76 464 mepa water quality eec 2000

Assessing the Impact of Compliance

with CD 76/464/EEC and other related Water Quality Directives with

Reference to Marine Discharges In Malta

For the Ministry for the Environment

Victor Axiak

Carmen Delia

Final Report, 30 November 2000

CONTENTS 1. INTRODUCTION 1

1.1 Terms of Reference for the Study 1 1.2 Definitions of Terms Used. 2 1.3 Boundaries of Study 3 1.4 Approaches Adopted and Investigations Undertaken 5

1.4.1 Review of Archived Data 5 1.4.2 Interviews with Industries 5 1.4.3 Field Monitoring 6 1.4.4 Consultations 6

1.5 Work Team 6 1.6 Structure of the Report 7

2. EU ENVIRONMENTAL LEGISLATION AND DIRECTIVES RELEVANT TO THIS STUDY. 8

2.1 EU Environmental Legislation 8 2.1.1 Introduction 8 2.1.2 Legislative Acts 8 2.1.3 Review of EU Environmental Legislation dealing with Water Quality 9

2.1.3.1 Legislation to protect Water according to its Specific Use 10 2.1.3.2 Legislation Relating to Specific Industries 10 2.1.3.3 Legislation Relating to the Source of Pollution 11 2.1.3.4 Legislation To Protect The Aquatic Environment From Pollution By Certain Dangerous Substances. 11

2.2 Council Directive 76/464/EEC On Pollution Caused By Certain Dangerous Substances Discharged Into The Aquatic Environment Of The Community 11

2.2.1 Provisions of the Directive 11 2.2.2 Implementation of Directive by Member States 15

2.3 Council Directive 91/271/EEC Concerning Urban Waste Water Treatment 16 2.3.1 Provisions of Directive 16

2.3.2 Assessment of Implementation of Directive by Member States 17

2.4 The Water Framework Directive: European Parliament and Council Directive establishing a framework for Community action in the field of water policy 18 2.4.1 Relevant Provisions of the Water Framework Directive. 19 2.4.2 Development of Principles at EU Level 21 2.4.3 The Water Framework Directive and Implementation of

CD 76/464/EEC. 22 3. WATER QUALITY, MARINE AND SEWER DISCHARGES:

Compliance Impact of CD 76/464 EEC and other Water Quality Directives Contents

CURRENT LOCAL LEGISLATION AND PROVISIONS. 25

3.1 Transposition of EU Water Quality Directives related to Discharges 25 of Waste waters.

3.2 Wastewater Discharges into Public Sewers: LN 8/93 26 3.3 Degree of Present Compliance with LN 8/93. 27 3.4 Cost of Compliance on part of Industry for Sewer Discharges 29 3.5 Special Considerations for SMEs 30 3.6 Control of Wastewater Discharges into the Marine Environment 32

4. MONITORING PROGRAMME 35

4.1 Introduction 35 4.2 Stations Monitored and Sampling Protocol 35 4.3 Range of Potential Marine Contaminants Investigated 36 4.4 Results 37

5. ASSESSING IMPACT OF COMPLIANCE BY SECTOR 38

5.1 Point versus Diffuse Source of Marine Discharges 38 5.2 Sectors and Elements of Assessment 38 5.3 Assessment Methods Adopted 39

5.3.1 Interviews with Industries 40 5.3.2 Field Monitoring 41

5.4 Presentation of Results 41 5.5 Quality of Data 42

5.5.1 Data on Discharged Waste waters 42 5.5.2 Costing of Treatment Plants 42

5.6 Required Time Frame for Compliance 43 5.7 Confidentiality of Data Presented in this Report 44

6. IMPACT OF COMPLIANCE: FISH FARMING SECTOR 45

6.1 General Background 45 6.2 Present Information on the Environmental Impact of Fish farming in Malta 46

6.2.1 Water Quality Reports by the National Aquaculture Centre: 1995-1998. 47 6.2.2 Life Project: Monitoring Programme: 1997-1998 48 6.2.3 Coastal water quality Monitoring Programme: 1998-2000 48 6.2.4 Impact On Benthic Habitats 49 6.2.5 Environmental Impact: Conclusion 50

6.3 Legislation and Control of Local Fish Farming 50


6.4 Assessment of Individual Fish Farming Units 52 6.4.1 National Aquaculture Centre (FF1) 52 6.4.2 Pisculture Marine de Malte, P2M: (FF2) 53 6.4.3 Malta Mariculture Ltd. (FF3) 54 6.4.4 Fish and Fish Ltd. (FF4) 55

6.5 Impact of Compliance on Fish Farming 56

7. IMPACT OF COMPLIANCE: FUEL TERMINALS 58

7.1 General Background 58 7.2 Environmental Impact of Sector on Water Quality in Malta 58

7.2.1 Risks of Contamination 58 7.2.2 Levels of pollution of coastal waters by oil and its products. 59 7.2.3 Levels of Oil Pollution: Summary 61

7.3 Assessment of Individual Fuel Terminals 61 7.3.1 Malta Drydocks Tanker Cleaning Facility (OT1) 62

7.3.1.1 Fuel Terminal Profile 62 7.3.1.2. Quality of Discharged Effluents 63 7.3.1.3 Levels of petroleum oils in water in the vicinity of the

discharge point. 64 7.3.1.4 Upgrading the Installation 66 7.3.1.5 MD Tanker Cleaning Facility: Conclusions of Assessment 67 7.3.1.6 Potential Options to ensure Compliance 67

7.3.2 Oiltanking Malta Ltd (OT2) 71 7.3.2.1 Company Profile 71 7.3.2.2 Waste water Generation 72

7.3.3 Mediterranean Offshore Bunkering Company Ltd. (OT3) 72 7.3.3.1 Company Profile 72 7.3.3.2 Generation and Treatment of Wastewaters 73 7.3.3.3 Degree of Compliance and Costs. 74

7.3.4 Waste Oils Company Ltd. (OT4) 75 7.3.4.1 Company Profile 75 7.3.4.2 Generation and Treatment of Waste Waters 75 7.3.4.3 Chemical Composition of Waste waters 75 7.3.4.4 Degree of Compliance 76

7.3.5 ENEMALTA Petroleum Division (OT5) 76 7.3.5.1 Profile and Waste waters Production 76 7.3.5.2 Compliance and Costs 79

7.3.6 Maritime Base (Armed Forces of Malta) (OT6) 79 7.3.6.1 Relevant Activities and Operations 79 7.3.6.2 Risks of Pollution by Oil 80 7.3.6.3 Level of Compliance 81

7.3.7 Other Fuel Terminals 82 7.4 Impact of Compliance on Fuel Terminals 82


8. IMPACT OF COMPLIANCE: ELECTRICITY GENERATION AND FRESHWATER PRODUCTION 84 8.1 General Background 84

8.1.1 Electricity Generation 84 8.1.2 Freshwater Production 85 8.1.3 Trends In Water Consumption And The Impact On Energy Consumption 86

8.2 Assessing Impact of Compliance by the Power Stations 87 8.2.1 Marsa Power Station (PP1) 87

8.2.1.1 Operations 87 8.2.1.2 Generation of Waste waters 88

8.2.2 Delimara Power Station (PP2) 89 8.2.2.1 Operations 89 8.2.2.1 Generation of Waste waters 89

8.2.3 Analysis of Marine Discharges 90 8.2.4 Thermal Discharges 90 8.2.5 Compliance and Costs for Power Stations 92

8.3 Assessing Impact of Compliance by Reverse Osmosis Plants 93 8.3.1 Malta Desalination Services (RO1,RO2,RO3) 93 8.3.2. Marine Discharges from RO plant 93 8.3.3 Level of Compliance 95

9. IMPACT OF COMPLIANCE: SHIP YARDS AND SHIP REPAIRING 97

9.1 General Background 97 9.2 Malta Drydocks (SY1a) 97

9.2.1 Introduction 97 9.2.2 Assessing Marine Discharges 98

9.2.2.1 Machine Shop 98 9.2.2.2 Electrical Shop and Electronics Department 100 9.2.2.3 Galvanizing Shop 101 9.2.2.4 Acetylene Plant 101 9.2.2.5 Motor Plant Repair Shop 101 9.2.2.6 Dock Works 102

9.2.3 Compliance: Common Wastewater Treatment Facility for the MD 106 9.3 Manoel Island Yacht (SY1b) 106 9.4 Summary of Compliance Costs for MD (not including MDTCF) 108 9.5 Cassar Ship Repair Ltd. (SY2) 109

9.5.1 Company Profile 109 9.5.2 Operations 109 9.5.3 Marine Discharges 110 9.5.4 Volumes of Marine Waste waters 111 9.5.5 Costs of Compliance 111

9.6 Bezzina Ship Yard Ltd. (SY3) 112 9.7 Other Ship Yards and Maritime Related Installations 112 9.8 Summary of findings for the Ship Yard and Ship Repairing Sector 112


10. IMPACT OF COMPLIANCE: OTHER INDUSTRIES 114

10.1 Introduction 114 10.1.1 Industrial Discharges into Sewers 114

10.2 Industrial Wastewater Discharges into the Marine Environment 114 10.2.1 Half Far Industrial Estate (IN1) 115

10.2.1.1 General Description of the Estate 115 10.2.1.2.1 Generation of Waste waters 115 10.2.1.2.2 Treatment Plant at Hal Far 116 10.2.1.2.3 Compliance 117

10.2.2 Comino Pig Farm ( Koperatiiva ta’ min irabbi l-Majjali Ltd.) 117 10.2.2.1 Profile 117 10.2.2.2 Generation of Waste waters 118 10.2.2.3 Quality of Marine Discharges 119 10.2.2.4 Compliance Costs 119

10.2.3 Vernon’s Food (IN3) 120 10.2.3.1 Company Profile 120 10.2.3.2 Discharge of cooling waters 120 10.2.3.3 Compliance Cost 120 10.2.4 Other Industries 121

10.3 Summary of findings for Other Industries 122

11. IMPACT OF COMPLIANCE: HOTELS AND RECREATION

ESTABLISHMENTS 124

11.1 Introduction: Tourism Development 124 11.2 Tourism, Hotels and Tourist Related Recreation 125 11.3 Assessment of Marine Discharges by Hotels 126

11.3.1 Comino Hotel (HR3) 126 11.3.2 Other Coastal Hotels 127 11.3.3 Mediterraneo , Marine Land Ltd. (HR11) 128 11.3.4 Other Discharges 128

