise absorbing walls will be set up if there is any dwellings, offices or public places in less than 50 m distance;

• Nearby people and institutions will be warned about high noise during daytime;

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• Special attention will be given to sensitive institutions, especially schools, kindergartens and hospitals;

• Mufflers of heavy equipment will always be kept in good condition. 6.2.6. Fire safety measures Appropriate measures against fire will be taken in compliance with existing laws and safety rules. These measures are as follows:

• Fire fighting equipment will be placed in all cleanup areas, as well as in all objects having fire potential within these areas;

• All personnel will be trained on fire fighting; • Smoking will be prohibited in the field and special areas will be assigned

for smoking • Fire warning marks will be placed on soil remediation equipment,

transports and nearby oil ponds. 6.2.7. Management of emergency situations All technical and human resources of ED, as well as other departments of SOCAR will be involved in prevention of overflow in oil ponds, wide-scale fires, oil waste spills and other accidents. In case of any accident with potential of spreading beyond local boundaries, relevant troops of Ministry of Emergency Situations will be used. 6.2.8. Management of Health and Safety Safety and safe work place is obtained when all personnel strictly and punctually follow all safety rules and regulations. ED has safety, environment and quality control services in its structure, and this service carries out personnel trainings and safety observations in all activities of ED. Work of the service is guided by existing laws, sanitarian rules and SOCAR instructions. SOCAR has the following health and safety regulations:

• Integrated safety management system in oil industry of Azerbaijan. Maarif press, Baku, 1996;

• Safety regulations in oil and gas industry. Danizneftlayihe SRPI. Maarif press, Baku, 1996.

Besides general safety regulations, ED will also organize application of safety rules for soil cleanup equipment during soil remediation operations. Plants and heavy equipment will be utilized in compliance with recommended safety rules in their technical handbooks. The following measures will be taken to protect health of personnel working in polluted areas:

• Health protection trainings will be conducted;

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• All personnel will be supplied with special coveralls; • Personnel working at remediation plants, around oil ponds, in excavation

of very high polluted soils, loading, transportation and unloading of wastes operations will be supplied with protective safety glasses, gloves, long rubber boots and dust masks;

• Mobile shower cabins will be set up for personnel; • Mobile container-rooms will be placed in the field for personnel to rest

during lunch time; • Personnel will be supplied with dairy products daily; • Personnel will pass regular medical check-ups.

6.3. Environmental monitoring plan 6.3.1. Introduction Monitoring is the most important means for environmental management. Planning of monitoring allows to identify and foresee potential impacts. As ED is main environmental organization in SOCAR system, conducting pollution monitoring in all environments - air; water and soil, is one of main directions of its activity. ED has complex environmental monitoring plan for this purpose. It has necessary equipment, technical means and laboratories for conducting monitoring. ED has conducted environmental monitoring in project areas before commencement of soil remediation works, and its results have been included in this document. Monitoring programme in project areas during and after soil remediation operations is described in the following section. 6.3.2. Emissions monitoring plan Air pollution observations will be conducted on the following ingredients:

• Dust; • Nitrogen oxides (NOx); • Carbon dioxide (CO2); • Sulphur dioxide (SO2); • Vaporizing light organic substances (VLOS); • Carbon monoxide; • Methane (CH4).

Measurements will be performed at waste sources using modern mobile devices and in laboratories. Monitoring will be conducted during and after soil remediation operations on a regular base.

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Monitoring of air will take place nearby remediation plants, in oil waste storages, on surface of oil ponds, nearby exhaust pipes of heavy equipment powered with fuel. 6.3.3. Soil monitoring plan Monitoring of soil pollution level will be conducted before and after soil cleanup process, as well as in the field after soil remediation. Soil pollution monitoring will be carried out on the following ingredients:

• pH (potential of hydrogen); • sulphates solved in acid; • organic carbon and carbonates; • total amount of hydrocarbons (C6-C40); • phenols; • polycyclic aromatic hydrocarbons; • metals, including heavy metals (Al, As, Ba, Cd, Cr, Cu, Fe, Hg, Ni, Pb, Sr,

V, Zn); • fractional hydrocarbon compositions; • oil oxidizing microorganisms; • active synthetic substances; • granulometric compositions; • amount of petroleum hydrocarbons.

