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As part of due diligence for this project, an independent environmental
consultant was retained to complete an environmental audit of the project. In
addition to the environmental audit, the consultant reviewed the status of
environmental management of the company and reviewed the Russian version of
the environmental impact assessment (EIA) that was prepared for national
project permitting/approval.
There were no significant environmental liabilities identified in the
environmental audit. Operation of the pipeline does not cause significant
harm to the environment. Further, there are engineering controls in place to
minimize any potential leakage from the pipeline, and to provide early
response in the unlikely event of a leak. This includes 23 solar powered
monitoring stations and computerized shut off valves. While the majority of
these valves are located at regular intervals along the pipeline, there are
also valves on each side of major river crossings.
It was noticed during the audit that there is a lack of due coordination of
activities between the Company and KTO (the operator) in the process of
obtaining permits for the use of natural resources issued by governmental
environmental supervisory agencies. The existing communications between the
MunaiTas Company and KTO do not ensure at present adequate exchange of
information required for effective joint environmental management in the
process of the oil pipeline operation. Recommendations to address these
issues are presented in the audit report.
In addition, there is lack of a clear structure for environmental management
and division of responsibilities between the Client, the contractor and the
pipeline operator. The Client, MunaiTas” NWPC” CJSC, the owner of the
pipeline, is legally responsible for environmental regulatory compliance of
any activities related to its facilities as a whole, regardless of its
contractors’ obligations. At the same time, the contract signed between
MunaiTas and Stroytransgas, main construction contractor, makes the latter
responsible for environmental regulation compliance of activities related to
MunaiTas facilities for the period of construction and, partly, two years
after the state acceptance of the pipeline (warranty period). While, the
contract signed between MunaiTas and KTO, the pipeline operator, makes the
latter responsible for environmental regulation compliance of the operations
related to MunaiTas facilities. These issues are addressed in the
Environmental Action Plan for the project.
While this project is screened C/1, the EIA completed for national permitting
purposes was also reviewed. A summary of this EIA is attached to this PSD.
As outlined in the summary document, the scope of work completed for the EIA
for this project is adequate and the EIA was completed to a high standard.
The EIA confirmed that the project is not located in a highly sensitive or
unique environment. There were no rare or endangered species identified in
the site area, and there were no unique habitats identified in the pipeline
corridor.
There is an Environmental Impact Assesment available for this project.
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