12. IMPACT OF COMPLIANCE: MARINE DISCHARGES FROM PUBLIC SEWERS. 130

12.1 Introduction 130 12.2 Sewage Outfalls 130 12.3 Sewage Overflows (Emergency Discharges) (SGe) 131 12.4 Wastewater Composition 132 12.5 Wastewater Treatment 133 12.6 Disposal of Activated Sludge 135 12.7 Compliance 135

12.7.1 Malta North and Malta South Plans 135


12.7.2 Gozo Plans 136 12.7.3 Treatment Technology to be Adopted 136 12.7.4 Treatment and Disposal of Sludge 137 12.7.5 Compliance Costs 138 12.7.6 Cost of Investment in the Sewage Master Plan per population Equivalent 138

13. ASSESSING IMPACT AND CONTROL OF NON-POINT DISCHARGES 140

13.1 Introduction 140 13.2 Agricultural practices 140 13.3 Animal Husbandry 141 13.4 Marinas and other Maritime Related Activities 142 13.5 Landfills 142 13.6 Control to ensure Compliance 143

14. CURRENT ECONOMIC BACKGROUND AND

FUTURE DEVELOPMENT IN RELEVANT SECTORS 144

14.1 Introduction 144 14.2 Demand and Supply Conditions 144 14.3 Current Status 146

14.3.1 Demographic Review 146 14.3.2 Household Income and Expenditure 147 14.3.3 Industrial Growth 148 14.3.4 Agriculture and Fisheries 148 14.3.5 Manufacturing Industry 149 14.3.6 Plastic and Rubber 149 14.3.7 Basic Metals and Fabricated Metal Products 149 14.3.8 Machinery and equipment 149 14.3.9 Electrical machines 149 14.3.10 Communication Equipment and apparatus 150 14.3.11 Services Sector 150 14.3.12 Malta Financial Services 151 14.3.13 Malta Freeport Corporation Ltd. 151 14.3.14 Recent Trends in Importation of Chemicals 151 14.3.15 Summary of Recent Trends 152

14.4 Future Development 152 14.4.1 Predicting Development in the Manufacturing Sector 153 14.4.2 Other Developments 154


15. AUTHORIZATION SYSTEM FOR DISCHARGES INTO THE MARINE ENVIRONMENT 157

15.1 Introduction 157 15.2 Two Authorization Systems 157 15.3 Responsibilities of Authorization System Controlling Marine Discharges 159

15.3.1 Classification of coastal waters 159 15.3.2 Setting up of Water Quality Objectives 160 15.3.3 Water Quality Elements 161 15.3.4 Identification of Human Impact and Economic Implications 161 15.3.5 Protected Areas and Sensitive Areas 162 15.3.6 Monitoring Obligations 162 15.3.7 Control of Marine Discharges 164

15.4 Establishing Pollution Reduction Programmes 164 15.4.1 Need for a Single Co-Ordinating Body 165 15.4.2 Identification of Relevant Pollutants to be Covered 165 15.4.3 Quality Objectives and Compliance Monitoring 166

15.5 Establishing Criteria of Impact of Specific Substances 166 15.5.1 Toxic Effects 167 15.5.2 Environmental Fate 168 15.5.3 Bioavailability of Pollutant 168 15.5.4 Bioaccumulation 168 15.5.5 Applying a combination of Environmental Standards 169

15.6 Cost Implications of Authorization System 170 15.7 Need for a Single Compliance Co-Ordinating Body 171

16. OVERVIEW OF COMPLIANCE COSTS, COST RECOVERY AND

REQUIRED TIME FRAME 173 16.1 Summary of Costs 173

16.2 Scale of the Investment Needs 175 16.3 Potential benefits of the Investment Programme 178 16.4 Cost Recovery 178

16.4.1 Additional Costs due to Compliance: Waste Oil Company Ltd. 179 16.4.2 Additional Costs due to Compliance: MOBC Ltd. 180 16.4.3 Additional Costs due to Compliance: Fish and Fish Ltd 181 16.4.4 Recovery of Compliance Costs: Drainage Department 181 16.4.5 Cost Recovery: Conclusion1 183 16.4.6 Financing of upgrading programmes 183

16.5 Required Time Frame for Compliance 184

ANNEX 1 List of organizations with which Consultations were held for


the purpose of this Study. 1 page ANNEX 2 Monitoring Programme for the purpose of the Present Study. Analytical Protocols and Results of Analysis of Waters and Waste Waters. 76 pages ANNEX 3 Questionnaire Used for Survey of Industrial Marine Discharges 8 pages ANNEX 4 List of Industries and Personnel Interviewed 2 pages ANNEX 5 Location of Marine Discharge Points Investigated 1 page ANNEX 6 Capital Cost Estimates of Relocating the MD Tanker Cleaning Facility from its present location in Grand Harbour (Chapter 7). 1 page ANNEX 7 Financing Upgrading Programme 6 pages


EXECUTIVE SUMMARY The report carries out an appraisal on point sources of liquid discharges to the marine environment, and assesses the current load of effluents from such sources as arising from different industrial and other sectors. In doing so, it identifies per sector, those requirements for provisions and measures that have to be taken into account to ensure compliance with a range of EU water quality Directives which are relevant to marine discharges. The relevant Directives were mainly: the Dangerous Substances Directive 76/464/EEC and its daughter Directives; the Urban Waste Water Treatment Directive 91/271/EEC and the Water Framework Directive. As a first approximation, the global estimated capital costs required for compliance, would amount to between Lm 45 million or 108.5 million EUROs (best-case scenario) to Lm 65 million or 157.6 million EUROs (worst-case scenario), with the final figure being probably closer to the lower limit. The biggest extent of uncertainty is that related to the fuel and oil terminals. The highest capital costs per m3 of wastewaters discharged, are those produced by ship yards and ship repairs. Annual running costs, which are attributed directly to compliance with the relevant Directives amount to Lm 2.24 million or Lm 2.37 million, for the best-case and the worst-case scenarios respectively. If these investment costs are amortised over a fifteen-year period at a 3% real discount rate, the annual capital requirement is between 9.082 in a best scenario and 13.201 million EUROs in a worst scenario. The impact of the investment on the Maltese economy will depend to a large extent on the timing of the investment programme. Annualised investment needs account for 0.28 per cent of GDP for 1999 in the best scenario and 0.407 per cent of GDP in the worst scenario. The required time frame for compliance for different sectors varies from 1 to 4 years. In each case, the time frame for compliance has been estimated in terms of the number of years required for implementation of the relevant compliance programme, assuming that the necessary administrative decisions have been already taken and that the necessary financial and other resources would have been made already available. No allowance was made for undue delays in compliance-related policy and decision making by the respective authorities or companies, as well as for any difficulties, which may arise to allocate the necessary funds and other resources. Assuming that Malta will aim at EU accession at the beginning of 2003, then the longest time frame required will be for the compliance by the public sewerage system, (i.e. by 2005).

Under these circumstances, it would be wise to ask for a transition period of 3 to 4 years and preferably 4 years, for Malta to comply with the provisions of the relevant directives. This transition period will not be specified for any one single sector, but will apply for all sectors. This would make up for any delays in efforts to procure the necessary financial and other resources as well as in decision-taking for the implementation of the compliance programme. Such a transition period of 4 years is quite reasonable since, it will not induce any distortion of competition within the EU; it should not have heavy consequences on the EU budget; and it is reasonably limited in time and scope. The report makes recommendations concerning the authorization system that will be required to control marine discharges according to provisions of the relevant Directives. Another authorization system to control discharges into the public sewers is already in place. We must ensure that the various programmes of implementation by the different entities will be fully integrated in a common environmental strategy and work plan. For this purpose it is proposed that the Ministry for the Environment (as the Competent Authority) will set up an inter-departmental body which would be responsible for the implementation of water pollution reduction and pollution control programmes. Such a body, will be entrusted with the coordination of the implementation of all provisions of the relevant water quality Directives. It should have a sufficiently high level of administrative authority to ensure that the different players will comply with its policies and decisions. It is proposed that this Compliance Co-ordinating Body will have the following responsibilities:

a) Co-ordinate the various programmes at the Governmental level, which will be required for the implementation of the various provisions of the EU water quality Directives;

b) Ensure that there are no gaps or inconsistencies amongst such compliance programmes as being implemented by the various Departments (e.g. the Environment Protection Department and the Drainage Department);

c) Ensure that any further development of legislation to control discharges, as well as to ensure compliance, will be carried out in full consultation with the Private Sector and Industry, as well as any other partner;

d) Assist the Private Sector in identifying the requirements arising from the provisions of the EU Directives;

e) In collaboration with the Private Sector, set up a time schedule for compliance, taking into consideration any transition periods which may be granted by the European Commission to Malta;

f) Ensure, through constant supervision, that this time schedule for compliance is being met by the various partners;

g) Elicit public support for the whole compliance programme, through comprehensive information and education programmes.

1. INTRODUCTION

1.1 Terms of Reference for the Study The terms of reference for the study were provided by the Ministry for the Environment as follows:

a. Carry out an appraisal on all point sources (discharges) of pollution to the marine

environment, based on type and quantity;

b. Assess the current load of effluents from sources, whether land-based or

otherwise, and thus predict the expected trends over the next decade. This

assessment will be based mostly on archived data;

c. Determine the proper methodologies on how to establish the criteria of the degree

of effect of certain substances, namely on the basis of their toxicity, persistence

and bioaccumulation;

d. Identify and enlist, in view of the provisions of Directive 76/464/EEC and the

Daughter Directives, those sectors that are most likely to be affected;

e. Identify per sector, those requirements for provisions/measures that have to be

taken into account in each sector in order to abide by the provisions relating to

limitation and monitoring;

f. Wherever possible, estimate and analyze the costs that would be incurred to

ensure compliance. This estimate will be based on information made available

from the plants/establishments themselves. This estimation of compliance should

produce an ’order of magnitude’ estimate of the costs involved;

g. Make recommendations concerning the appropriate measures and structures that

would be required to enforce these provisions (i.e. concerning the authorization

system);

h. Assess the operational implications and propose alternative scenarios for

compliance specifying time frame required;

i. Specify time frame required for the compliance.