Monitoring samples will be taken from surface and from depth, i.e. the depth to which pollution is observed. This depth is where petroleum hydrocarbon concentration is 1000 mg/kg or 0,1%. ED will utilize modern sample-extracting devices and conduct laboratory analysis to organize these works in high quality level. 6.3.4. Water monitoring plan Monitoring of chemical composition and pollution level of surface and groundwater in oil polluted areas will be conducted on the following ingredients:

• pH (potential of hydrogen); • total amount of hydrocarbons (C6-C40); • phenols; • polycyclic aromatic hydrocarbons; • metals, including heavy metals (Al, As, Ba, Cd, Cr, Cu, Fe, Hg, Ni, Pb, Sr,

V, Zn); • active synthetic substances; • dry solid matters; • amount of petroleum hydrocarbons; • salinity;

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• anions and cations; • suspensions (colloids); • physical properties of water.

6.3.5. Other monitoring activities Monitoring of noise causing disturbance during soil remediation operations is also planned. Results of the monitoring will regularly be introduced to project implementation team for noise management. Topographic mapping, calculating area and volume of lakes and ponds, identifying pollution distribution and other measurements required for complex environmental monitoring are planned to be performed. ED environmental monitoring plan also includes assessment of radioecological situation. Results of monitoring will be documented in ED and distributed through shared information system among institutions managing soil remediation. 6.4. Consultations Environmental and social aspects of the project have been discussed with ED experts and management, and its final content have been agreed upon. EMP document will be placed in internet address of ED and SOCAR prior to project appraisal. Copies of EMP will be distributed to local ED offices for public information. Copies will also be available in other departments of SOCAR involved in the project. Regular consultations with local communities of the affected areas and NGOs will be held, and their participation in the project will be provided during all stages of project implementation. These consultations will have great importance when project activities directly affect these communities. Natural and social environment must not be changed to their detriment, and any change directly affecting local community shall be made conditional to their prior consent. Representatives of local communities affected by the project and NGOs will be involved in consultations. Consultations, as well as any issues causing public objection shall be recorded and archived, and alternative options shall be studied.

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ANNEX I. ENVIRONMENTAL MANAGEMENT PLAN

Planned Works

Potential Impacts Mitigation Measures Cost (USD per

year)

Institutional Responsibility

Notes

Impact of emission thrown into air is insignificant and personnel will be supplied with special PPE and respirators

25.000

ED

Air pollution control program

Due services to bulldozers, graders, excavators and trucks will be performed in compliance with their exploitation standards, use of recommended fuel will be controlled

n/a

ED

Emissions vaporizing from remediation ponds; gases emitted from cleanup plants during washing and recirculation; emissions from steam and power generators; and emissions from heavy equipment and trucks

Regular check of technical condition of all equpment Programme will be prepared and carried out regularly

22.000

ED

Dirt roads and areas will be watered in arid seasons to prevent dust pollution in remediation areas

10.000

ED

30 km/h speed limit will be set for movement of vehicles on dirt roads

n/a

ED

Air pollution

Dust emission during soil excavation and transportion

Ground works, loading/unloading and transportation of soil will be stopped when wind speed exceeds 11m/s; Transported loads will be covered if there is any people and dwellings at 300 m or closer distance

n/a

ED

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ANNEX I. ENVIRONMENTAL MANAGEMENT PLAN

Planned Works

Potential Impacts Mitigation Measures Cost (USD per year)

Institutional Responsibility

Notes

A water cleaning unit is planned for use during soil cleanup process.

n/a

ED

Dirty waters polluted with petroleum hydrocarbons and heavy metal are generated during oil polluted soil washing process Therefore emission of waste waters into environment is

not foreseen; Waste water generated by soil remediation equipment will be cleaned through water recycling units and reused. Active coal and filter wastes generated by soil remediation units will be hauled to dangerous waste landfills