Compliance Impact of CD 76/464 EEC and other Water Quality Directives

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These TOR were elaborated upon in a detailed project proposal submitted to the Ministry for the Environment on the 10th March 2000. A contract for consultancy services was signed on the 16 May 2000. Mr. Joe Callus (Head of Section) and Ms Prassede Grech, from the Pollution Control Co-ordinating Unit within the Environment Protection Department, were subsequently appointed as liaison officers for this study. Following a number of consultation meetings with these liaison officers, the original TOR were expanded upon so that the study would include an assessment of other EU water quality Directives which may be relevant to the discharge of waste waters into the marine environment. These include CD 91/271/EEC which concerns urban waste waters, and other Directives. 1.2 Definitions of Terms Used.

For the purpose of this report, the following definition of terms shall apply:

Waste waters shall mean any liquid effluents which are generated as a result of an industrial or other activity, or which are used for such activity and which subsequently need to be disposed off. These shall include reject waters. Marine Discharge shall mean any direct or indirect release of waste waters into the marine environment. Point of discharge shall mean any plant, treatment facility, establishment, factory, pipeline, or any other site or means from which release of a substance, effluent or pollutant into a receiving body of water takes place. Diffuse Source of Discharge shall mean the release of effluents from multiple sources which may not be easily defined in terms of geographical location and/or time. Competent Authority shall mean the authority or authorities or bodies responsible under the legal provisions of Malta for carrying out the obligations arising from EU Directives. Sewage shall mean urban and domestic waste water arising usually from residential settlements and services or from animal farms, which originates predominantly from human and/or animal metabolism and from household activities.


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Treatment plant shall mean an installation or system which acts on waste waters in order to reduce the levels of their contaminants to satisfactory limits. Sludge shall mean the residual material arising from a treatment plant. Coastal waters shall mean the marine waters extending from the shoreline up to territorial waters. Run-off shall include rainwater which is not absorbed by the ground or which does not evaporate and which subsequently reaches the marine environment. Industry shall mean any manufacture or production of goods or any provision of service(s) as part of normal business practices. Other terms and definitions used in the present report, and not included in the above list, shall have the same meaning as that stated in the relevant Council Directives or local legislation.

1.3 Boundaries of Study

The ultimate aim of the study is to provide the national negotiating team for accession to the European Union, with the best possible and most reliable data base on which to proceed during its deliberations and discussions with the Commission. Furthermore this information is to be made available in the proper format on the basis of which policy-makers and negotiators will be able to act. Nonetheless, due to the particular circumstances and ‘status quo’ of the present administrative structures responsible for the various sectors of the environment, as well as to the limited time and resources available, it was agreed that the study will proceed within the following boundaries: Sources and Discharge Points. For the purpose of quantitative assessment, only the most significant marine point discharges had to be considered. Furthermore, point sources were defined as those points of discharges of waste water which may collect effluents from one or more inland or sea-based activities and which discharge directly on the shoreline or at some distance out into the sea. This means that point sources of discharges of


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industrial effluents into the public sewers will not be taken into consideration for the purpose of the quantitative assessment. Most industries generate waste waters or industrial effluents that are discharged in the public sewers. The compliance costs on part of industry for sewer discharges will be significantly high and may well represent a significant impact on the local industry. No attempt has as yet been made to assess such costs. Originally it was planned to assess point sources of industrial discharges into sewers, only in a general manner and this assessment was to be based on archived data only. Subsequent consultation meetings with the Director of the Drainage Department showed that such an assessment would not be possible within the framework of the present study. This is mainly because:

a) The limited information and archived data on industrial discharges into sewers could not be made available to the present consultants due to confidentiality;

b) The DD had confirmed that it does not require any additional impact

assessment of compliance with EU Directives arising from discharges into sewers. The DD had argued that in any case, it would be up to the local industry to carry out such assessment of compliance costing.

Subsequently the present study has been focused on compliance costing of discharges directly into the marine environment. Nature of Field Monitoring The present study included considerable field monitoring and the generation of new quantitative data on the levels and loads of relevant pollutants at discharge points as identified above. This field monitoring was focused on the waste waters and effluents themselves, rather than on all the various environmental sectors such as biota, and sediments which may be exposed to such discharges. This ensured the best possible level of information in terms of scientific reliability within the limitations of the resources and time available for this study. Range of Potential Marine Contaminants Investigated The relevant Directives are applicable and make references to general classes of chemicals as well as to a wide range of specific named chemicals. The present


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study took into consideration a list of specific chemicals and water quality parameters which, the light of experience, may be most relevant to the local environmental and industrial context, as well as to the UE water quality Directives , compliance with which is being assessed. Relevant Sectors In general, the provisions of the relevant Directives apply to specific types of industrial plants or centers of activities which may produce or in any way handle specific chemicals or groups of chemicals. For the purpose of the present study, and in the light of the above definitions of discharge points and sources, the following sectors were considered:

• Energy Production • Waste water Marine Discharges

from Sewers or Sewage Treatment Plants

• Freshwater Production • Shipyards • Fishfarming • Marinas • Fuel Terminals

1.4 Approaches Adopted and Investigations Undertaken

1.4.1 Review of Archived Data

With the assistance of personnel from the Pollution Control Co-ordinating Unit of the Environment Protection Department, relevant archived data was reviewed with the aim of assessing and appraising the sources and discharges as identified above, as well as to obtain the necessary information as per terms of reference. 1.4.2 Interviews with Industries

Initial attempts to identify any archived data on industries having direct marine discharges proved to be unsuccessful. Neither the Planning Authority, nor governmental departments (such as the EPD, COS, and others) have any reliable data which could be used as a basis to comply a detailed inventory of direct marine


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discharges of waste water effluents. Therefore, the work team had to comply such an inventory from scratch. The methodology adopted for such compilation initially involved the mailing of letters of inquires to a large number of industries, followed by the holding of interviews with those industries which could potentially have such marine discharges. In each case, information on the quantity and quality of discharged effluents was collated and wherever possible verified. 1.4.3 Field Monitoring The study generated a significant amount of original quantitative data on the quality of effluents discharged into the marine environment, through a field monitoring programme involving the sampling and analysis of both undiluted waste waters from land-based point sources of discharges, as well as water samples from inshore areas. 1.4.4 Consultations Consultations were held with a range of Governmental and Industrial entities that have a particular interest in the provisions of the relevant Directives. A full list of such entities may be found in Annex 1 to this report. 1.5 Work Team The work team on this study consisted of the following:

Professor Victor Axiak Team Leader Mr. Joe Callus, B.Sc.(Hons), M.Sc. (PCCU) Study Liaison Officer Ms Prassede Grech, B.Sc., M.Sc. Ms Carmen Delia M.A. Cost Estimation Element and

Economical Aspects Dr. George Peplow Chemical Analysis Professor Alfred J Vella Dr. Franco Romani Dr. Pablo Andechaga


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Dr. Paolo Pucci Ms. Lisa Pace, B.Sc. M.Sc. Research Assistants Ms. Paola Bonanno, B.Sc. M.Sc. Ms. Michelle Sammut, B.Sc. M.Sc. Mr. Anthony Zammit, B.Sc. Ms. Charmaine Vassallo Ms. Ramona Scerri Ms. Marija Axiak Mr. Carmelo Galea Laboratory Officers: Monitoring Mr. Andrew Scicluna

1.6 Structure of the Report The report starts with a summary of its findings and main conclusions. The first part reviews the current Council Directives relevant to the present study and their various provisions. Then it presents a synoptic view of the current local administrative structures and controls, which in some way have a bearing on marine discharges. The methodologies followed in the field monitoring undertaken for the purpose of the present study, as well as the resultant data are presented in Chapter 4. Chapter 5 describes the general approach followed in assessing the impact of compliance on the various identified sectors. The results of such an assessment for respective sectors are then presented in Chapters 6 to 13. The last part of the study is divided into three chapters. Chapter 14 gives the current economic background and presents predictions on likely future economic developments which are relevant to the study. In the light of the findings of the study, Chapter 15 identifies the requirements of an authorization system for marine discharges as well as the duties and responsibilities of the Competent Authority. The study is concluded by a presentation of the main findings regarding impact of compliance, as well as on the required time frame for implementation (Chapter 16). Detailed information on various issues raised during the report is presented in the accompanying annexes.


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2. EU ENVIRONMENTAL LEGISLATION AND DIRECTIVES RELEVANT TO THIS STUDY.

The aim of this Chapter is to briefly review the relevant provisions of the Council Directives, which fall within the framework of the present study. This is done only after a general introduction is made to the EU environmental legislation followed by a synopsis of EU Directives dealing with water quality in particular. Wherever possible, the level of compliance with the relevant directives by the Member States has been assessed, and the various problems of implementation in such States, have been identified.

2.1 EU Environmental Legislation

2.1.1 Introduction This brief review of the development of EU environmental legislation is mainly based on Debeuckelaere and Casshman (1998). EU environmental legislation is crucial in the sense that member states of the EU often rely heavily on Community laws to shape their own national legislation. EU environmental legislation, which can take the form of regulations, Directives or decisions, is currently based on Article 130s or 100a of the Treaty. These articles are reinforced by the Environmental Action Programmes.

2.1.2 Legislative Acts The following legislative measures can be adopted to reinforce the Treaty provisions and the Environmental Programmes: regulations, Directives, decisions, recommendations and opinions (Article 189). A regulation is meant for general application; it is binding in its entirety and is directly applicable in the member states. When a regulation has been adopted, the member states do not have to take national measures to implement the act. Thus a regulation has to be more detailed of necessity than a Directive. Once a regulation is published in the Official Journal of the Communities (OJ), it comes into force on the date specified in the text, or on the 20th day following publication. A Directive, on the other hand, is binding as to the result to be achieved in each member state to which it is addressed. However, the member states have the choice


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of both form and method of implementing the Directive in their national legislation. In practice this means that a Directive is a legal measure, which requires action from the member states to translate it in their respective national legislation. At the end of a Directive there is always a specific article, or articles, stipulating the date by which the member states should implement the measures to which the Directive refers. A decision is binding in its entirety upon those to whom it is addressed. It is notified to the member states concerned, bi]t its publication in the OJ is not obligatory. Regulations, Directives and decisions contain in their preamble the legal basis of the measure, the reasons for its adoption, the origin of the proposal, and the required opinions. Recommendations and opinions arc not legally binding. In matters of environmental protection most Community measures are in the form of Directives. This means that the member states have to take necessary steps to incorporate them into their national legislation within the time limit stipulated in the text of each Directive. The member states are also required to communicate the measures taken to implement the Directives. In practice, however, there is often a delay in implementation, and sometimes the member states are not able to communicate adopted measures on time; the Commission, as guardian of the Treaty, has to ensure that the member states do implement the Directives. Community environmental legislation is divided into these sectors: water, air, noise, chemicals, nature conservation, waste and general measures.