30.000

ED

Initial pollution level of cleanup areas with formation waters is very high. Despite the lack of information about groundwater pollution, their pollution possibility is very high

All waste water sources will be eliminated before starting cleanup works. Formation waters flowing into areas will be conveyed to water injection facilities through enclosed concrete channels. Communication of these waters with groundwater and oily ponds will be prevented. As project pilot areas are located in oil and gas production areas, waste formation waters in the surface will be pumped to water injection facilities and be re-injected into wells to keep formation pressure.

n/a

SOCAR/ED

Sewage and domestic waste waters flowed to areas by local residents

Sewage and waste waters flowing into Bibihaibat area will be directed to Baku city sewer system.

n/a

Azersu JSC, Sabayil district executive power

Polluted waters

Domestic waste waters generated by personnel

will be accumulated in septic tanks and removed from the area by sewage trucks

15.000 ED

Water pollution control program

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ANNEX I. ENVIRONMENTAL MANAGEMENT PLAN

Planned Works

Potential Impacts Mitigation Measures Cost (USD per

year)

Institutional Responsibility

Notes

Waste waters generated during heavy equipment wash

Special areas will be assigned and waste waters will be cleaned in water processing units, reused or conveyed to sewer system

20.000 ED Waters

Waste water spil caused by overflow of cleanup ponds

Special areas will be assigned and waste waters will be cleaned in water processing units, reused or conveyed to sewer system

50.000 ED

Water pollution control program

Boundaries of soil remediation areas should be marked and “no waste”, “no entrance” warning signs should be erected in the area before the commencement of remediation works

25.000 ED

Metal wastes shall be collected and taken to metal processing plants

n/a

ED and client

Construction debris can be used for filling deep ditches and trenches

n/a

ED

Solid wastes There too much construction debris and domestic wastes in cleanup areas which have been accumulated in a course of many years and still continue by local people. Their geographic range is very big and can be seen everywhere. Domestic wastes pollute both the air and the area, and are main source of infections. Impacts of these wastes are local, and affect surrounding dwellings, especially Qala, Mashtagha and Buzovna settlements and landscape negatively

Wastes mainly consisting of paper polyethylene and other food containers, domestic equipment and etc. will be accumulated in special trash bins located in the area and hauled to waste landfills

30 000 ED

Soil pollution control program

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ANNEX I. ENVIRONMENTAL MANAGEMENT PLAN

Planned Works

Potential Impacts Mitigation Measures Cost (USD per

year)

Institutional Responsibility

Notes

Oily wastes generated during cleanup processes

Crude oil, bitumen and other petroleum hydrocarbon products generated in soil remediation processes will be removed from areas by their users (cement and bitumen plants, power stations, etc.) following all safety procedures Loading and transportation procedures will be agreed with ED

n/a ED And Client

Domestic wastes generated by personnel

Domestic wastes (polyethylene, paper, glass and metal food containers, leftover food and etc.) generated by personnel will be accumulated in special trash bins located in the area and hauled to waste landfills

7 500 ED

Solid wastes

Pollution caused by spills and leakages during transpotation and accidents

Technical condition of transports will strictly be checked; regular technical service and control to heavy equipment will be carried out; personnel will be trained accordingly; special procedures will be applied to transportation of wastes within and outside the areas; waste transporting vehicles will be distinguished with special marks

15 000 ED

Soil pollution control program

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ANNEX I. ENVIRONMENTAL MANAGEMENT PLAN

Planned Works

Potential Impacts Mitigation Measures Cost (USD per

year)

Institutional Responsibility

Notes

Noise Noises from remediation units, pumps, bulldozers and excavators, tipper trucks, steam boilers and power generators

Equipment and heavy transport will not be used at night time, on Saturdays and Sundays;

Noise absorbing walls will be set up if there is any dwellings, offices or public places in less than 300 m distance;

Nearby people and institutions will be warned about high noise during daytime ;

Special attention will be given to sensitive institutions, especially schools, kindergartens and hospitals ; Mufflers of heavy equipment will always be kept in good condition.