2.1.3 Review of EU Environmental Legislation dealing with Water Quality Community legislation to protect and improve the aquatic environment can be subdivided into:

(a) legislation to protect water according to its specific use; (b) legislation relating to specific industries; (c) legislation relating to the source of pollution, and (d) legislation to protect the aquatic environment from pollution by certain

dangerous substances. The Community is party to several international conventions on the protection of the marine environment and the Rhine. It should be noted that in this capacity the Community has mixed competence along with the member states.


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In 1996 the Commission presented a communication to the Council and Parliament in which it discussed the possibility of a major new piece of Community water legislation - a Water Quality Framework Directive - which is a more comprehen-sive and integrated approach to water management (Com (96) 59 final, 21 February 1996). Such a holistic Framework Directive has now been proposed but still needs to be ratified. 2.1.3.1 Legislation to protect Water according to its Specific Use Community legislation to protect water according to its specific use covers: the quality of surface water intended for the abstraction of drinking water

(Council Directive 75/440, OT 1975, L 194/26) supplemented by a Directive on the methods of measurement and frequencies of sampling and analysis of such water (Council Directive 79/869, OJ 1979, L 271/44);

the quality of bathing water (Council Directive 76/160, OJ 1976, L 31/1); the quality of fresh waters needing protection or improvement in order to

support fish life (Council Directive 78/659, OT 1978, L 222/1); the quality required of shellfish waters (Council Directive 79/923, OJ 1979,

L 281/47); the quality of water intended for human consumption (Council Directive

80/778, OJ 1980, L 229/11). These Directives contain provisions relating to the achievement of required water quality. They impose an obligation on member states to take necessary measures to that end, and (in most cases) require them to establish plans or programmes to ensure that the required quality standards are met within the time limit set in each Directive. 2.1.3.2 Legislation Relating to Specific Industries Community legislation on the reduction of water pollution from specific industries is limited to the titanium dioxide industry (Council Directive 78/176, OJ 1978, L 54/19; Council Directive 82/883, OJ 1982, L 378/1). A Directive to harmonise national programmes for the reduction of titanium dioxide pollution (Council Directive 89/428, OJ 1989, L 201/56) was annulled by the ECJ (see pp.408-409) before it was re-adopted under a new legal basis (Council Directive 92/112/EEC, OT 1992, L 409/ 11). 2.1.3.3 Legislation Relating to the Source of Pollution


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Community legislation on the protection of water, which deals specifically with the source of pollution, in fact comprises a Directive on the protection of waters against pollution caused by nitrates from agricultural sources (Council Directive 91/676, OJ 1991, L 375/1), and a Directive concerning urban waste water treatment (Council Directive 91/271, OJ 1991, L 135/40). The Nitrates Directive requires member states to identify nitrate-polluted waters and to take a range of measures to limit agricultural nitrate use in the catchments. The Urban Waste Water Directive will be reviewed in more detail below, since it is one of the Directives which is being considered in this study on compliance and impact. 2.1.3.4 Legislation To Protect The Aquatic Environment From Pollution

By Certain Dangerous Substances. Community legislation to protect the aquatic environment from pollution by certain dangerous substances comprises the Framework Directive which is the main subject of the present study.

2.2 Council Directive 76/464/EEC On Pollution Caused By Certain Dangerous Substances Discharged Into The Aquatic Environment Of The Community 2.2.1 Provisions of the Directive Council Directive 76/464 on pollution caused by certain dangerous substances discharged into the aquatic environment of the Community (OJ 1976, L 129/23) is the Framework Directive on measures to protect the aquatic environment from pollution by substances listed in the annex to the Directive. This annex contains List I substances that are particularly dangerous because of their toxicity, persistence and bio-accumulation, and List II substances, which are less dangerous but which have a deleterious effect on the aquatic environment. The ultimate aim is to eliminate the discharges of List I substances and to reduce those from List II.

List I


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1. Organohalogen compounds

2. Organophosphorus compounds

3. Organotin compounds

4. Carcinogenic teragenic and mutagenic substances

5. Mercury and its compounds

6. Cadmium and its compounds.

7. Persistent mineral oils and hydrocarbons 8. Persistent synthetic substances which interfere with water

use LIST II

1. List I substances not regulated

2. Other metals and metalloids

3. Other Biocides

4. Substances which affect taste/smell

5. Toxic organic Silicon compounds

6. Inorganic phosphorus compounds

7. Non-persistent mineral oils

8. Fluorides and cyanides

9. Substances which affect the oxygen balance (ammonia,

nitrites)

Article 6 of the Directive provides that for List I substances the Commission has to establish Community limit values. Member states can also opt for emission standards instead of limit values, provided that these standards are based on quality objectives. Therefore a Member State has two possible approaches to adopt. It can either set a uniform standard, based on the best available techniques (BAT) for all discharges or for discharges from the same sector, including the determination of a concentration level or the maximum allowable amount per day; or a Member State can adjust the standards in order to keep a quality target (Environmental Quality Standards) in a particular geographic location. To date Community limit values and quality objectives have been set for 18 substances, in a number of daughter Directives: Council Directive 82/176/EEC on limit values and quality objectives for

mercury discharges by the chlor-alkali electrolysis industry. This


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Directive covers industrial plants where alkali chlorides are electrolyzed by means of mercury cells and which discharge mercury or its compounds.

Council Directive 83/513/EEC on limit values and quality objectives for

cadmium discharges. Council Directive 84/156/EEC on limit values and quality objectives for

mercury discharges by sectors other than the chlor-alkali electrolysis industry.

Council Directive 84/491/EEC on limit values and quality objectives of

hexachlorocyclohexane. Council Directive 86/280/EEC on limit values and quality objectives for

discharges of certain dangerous substances included in List I of the Annex to Directive 76/464/EEC. These substances include: carbon tetrachloride, DDT and pentachlorophenol.

Council Directive 88/464/EEC amending Annex II to Directive

86/280EEC on limit values and quality objectives for discharges of certain dangerous substances included in List I of the Annex to Directive 76/464/EEC. This Directive includes control over discharges of aldrin, dieldrin, endrin, isodrin, hexachlorobenzene, hexachlorobutadiene and chloroform.

Council Directive 90/415/EEC amending Annex II to Directive

86/280/EEC on limit values and quality objectives for discharges of certain dangerous substances included in List I of the Annex to Directive 76/464/EEC. This Directive covers discharges from industrial plants handling 1,2- dichloroethane, tricholoroethylene, perchloroethylene and trichlorobenzene

According to the Annex to the Directive List I, substances for which no Community limit values or quality objectives have so far been established have to be considered as List II substances. Also, member states have to establish programmes (Article 7) to reduce pollution of the aquatic environment caused by List II substances. Most EU countries have favoured the uniform emission standards or limit values approach, whereas the U.K. has adopted the approach of applying environmental quality standards.


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Emission Limit Values for List 1are to be determined by Council as proposed by Commission, on the basis of toxicity, persistence and bioaccumulation of the respective contaminant. Where appropriate ELVs are to be established by sector and type of product. Emission Standards shall determine:

Maximum Allowable Concentration i.e. in a discharge (in case of dilution, to divide limit value by Dilution Factor); Maximum Quantity (i.e. Concentration over a period of time). This may be expressed in terms of unit of weight of pollutant per unit of production.

The Emission Standards to be set must not exceed Emission Limit Values as set by the Commission. Environmental Quality Objectives (EQO) are to be established by Commission for List 1. These are determined on basis of toxicity, persistence bioaccumulation and sediment accumulation. ELVs are not to be applicable in cases where EQO are being met and maintained. Such cases are to be reported to the Council by the Commission. For List II compounds, a Member State must establish programmes of reduction by:

o Requiring authorization of discharges based on Emission Standards.

o Such ELVs are to be based on EQOs according to Council Directives.

o Including specific provisions controlling composition and use of chemicals taking into account latest economically feasible technical developments.

o Including deadlines for implementation

Results of such programmes are to be reported to the Commission. Furthermore the Commission expects that programmes of different member states are to be sufficiently co-ordinated. The Directive provides for the setting up an authorization system responsible for the following duties:


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o To lay down emission standards into inland surface waters, territorial waters and sewers.

o To grant authorization for existing discharges for limited periods

under given conditions (as determined by Commission).

o To review authorizations every 4 years.

o To take appropriate steps to stop contraventions (check what sort of powers of implementation and policing will this authority have).

o To draw up an inventory of discharges (which may contain list 1

chemicals).

o Establish a national monitoring network.

o Report to Commission about its work

2.2.2 Implementation of Directive by Member States In an evaluation of this Directive undertaken in 1994 (Club de Bruxelles, 1994) it was noted that the pace at which the Daughter Directives are adopted is extremely slow because the Council of Ministers must vote unanimously in each case. Member States were found to be too slow in transmitting their pollution reduction programmes for a number of hazardous substances. In addition, one particular Daughter Directive (90/415/EEC), which was supposed to be transposed into national law in 1992, had actually been transposed by only 7 Member States by 1994. The Commission had to start infringement procedures against the rest of the Member States. Generally speaking, industry was more willing to comply with the quality targets (Environmental Quality Standards), which do not require the use of more “ ecologically protective” technologies, than to adapt their activities to the best available technology, which implies high costs that some could not afford. Many from the Industrial Sector were reported to feel that the quality targets should have been determined on the basis of scientific assessment of risks and of environmental impact of discharges of substances in water. Unfortunately such a basis of scientific information was (and still is) not present to the desired extent.


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2.3 Council Directive 91/271/EEC Concerning Urban Waste Water Treatment

2.3.1 Provisions of Directive This Directive requires member states to meet certain standards for urban waste water collecting systems and for the treatment of urban waste water. These obligations are to be met in several stages, depending on various factors such as the sensitivity of receiving waters, and the population equivalent of the urban area under consideration. This Directive gives specific guidelines for the level of wastewater treatment which would be required for different population equivalents and receiving waters. Urban wastewater includes domestic and industrial wastewater. Generally, this Directive states that wastewater entering a collecting system must be subject to secondary treatment before being discharged at sea. Sensitive are to be identified, based mainly on risk of eutrophication. More stringent treatment is required for discharges to such sensitive areas. Primary treatment may be sufficient for less sensitive areas provided that the water quality is not adversely affected (i.e. there is good water exchange and subsequently there are no actual or potential risks of eutrophication or oxygen depletion). The deadlines to implement the provisions of this Directive extend from 1998 to 2005.

By 1993 to identify sensitive areas. Such areas to be reviewed every four years.

By 1998: to have collecting systems for cities of more than 10000 inhabitants (or

population equivalents), which are discharging in sensitive areas. to have more stringent treatment for discharges into sensitive areas by

cities of more than 10000 (with some exceptions in case of minimum loads of N and P)

to eliminate discharge of sludge into the sea. By 2000:


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to have collecting systems for cities of more than 15000 to have secondary treatment plants for cities of more than 15000 biodegradable industrial waste waters (agro-food), which are discharged

directly into the sea, (not through sewers, and thus subjected to treatment) must require authorization, in respect of all discharges from plants representing 4000 p.e. or more (equivalent to 240,000g BOD5 /day).

By 2005: to have collecting systems for cities of between 2000-15000 to have secondary treatment plants for cities of between 10000 and

15000 urban waste entering collecting systems to be treated prior to discharge,

from cities less than 10000

Monitoring programmes are to be established according to Annex I for discharges from waste treatment plants into the marine environment and into sensitive areas, in order to confirm compliance with limit values and quality objectives stipulated in Annex I (Table 1 and 2, for BOD,COD, total suspended solids, total P and total N). 2.3.2 Assessment of Implementation of Directive by Member States In an evaluation of this Directive undertaken in 1994 (Club de Bruxelles, 1994) it was noted that by that time, only one Member State had presented to the Commission their implementation programme to determine sensitive areas. This should have been done by 1991. This evaluation also noted that while the Directive will offer Industry with new opportunities for companies specializing in wastewater treatment plants, several industrialists were perceiving a number of drawbacks. First of all, there were the costs involved in adapting to the liquid waste management process, and the discharge limits were too strict. Next, because of risks, public or private water treatment companies were reluctant to treat waste water from hospitals, industrial laundering facilities and laboratories, for example. Lastly, the industrialists were claiming that the Directive would cause a sharp increase in solid discharges, as well as in the treatment of solid sludge. Article 17 of this Directive provides for the Commission to periodically review and assess its implementation by the various Member States as well as to publish the resultant findings. The publication of the first report (1998) of the Commission was in fact delayed by four years due to the delays attributable to a number of Member States in providing the necessary information to the Commission.


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By 1998 (five years after the stipulated deadline) Italy had not yet transposed the Directive, while other Member States had done so by varying delays. Transposition was assessed to be not in conformity with the provisions of the Directive, in the case of Greece and Austria. Regarding the identification of sensitive areas, as required by the Directive, the Commission was verifying whether the identification criteria have been respected in a number of Member States. France had by then (1998) not identified sensitive areas in its overseas departments, while Austria considered that there is no sensitive area in its territory. Greece and Italy had still to formally identify such areas. The same report also makes several references to the fact that the reporting obligations as stipulated by the Directive are being infringed or are not being fulfilled in a satisfactory manner, by a number of Member States. Regarding the discharge of disposal of treatment sludge, Spain, Ireland and the United Kingdom, were discharging such sludge in surface waters in 1998, while Spain was planning to continue this type of discharge beyond 1998, which is contrary to the provisions of the Directive. 2.4 The Water Framework Directive: European Parliament and Council Directive establishing a framework for Community action in the field of water policy This Water Framework Directive has been adopted by the Commission on the 14th September 2000. When it comes into force, this umbrella Directive will greatly affect the implementation of other water related Directives, such as that of CD 76/464/EEC and 91/271/EEC, which are the main Directives relevant to the present study. Indeed the Dangerous Substances Directive 76/464/EEC and its daughter Directives will, in terms of their provisions, be integrated into the Water Framework Directive, allowing them to repealed in a phased approach. The Framework Directive will complement and complete other key pieces of water-related legislation: in particular, the 1991 directives on urban waste water treatment. All transposition and implementation considerations concerning these Directives should therefore take account of this fact. The Water Framework Directive aims at establishing a management structure for a European water policy, with the following main objectives:


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• expanding the scope of water protection to all waters, surface waters and groundwater;

• achieving "good status" for all waters by a certain deadline; • water management based on river basins; • "combined approach" of emission limit values and quality standards; • getting the prices right: charges for water and waste water reflecting the

true costs; • getting the citizen involved more closely; and • streamlining legislation.

As seen from the above account, the Water Framework Directive, embraces a wide range of issues related to water quality. In the following account, reference is made only to those issues relevant to the Council Directives, compliance to which is being assessed in the present study. While the main focus of this Directive is the management of river basins, it aims to protect all waters, i.e. groundwater and surface waters, freshwaters and coastal waters. In the case of Malta, there are no permanent rivers, and most freshwater streams are not of a permanent nature (tending to dry up during the summer months). Nonetheless, the provisions of this Directive will have an impact on the management of such ‘inland waters’, and will require local environmental authorities to formulate legislation and control of such bodies of water. It is beyond the scope of the present study to deal with such issues. Whilst vastly expanding the scope of water protection, it will encompass and extend the effectiveness of a number of existing directives. The key obligations under the Water Framework Directive are of particular importance where river basins are shared between Member States or between Member States and Third Countries. 2.4.1 Relevant Provisions of the Water Framework Directive. The various relevant provisions and main obligations of Member States as stipulated in this Directive are listed below (from European Commission, DG ENV, 1999) Planning Identify river basins and assign them to individual river basin districts. Two

or more river basins may be combined into one river basin district.


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Establish competent authorities, using either existing structures or creating new ones, and establish administrative arrangements to ensure that the directive is implemented effectively within River Basin Districts.

Elaborate operational objectives for "good status" for the surface waters in

the river basin based on Annex V. Good status has to be based on ecological, physico-chemical and hydro morphological criteria.

Identify waters used for the abstraction of drinking water and establish

environmental quality standards for these waters; identify other protected areas (e.g. those under EU nature protection legislation).

Based on an analysis of impact of human activity on the waters within the

river basin, based on the monitoring of waters as well as based on the operational objectives of "good status", establish a River Basin Management Plan for each River Basin District, including programmes of measures for achieving the specified objectives.

Monitoring For each River Basin District, undertake:

o an analysis of its characteristics; o a review of the impact of human activity on the status of waters; and o an economic analysis of water use.

Establish programmes for monitoring the status of:

o surface waters, and o protected areas.

Regulation • Implement programme of measures included in River Basin Management Plans. • Take action to prevent or reduce the impact of accidental pollution incidents. • Establish controls over abstraction of fresh surface water and groundwater, as well as discharges and other activities with significant adverse impacts on status of waters. • Establish an effective system of penalties for non-compliance with national provisions adopted pursuant to the Directive.


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• Ensure that the price charged for services related to water (e.g. drinking water supply, waste water disposal and treatment) reflects the true economic costs of providing the service. Consultation and Reporting Allow the public to have access to draft River Basin Management Plans, consult

the public on the content of the draft Plans, and publish the final Plans. Consult interested parties on additional interim measures to combat pollution of

waters. Send copies of plans and programmes (including River Basin Management

Plans) to Commission and the European Environment Agency (Art. 20). Report to the Commission on:

competent authorities; exemptions from the provisions on cost recovery; plans and programmes; penalties under national law; measures taken to comply with the Directive; and transposition, with texts of the main provisions of national law adopted in the field covered by the Directive.

2.4.2 Development of Principles at EU Level The Directive provides for a number of principles to be defined at the EU level and which member States will then be expected to comply with.

• Definition of ecoregions and types of water bodies, including reference conditions;

• Definition of European chemical quality standards for surface waters (priority substances),

• classification and mapping of chemical quality; • Development of criteria for significant anthropogenic impacts; • Methodology for assessing and quantifying diffuse sources of pollution; • Development of measures for emission control of priority substances; • Methodology for economic analysis and long-term forecasts; • Development of criteria for designating heavily modified bodies of water and

for the definition of maximum ecological potential.


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2.4.3 The Water Framework Directive and Implementation of CD 76/464/EEC.

As pointed out above, the Dangerous Substances Directive 76/464/EEC and its daughter Directives will, in terms of their provisions, be integrated into the Water Framework Directive, allowing them to repealed in a phased approach. The transposition and implementation considerations concerning this Directives should therefore take account of this fact. The purpose of the present section is to identify some examples to show how this forthcoming Directive will influence the implementation of the Directives relevant to the present study.

a) The whole of Directive 76/464/EEC will be repealed after 13 years of the date of entry into force of the Water Framework Directive (Art. 21(2) of the WFD).

b) Art. 6 of Directive 76/464/EEC (which authorizes

the Council to lay down limit values for emission standards for various dangerous substances) will be repealed on the date of entry into force of the Water Framework Directive (Art. 21(2) of the WFD).

c) The list of priority substances adopted under the

Water Framework Directive will replace the list of substances set out in the Commission Communication to the Council of 22 June 1982 (Art. 21(3a) of the WFD). Articles 10 and 16 of the Water Framework Directive sets out the requirements for controlling priority substances.

d) As indicated in Section 4.2 the Water Framework Directive provides for a

number of principles to be defined at the EU level and which member States will then be expected to comply with. The transposition of the Dangerous Substances Directive 76/464/EEC, its daughter Directives and of the Urban Wastewater Treatment Directive 91/271/EEC into the national legislation of Malta, will need to take in full consideration such defined principles.

e) In tackling water pollution from substances

prescribed under this directive and its daughter directives, Candidate Countries should use the ‘‘combined approach’’ set out in the Water Framework Directive. That is to say, rather than basing emission standards on emission limit values or on water quality objective, both approaches should be used to mutually reinforce each other. In


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any particular situation, the more rigorous approach will apply.

f) Member States may apply the principles and

procedures laid down in the Water Framework Directive for the purpose of implementing Article 7 of the Dangerous Substances Directive (which obliges Member States to establish programmes to reduce water pollution caused by List II substances) (Art. 21(3b) of the WFD).

g) The Commission within two years of the date of

entry into force of the Water Framework Directive will review the Daughter Directives under Directive 76/464/EEC. The provisions for controlling water pollution by substances on the priority list under the Water Framework Directive will need to be revised. The review will consider the repeal of controls for all other substances (Art. 16(8) of the WFD).

h) As a general rule, Candidate Countries should be

able to use the programmes under Directive 76/464/EEC to fulfill the relevant parts of the requirements of the Water Framework Directive (for example the provisions of Art. 11 relating to the adoption of a programme of measures to achieve the environmental objectives set out in Article 4 of the WFD; and Article 13 which contains provisions relating to river basin management plans).