35 000 ED Noise monitoring plan

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ANNEX I. ENVIRONMENTAL MANAGEMENT PLAN

Planned Works

Potential Impacts Mitigation Measures Cost (USD per

year)

Institutional Responsibility

Notes

Health and safety

Impacts on personnel health Health protection trainings will be conducted;

All personnel will be supplied with special coveralls;

Personnel working at remediation plants, around oil ponds, in excavation of very high polluted soils, loading, transportation and unloading of wastes operations will be supplied with protective safety glasses, gloves, long rubber boots and dust masks; Mobile shower cabins will be set up for personnel; Mobile container-rooms will be placed in the field for personnel to rest during lunch time; Personnel will be supplied with dairy products daily; Personnel will pass regular medical check-ups.

n/e ED Personnel health and safety protection program

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ANNEX I. ENVIRONMENTAL MANAGEMENT PLAN

Planned Works

Potential Impacts Mitigation Measures Cost (USD per

year)

Institutional Responsibility

Notes

Health and Safety

Fire risks

Fire fighting equipment will be placed in all cleanup areas, as well as in all objects having fire potential within these areas; All personnel will be trained on fire fighting; Smoking will be prohibited in the field and special areas will be assigned for smoking; Fire warning marks and signs will be placed on soil remediation equipment, transports and nearby oil ponds.

25 000

ED/SOCAR

Health and Safety protection program

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ANNEX II. ENVIRONMENTAL MONITORING PLAN

Planned Monitoring

Pollution Source Monitoring Frequency Effectiveness Indicador

Cost (USD per

year)

Institutional Responsibility

Notes

• Remediation plant • Petroleum

hydrocarbon emission evaporated from oil waste pits and oily ponds

• Exhaust pipes of heavy equipment powered with fuel

• Every 10 working days • Every day in case of local

accidents and fires • Continuous in case of

regional-scale accidents and air pollution

Control over tolerance limits of wastes

Emissions thrown into Air

• Dust generated by soil excavation and transportation

Continuous visual observation Control over tolerance limits of wastes

20 000

ED Monitoring Department

Existing waste water ponds in areas

Once before the commencement of soil remediation operations

For identifying and securing pollution source

10 000 ED Monitoring Department

Waste water generated by remediation plant

• Once a month in normal working mode

• Additional monitoring during any deviation in technological processes

Cleanup control for identifying safety

15 000 ED Monitoring Department

Water

Domestic waste waters generated in cleanup areas

Continuous visual control to prevent water pollution

To prevent repollution of soils

Not required ED supervisors in remediation areas

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ANNEX II. ENVIRONMENTAL MONITORING PLAN Planned Monitoring

Pollution Source Monitoring Frequency

Effectiveness Indicator

Cost (USD per

year)

Institutional Responsibility

Notes

Solid wastes

Unorganised wastes, old oily wastes in areas

Once before the commencement of soil remediation operations

For identifying and securing pollution level

15 000 ED Monitoring Department

Noise Noise generated by heavy equipment, remediation plants and transport working in cleanup areas

Once a month Control over prevention of transcending limits by technical equipment

7500 ED Monitoring Department

Soil pollution Formation water and oil spills, old oil storage pits

• Once before and once after the commencement of soil remediation operations

• Once a year in remedied soils

Identifying pollution and remediation levels

15 000 ED Monitoring Department

Soil monitoring • Once in every 5 years • Once in every 5 years

to identify background level

Control over pollution level of areas

10 000 ED Monitoring Department

Water monitoring Once a year

Control over water pollution

15 000 ED Monitoring Department

General monitoring in oil polluted areas of oil and gas production fields of SOCAR

Radioecological monitoring Once a year Control over radiation level

10 000 ED Monitoring Department

Public monitoring Regularly involving NGOs and local residents

Environmental and social consequences of remediation operations

4 000 ED/NGOs