To assist in the smooth transition from Directive 76/464/EEC to the proposed Water Framework Directive, the European Commission will be carrying out a study on the ‘‘Assessment of programmes under Article 7 of Council Directive 76/464/EEC. The study should start in December 1999 with a final report in early 2001. Furthermore, the Framework Directive will complement and complete other key pieces of water-related legislation: in particular, the 1991 directives on urban waste water treatment. The construction of waste water treatment plants with more stringent objectives than required by the Urban Waste Water Treatment Directive 91/271/EEC, may be required by this Framework Directive.

References


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Club de Bruxelles. 1994. Environment: New Policies of the European Union. Study written by the Club de Bruxelles for the conference organized in February 1994. 143pp plus annexes. Debeuckelaere, K., and Cashman L. 1998. EU Environmental Legislation. In Environmental Management in Practice Volume 1. Instruments for Environmental Management. Edited by Nath, B.; Hens, L., Compton, P., and Devuyst, D., UNESCO, Routledge, London and New York. 404-420. European Commission. 1998. Implementation of Council Directive 91/271/EEC of 21 May 1991 concerning urban waste water treatment, as amended by Commission Directive 98/15/EC of 27 February 1998. European Commission (DG ENV). 1999. Handbook on the implementation of the EC Environmental Legislation.


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3. WATER QUALITY, MARINE AND SEWER DISCHARGES: CURRENT LOCAL LEGISLATION AND PROVISIONS.

The purpose of the present Chapter is to review the more relevant national legislation concerning marine discharges and the existing provisions and administrative structures for their implementation, as well as any difficulties in their enforcement. Thorough reviews of such legislation and provisions may be found in the National Programme for the Adoption of the Acquis (NPAA), published by the Ministry of Foreign Affaires, 11 February 2000, as well as in other texts. A Working Group on Water Quality (WGWQ) to discuss and advice on the transposition, adoption and implementation of such EU legislation has reviewed the current status in Malta vis-à-vis our capabilities for implementation. The following account is mainly based on the findings of such a working group. The Maltese environmental legislation stems from the obligations set out in the Environment Protection Act (Act V of 1991). This framework Act addresses all or most scenarios of potential environmental concerns, including those dealing with water quality. This Act operates both by direct provisions and by further specific Regulations. Though it has served as an enabling Act for a number of important Regulations, many provisions of this Act have never come into force. In fact, it is widely recognized that this Act needs to be reviewed and upgraded. The Ministry for the Environment is currently working on such an upgrading exercise. 3.1 Transposition of EU Water Quality Directives related to

Discharges of Waste waters. The relevant EU directives concerning discharges of waste waters into the environment, lay down the conditions and limits for such discharges both as released into sewers and public collecting systems, as well as when released into the marine environment. The manner in which the EU directives will be covered by local legislation, has already been agreed upon and identified by the National Plan for the Implementation of the Acquis. An authorisation system is already in place within the Drainage Department (DD) to control discharges of industrial waste waters into the sewers. Such an authorization system, more specifically: the Discharge Permit Unit, has been provided for under Legal Notice 8/93 dealing with Sewer Discharge Control

Compliance Impact of CD 76/464 EEC and other Water Quality Directives 25

Regulations, established under the Environment Protection Act of 1991 and the Water Services Corporation Act of 1991. This LN will be reviewed later on in this Chapter. Collection and treatment of urban wastewater falls under the responsibility of the DD. Presently, 10% of such wastewater is treated in conformity with provisions of the Urban Wastewater Directive (CD 91/271EEC). The resultant sludge from water treatment is discharged at sea. A Sewerage Master Plan has been drawn up and is currently being implemented by the Sewage Plan Implementation Unit. It is planned that all waste waters will be treated in conformity with EU Directives by 2005. Treatment sludge will no longer be discharged at sea. Specific provisions for the control of discharges of waste waters into the marine environment both directly from industrial establishments, as well as from the public sewers (even after treatment) are still lacking. Part IV of the Environment Protection Act of 1991 provides for control of such discharges into the sea, but it still needs to be brought in force. The authorization system to control such marine discharges will be set up within the Environment Protection Department, through the new regulations as stipulated in a new Legal Notice on Environmental Protection (Discharges to the Marine Environment). 3.2 Wastewater Discharges into Public Sewers: LN 8/93 The NPAA points out that there are no current Maltese industries which discharge mercury, cadmium or most other relevant substances directly into the marine environment as a result of industrial activities listed in the Dangerous Substances Directive (76/464/EEC) and its daughter Directives. On the other hand, the discharges of industrial effluents into the public sewers (which is also covered by CD 76/464/EEC) are controlled by Legal Notice 8/93 dealing with Sewer Discharge Control Regulations, established under the Environment Protection Act of 1991 and the Water Services Corporation Act of 1991. This LN 8/93 established a specific authorization system for discharges of industrial waste waters into the sewers on the basis of limit values for a number of parameters. The WGWQ pointed out that these limit values are in line with those required by Dangerous Substances Directive and its daughter Directives. Indeed in some cases such as Boron, the limits are more stringent.


LN 8/93 is intended to cover only industrial discharges (as defined by its Article 2). Any of its present articles, which may inadvertently refer to non-industrial discharges, will be amended soon.

In fact the Drainage Department (DD) is in the process of revising such LN, to bring it in line with the Directive 76/464/EEC. In its present format, LN8/93 provides for the issue of Public Sewer Discharge permits which are renewed annually.

Council Directive 76/464/EEC requires that the authorization system draws up of an inventory of discharges. At present, chemical analysis and monitoring of discharges into sewers is being carried out by the industry itself. This data is regularly presented to the DD, at the time of permit renewal (annually). This data is confidential (as stipulated in the LN) and could not be made available for the purpose of the present study. The Directive requires the establishing of a national monitoring network. The DD has currently no monitoring programme and very limited data on the chemical composition and characteristics of effluents, including untreated sewage, as discharged into the marine environment. The only data available is that reviewed by COWIconsult in 1992, and more recently by a LIFE project (1999). 3.3 Degree of Present Compliance with LN 8/93. Council Directive 76/464/EEC requires that the authorization system takes appropriate steps to stop contraventions. The administrative setup for such enforcement of discharges into sewers is already available at the DD. However, during various discussions held with personnel from the DD itself, the Federation of Industries (FOI) as well as with the Malta Development Corporation (MDC), it became evident that while this LN has been in force for a number of years, the degree of compliance of the local industry is low. It is worth to try to identify the reasons, which eventually led to this undesirable situation. Such assessment would be useful in ensuring that any future transposition of Council Directives dealing with water quality will be fully implemented and enforced as required by the Commission. First of all, while the LN8/93 was drafted with the intention of fulfilling most (if not all) the provisions of the Council Directives relevant to discharges into sewers, it seems that the Sectors which had to eventually comply with its provisions were


never consulted during the drafting stage. For example both MDC and FOI confirmed that they were never involved in any way in the formulation of this LN. Furthermore, both agreed that Industry should be consulted at the earliest possible stage, whenever new legislation and regulations regarding its operations are being planned. Apparently, little efforts were made in the past to educate or sensitize the relevant industrial concerns about the need for such regulations and about the benefits which are derived from compliance. Subsequently (except possibly in the case of hotel and recreational establishments, with respect to the discharge of oils and fats into sewers), many small industries perceived (many still do) such regulations as simply additional burdens which they had to overcome or defeat, or to carry unwillingly. It is encouraging to note the present administration of the DD will be addressing this problem and is now planning to organize a comprehensive education and sensitization campaign amongst the local industry to raise awareness re obligations for sewer discharges. MDC explained how enforcement of such LN was difficult to comply with especially by the micro industries (such as garages). This is especially due to the stringent monitoring requirements which are not always relevant to a particular industrial premises and which often prove to be excessively costly. Furthermore, there may be up to 12 trade premises of medium size which are not operating in full compliance with this LN. On the other hand, MDC indicated a number of leading local companies, which are successfully complying with such requirements of sewer discharges. FOI started to receive negative reports from its members regarding such an authorization system for sewer discharges, from the very start. The main criticism was that no technical advice and assistance was forthcoming regarding the means of treatment of the liquid wastes. Furthermore, the costs involved with the required chemical monitoring was often excessive, and the method of disposal of any resultant sludge often proved to be problematic. During discussions with the DD, it was confirmed that no court cases, fines or withdrawal of permits have resulted as yet, from the LN8/93. At this stage, all sides involved (both the DD and industry) tactically understand that many of the local industrialists still cannot adhere to the set limits and conditions of discharges. Therefore the granting of permits for discharges at present is being carried out on the understanding that the relevant trade premises will, through voluntary agreement come into line with the LN in due course. However it is understood that this ‘interim period of grace’ will end by 2002, when all traded premises have to fall in line with the provisions of the LN (as would be amended by then).


According to FOI, such a Voluntary Agreement was actually signed by a very limited number of local industries. In fact, in an effort to improve the current situation , a new Voluntary Agreement (or Undertaking) has been recently redrafted and mutually agreed upon by DD and FOI. This aims at providing industry with the possibility to recognize and implement its legal obligations under LN8/93. The proposed agreement will allow for a case-by case approach in the determination of the duration of such a period of grace. However the objective of such a Voluntary Undertaking is to ensure that such legal obligations will be fully satisfied by the year 2003 at the latest. In our opinion, the feasibility of such a deadline being met will depend very much on:

(a) the level of technical advice which is forthcoming, especially to the micro-industries, regarding the manner in which they will have to implement a liquid effluent management plan (which includes monitoring and reporting obligations) as well as how to treat their waste waters to ensure compliance;

(b) the availability of external funds which would cover the additional costs

for such compliance;

(c) the manner in which the sludge which may result from the wastewater treatment will be effectively disposed off in a cost-effective manner by the relevant competent authority.

3.4 Cost of Compliance on part of Industry for Sewer Discharges

There is an urgent need to assess the cost of compliance on part of the industry for the provisions of discharges into sewers as provided by the amended LN8/93 as eventually required by the relevant EU Directives. As explained in Section 1.2. the present study focused mainly on compliance costing of discharges directly into the marine environment. It will not be able to deal in detail with compliance costing on the part of industry for discharges into sewers. Such assessment of compliance costs would require more detailed information on quality of present discharges into sewers. No exercise has ever been made on the part of Industry (e.g. FOI, MDC etc) to assess the cost associated with compliance to EU Directives relevant to discharges of waste waters in the sewers. Evidently, it would ultimately be up to the industry


itself to cover such costs. Nonetheless, such costs would be significantly high, and may well represent a significant impact on the local industry due to EU accession. It is unwise to expect that industry, especially the micro-industries, to be able to carry the burden of such additional costs by the year 2003, without adequate guidance and advice on part of the Government, through its relevant departments and/or MDC and with the full cooperation of FOI. The possibility of common liquid waste treatment plants for the local micro-industries, was discussed with MDC and FOI. It was agreed in principle, that this would ensure a more cost-effective approach to solve the problem of liquid wastes. However, due to the wide range of industries present in a particular estate, and subsequently, to the wide range of chemical characteristics of the resultant liquid wastes generated, a common treatment plant may be difficult to operate. On the other hand, MDC may be able to consider ways and means of facilitating joint ventures for the operation of such common treatment plants. MDC is offering financial incentives in the form of soft loans in order to encourage local industries to improve on their environmental performance. However it was pointed out that such loans are not meant to ensure compliance with the existing environmental regulations, but rather to go beyond such obligations. 3.5 Special Considerations for SMEs Environmental legislation is often perceived as either not completely applicable to, or indeed an excessive burden on small and medium-sized enterprises (SMEs). This is even more so for the so-called micro-industries. According to the Commission Recommendation 96/280/EC, an SME is an enterprise with less than 250 employees and turnover smaller than 40 million Euros, for a balance sheet smaller than 27 million Euros. Under this definition, most of the industrial concerns in Malta may be defined as SMEs. Currently, in the European Union, there are two opposing policy directions and views regarding SMEs and the environment (ECOTEC, 2000). The first considers SMEs as an important engine for economic growth and employments. Therefore, it is argued that environmental compliance costs to be carried by SMEs should be lower than normal, and that there should be a simplification and improvement of the administrative and regulatory procedures


which are applicable to their regard. In fact, following Council Decision 97/15/EC, environmental legislation was considered as requiring simplification to decrease the perceived burden on SMEs. In hindsight, lighter administrative and legislative burdens on SMEs could clearly lead to a lowering of environmental standards and performances in such companies. In fact, the second view and school of thought, see SMEs as important contributors to environmental pollution and that environmental requirements and legislative provisions should be related to the nature and magnitude of environmental pollution and not to the size of an enterprise. A recent report submitted to the European Commission (ECOTEC, 2000) found that while relatively little is known about the contribution of SMEs to pollution and waste in the EU, it is clear that this may be significant and probably around 50%. The same report found that there are few specific allowances made for SMEs in terms of environmental legislation in the EU Member States. Most Member States apply the same requirements on all companies. In view of the fact that most industrial enterprises in Malta fall under the category of SMEs and in the light of the above findings, we are of the opinion that in the transposition of EU environmental legislation (including those related to wastewater discharges into sewers and/or into the marine environment) the same provisions should be required for all companies irrespective of size. It is often stated that when an SME improves its environmental performance in terms of use and reuse of resources, this often brings in increased economy and decrease production costs. For example, the Austrian AITF study of 1996 indicated that EMAS (Environmental Management and Auditing System) implementation actually brought net savings after only 14 months on average, mainly through the implementation of improved practices. Having said this, one has to note that smaller SMEs still have difficulty with meeting the requirements of regulations, having very limited resources, particularly in terms of time and money. This will be even more so with regard to wastewater treatment and management prior to discharge into sewers or into the marine environment. The main barriers for SMEs, in terms of compliance and in terms of making environmental improvements in general, have been highlighted by the ECOTEC Report (2000) as follows: �lack of time/staff resources;


�lack of financial resources (for investments); �lack of understanding of environmental problems and risks; �the lack of understanding of the potential benefits of environmental

improvements; �economic short termism (i.e. quick payback on investments); �lack of expertise/confidence; �lack of access to appropriate information (e.g. through IT); �the view of environmental activity as peripheral to the core business; and �initiative fatigue/overload (related to lack of staff resources).

In its position paper on environmental strategy for Maltese industry in view of EU membership, the FOI (FOI, 2000) has again identified the main problems that local SMEs may encounter in fulfilling their environmental obligations. One recurrent problem as identified by FOI (which has also been identified in Section 3.2, above), was that of lack of advice and guidelines as to how micro-industries may comply with the required environmental standards. Evidently, the over-riding problem is that of costs. FOI believes that the environmental investments needed to meet the EU Acquis are, to a very large extent, investments which Malta would have found necessary to make, independent of the Enlargement process. Furthermore, the EU will ensure that environmental costs are internalized through, the appropriate use of economic instruments and the gradual elimination of subsidies incompatible with sustainable development. FOI noted that while Malta will have to mobilize the necessary resources for the implementation of the EU Directives, Community assistance could play a catalytic role in accelerating actions. 3.6 Control of Wastewater Discharges into the Marine Environment As indicated in Section 3.1, specific provisions for the control of discharges of waste waters into the marine environment both directly from industrial establishments, as well as from the public sewers (even after treatment) are still lacking. Part IV of the Environment Protection Act of 1991 provides for control of such discharges into the sea, but it still needs to be brought in force. The authorization system to control such marine discharges will be set up within the Environment Protection Department, through the new regulations as stipulated in a new Legal Notice on Environmental Protection (Discharges to the Marine Environment). A draft format for such LN has been made available for the purpose of the present study. It provides for maximum permissible limit values (Annex 1) which would be in conformity with the requirements of the various EU water


quality Directives covering marine discharges, including the Urban Wastewater Directive ( 91/271/EEC) and the Dangerous Substances Directive (76/464/EEC). The present study on the impact of compliance, dealt mostly with direct marine discharges as stipulated in Chapter 1. Our assessment on compliance and impact on the various industrial sectors, was based on the limit values and provisions which are likely to be included in this new LN. The authorisation system for the control of marine discharges will need to fulfill all provisions of the relevant EU Directives. These include: To lay down emission standards into the marine environment; To identify sensitive and less sensitive coastal areas for the purpose of

marine discharges; To grant authorization for marine discharges for limited periods under given

conditions (as determined by Commission). To review authorizations every 4 years; To take appropriate steps to stop contraventions; To draw up an inventory of discharges; To establish a national monitoring network; To report to the Commission about its work.

Furthermore, this authorization system will have to control through action plans and other management tools, illegal and accidental discharges into the marine environment, as well as land-based discharges from diffuse sources. References

ECOTEC, 2000 Report on SMEs and the Environment. Report for the European Commission, Directorate General Environment. 63pp + annexes. Malta Federation of Industry, 2000. FOI Position Paper: An Environmental Strategy for Maltese Industry in view of EU Membership. 68pp. Ministry of Foreign Affairs, 2000. Environment and Quality of Life IN National Programme for the Adoption of the Acquis. Draft. pp136-148. Working Group on Water Quality Directives. 2000. Report prepared by the Working Group on Water Quality to Discuss and Advise on the Transposition,Adoption and Implementation of the E.E. Environmental Acquis. Water Quality Directives Chapters 44 to 62. Prassede Grech, Rapporteur.28pp.


4. MONITORING PROGRAMME

4.1 Introduction The present study included considerable field monitoring and the generation of new quantitative data on the levels and loads of relevant pollutants at discharge points as identified above. This field monitoring was focused on the wastewaters and effluents themselves, rather than on the various environmental sectors such as biota, water column and sediments which may be exposed to such discharges. This ensured the best possible level of information in terms of scientific reliability within the limitations of the resources and time available for this study. 4.2 Stations Monitored and Sampling Protocol A total of thirty stations were sampled over the period 3rd July until the 10th July 2000. Many stations were sampled on two or three consecutive days. All samples were either of surface waters, or of undiluted effluents as emitted through the discharge culvert or pipe. Dry-dock waters were collected from a bottom drainage culvert in one of the dry-docks of Malta Drydocks Lt., while the dock was dry. The dock was occupied by a ship and normal dock operations were being carried out during the time of sampling. The same dock was sampled on two consecutive days. Samples from the MD Tanker Cleaning Facility (Rinella) were collected on two consecutive days from the outflow of the oil separator. Samples from Marsa Menqa, were collected 1 m away from the discharge point of the Waste Oils Company Ltd. (Marsa). There was no evident discharge of effluents during sampling. In fact this company is still not fully operational. Samples from Marsa Quay 1, were collected from the immediate vicinity of the discharge point of effluents originating from Vernon Foods Ltd. Samples from the RO plants, were collected undiluted immediately from the opening of the main outlets of each respective plant.


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Unless otherwise stated (in the tabulated results) samples from fish farms were collected in the immediate vicinity of floating cages at sea. Samples from the various marinas, were collected from the quay, or pontoon which is located approximately in the middle of each respective marina. Samples from Xghajra (Wied Ghammieq) outfall, were collected from the main reservoir immediately before the lifting pumps pass these waste waters into the pipe leading to the sea. Samples from the Cumnija outfall, were collected from a manhole immediately prior to discharge into the sea. Samples from Ras il-Hobs outfall and from the Comino Pig Farm, were collected by boat from within 1-2 m away from the discharge point. All samples were collected under the direct supervision of the present consultant or that of Ms Prassede Grech (PCCU). Water samples were stored in plastic containers (rinsed and acid washed prior use) at –22oC until use. 4.3 Range of Potential Marine Contaminants Investigated The relevant Directives are applicable and make references to general classes of chemicals as well as to a wide range of specific named chemicals. The present study took into consideration a list of specific chemicals and water quality parameters which, the light of experience, may be most relevant to the local environmental and industrial context, as well as to the EU water quality Directives , compliance with which is being assess. Samples were subsequently analyzed for a number of chemicals which were chosen in consultation with the PCCU. The full list of chemicals analyzed for, as well as the analytical laboratories involved, are presented in Table 4.1. The full analytical reports from Prof. Alfred Vella, Dr. George Peplow and Dott. Paolo Pucci are appended in ANNEX 2 to this report. These reports indicate the analytical protocols followed by each respective laboratory.


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For analysis carried out in the Department of Biology, analytical protocols for nutrients were those from Parsons et al. (1984), while for total phosphorus, protocol ISO 6878/1 1986 (E) was used. 4.3 Results All results obtained from these analyses are tabulated in Table 4.2. In the case of a number of chemicals (especially organics), all samples analyzed, showed levels which were below the analytical detection limit. These results have not been included in Table 4.2. The results of analysis from a specific sector, are presented again in the particular chapter which reviews that respective sector. References Parsons T. R., Maita Y., and Lalli C. M. 1984. A manual of chemical and biological methods for seawater analysis. Pergamon Press. Oxford.


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5. Assessing Impact of Compliance by Sector

The main objective of the present study is to assess the impact of compliance to EU water quality Directives (as identified in previous sections) of wastewater discharges into the marine environment. The present chapter will review the general methodology adopted for such an assessment. 5.1 Point versus Diffuse Source of Marine Discharges

While the main focus of the study was point and discrete sources of land-based discharges, the EU Directives also cover diffuse sources of pollution. These diffuse land-based (or indeed, even ship-based) sources of pollution are more difficult to identify and therefore to quantify their significance. Furthermore, such diffuse sources may not be easily controlled by setting emission standards, but rather by controlling the nature of the activities themselves and by stipulating codes of practice which may be required by registration obligations rather than by discharge permits. These diffuse sources of diffusion have only been hereby assessed in a preliminary manner depending on the availability of data, and time available to conclude the present study. 5.2 Sectors and Elements of Assessment In general, the provisions of the relevant Directives apply to specific types of industrial plants or centers of activities which may produce or in any way handle specific chemicals or groups of chemicals. For the purpose of the present study, the following sectors were considered:

o Fish Farming o Fuel Terminals o Freshwater Production o Electricity Generation o Shipyards

Compliance Impact of CD 76/464 EEC and other water quality Directives

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o Hotels and Recreation o Wastewater Discharges through public sewer outfalls o Marinas o Offshore bunkering o Land-based activities leading to diffuse sources of discharges

In assessing the compliance impact on each sector, the following elements were included:

I. An appraisal on sources (discharges) of pollution to the marine environment, based on type and quantity per sector.

II. An evaluation of the current load of effluents from sources, and thus predict the expected trends over the next decade.

III. An identification per sector of those requirements for provisions/measures that have to be taken into account in order to abide by the provisions relating to limitation and monitoring.

IV. Wherever possible, an estimation of the ’order of magnitude’ of costs that would be incurred to ensure compliance per sector.

V. An assessment of the operational implications and proposal of alternative scenarios for compliance specifying within a specified time frame required for compliance per sector.

5.3 Assessment Methods Adopted The full range of assessment methods and tools employed in the present study included:

a) Review of Archived Data b) Interviews with Industries c) Field Monitoring

Initial attempts to identify any archived data on industries having direct marine discharges proved to be unsuccessful. Neither the Planning Authority, nor governmental departments (such as the EPD, COS, and others) have any reliable data which could be used as a basis to comply a detailed inventory of direct marine


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discharges of wastewater effluents. Therefore, the work team had to comply such an inventory from scratch. 5.3.1 Interviews with Industries

The methodology adopted for such compilation initially involved the mailing of letters of inquires to a large number of industries, followed by the holding of interviews with those industries which could potentially have such marine discharges. In each case, information on the quantity and quality of discharged effluents was collated and wherever possible verified. For this purpose a questionnaire was designed and used during these interviews. A copy of such questionnaire may be found in ANNEX 3. A complete list of private and public entities which have been interviewed for the purpose of the present report is found in ANNEX 4. Interviews were conducted during the period July-September 2000. In many cases, the interviews were conducted with the full cooperation and assistance of the industries involved. Nonetheless a number f problems have been encountered during this exercise, some of which will be outlined below. In very few cases, the company initially reported that it does not discharge any wastewaters into the sea. Subsequently on further investigations, such marine discharges were confirmed. In other cases, the claim made by some companies that they were not discharging wastewaters into the sea, was confirmed. In one particular case, the company stated that it does not have direct marine discharges. However repeated investigations indicated that such discharges did occur but on an irregular basis, possibly due to some malfunction of the plant. In some cases, multiple interviews had to be held with a specific industrial concern, due to the degree of complexity involved. For example, over 15 different interviews were held with various sectors and divisions of the Malta Drydocks, resulting in a massive body of information regarding the nature of marine discharges from this major industrial complex.


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Very often, a particular industrial concern would be unable to provide the necessary quantitative data during or immediately after the interview. This was the main reason why the completion of the report had to be delayed. Furthermore there were cases, where data which was promised to us never reached us. Furthermore, many industries were unaware of their potential obligations for the treatment of their own liquid wastes prior to their discharge into the marine environment. In many cases, the work team itself had to identify potential treatment options and the associated technical details, before it could arrive at a reasonable assessment of the compliance cost involved. 5.3.2 Field Monitoring The study generated a significant amount of original quantitative data on the quality of effluents discharged into the marine environment, through a field monitoring programme involving the sampling and analysis of both undiluted wastewaters from land-based point sources of discharges, as well as water samples from inshore areas. The methodology of sampling, the sampling stations as well as the results of this field monitoring have been presented in Chapter 4. The data collected from this field monitoring was made use of in assessing the significance of pollution loads from the various sectors. 5.4 Presentation of Results In order to economize on space, as well as to present the results of our assessment and evaluation in a coherent manner, it was decided to make such presentation in the following manner: For each sector, all the elements of our assessment are being included in a given chapter. Therefore, for each sector, there will be an appraisal on sources (discharges) of pollution to the marine environment, based on type and quantity per sector; an identification of those provisions/measures required for compliance; an estimation of the ’order of magnitude’ of costs that would be incurred to ensure compliance, followed by the required time frame for compliance.


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For record purposes, and for the purpose of the present study, each investigated discharge point was given a code number. Furthermore, the approximate location of such discharge points are being indicated in a map of the Maltese Islands included in this report (ANNEX 3). 5.5 Quality of Data The reliability of our assessment of impact of compliance, including the ‘order of magnitude’ costs involved, will evidently depend very much on the accuracy of the information supplied to the present consultant and to his working team. In this respect, it is worth to make the following observations: 5.5.1 Data on Discharged Wastewaters

In our estimation of volumes and rates of discharges if wastewaters, we had to depend on the semi-quantitative data as supplied by the industrial complex being investigated. In most cases, it was evident that such data was quite an approximation. In fact almost none of the discharge points were equipped with flow meters. In our assessment of the type of contaminants which may be found in a specific discharge, we took into consideration the type of industrial activities and operations which gave rise to the generation of the wastewaters, as well as the type and quantities of chemicals used for such operations. In many cases, the company was able to provide us with official Material Safety Data sheets for all such chemicals. Furthermore, we made use of any available archived data on the quality of waters in the vicinity of the given discharge. Only in very few cases, did the company in question carry out any chemical monitoring of constituents in its discharged wastewaters. 5.5.2 Costings of Treatment Plants

The estimation of the capital costs which may be involved in the treatment of wastewaters proved to be problematic. It became quite evident during the initial stages of our study, that no detailed information was available in published literature on the costs of specific treatment plants. In fact, in many cases, we contact a number of manufacturers of water treatment plants, asking them for an ‘estimated’ quotation for a specific (but unnamed) company, indicating the expected rates of input, expected qualities and quantities


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of contaminants to be treated as well as the required threshold discharge limits to be reached through treatment. In general, very few water treatment manufacturers cared to answer back. When they did so they either gave a vague answer regarding the expected capital and running costs, or they indicated that such costs would be estimated only after a feasibility study would be carried out. Attempts to ask a local sales representative (Pantalesco Ltd.,) for a number of important foreign wastewater treatment plants, also failed to provide us with the required data, in time. It is evident that you cannot get ‘ready’ prices for treatment plants which you may get ‘off the shelf’. In establishing the costs of such water treatment, the respective company would have to undertake a detailed analysis of the wastewater produced and of a wide range of operational conditions and parameters. Very often the required treatment plant would have to be specifically designed within the operational constraints and limitations of the particular company. Only then may a reliable estimate of the relevant costs be known. In spite of such problems, ‘order of magnitude’ estimates were possible, through the assistance and cooperation of local companies which already have installed some type of treatment plants for their waste waters. Such companies included: ST Microelectronic (Malta) Ltd., and Oiltanking (Malta) Ltd. In this respect the assistance provided by the respective company managers, is gratefully acknowledged. In making use of this type of information on costs of already installed treatment plants, due allowance was made to depreciation and inflation rates, as well as to likely technological advances. In addition, advice was provided by a number of experts in the field of water treatment including those from the Ben-Gurion University of the Negev, Israel; EEC (USA) Environmental Equipment Consulting and Production Incorporation; Sanitherm Engineering (USA) Inc., and others. 5.6 Required Time Frame for Compliance


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In determining the compliance costs, very often it was possible to take two case scenarios: the best and the worst-case scenario. Full details will be provided for such scenarios in the individual sections on the various companies investigated. In each case, the time frame for compliance has been estimated in terms of the number of years required for implementation of the relevant compliance programme, which may be required, assuming that the necessary administrative decisions have been already taken and that the necessary financial and other resources would have been made already available. Therefore, no allowance is being made for undue delays in compliance-related policy and decision making by the respective authorities or companies, as well as for any difficulties, which may arise to allocate the necessary funds and other resources. It is not within the competence of the present author or his collaborators to be able to make such assessments. 5.7 Confidentiality of Data Presented in this Report All the data which refers to named companies is to be treated as strictly confidential and to be made use of only for the purpose of the present study as per its terms of reference. No such data which refers to named companies must be published. This was often a condition made by the companies themselves, during interviews held with their top management. As such this condition will need to be fully respected by the Ministry for the Environment to whom this report is being submitted. If the need arises, the present authors are willing to resubmit for publication a synoptic version of this report, omitting references to named companies.


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6. IMPACT OF COMPLIANCE: FISH FARMING SECTOR

6.1 General Background The development and characteristics of fish farming in Malta were recently reviewed by Schembri et al. (1999). The industry was launched in a sustained manner in 1988 when the National Aquaculture Centre was established within the Ministry of Agriculture and Fisheries to promote the industry of aquaculture in the Maltese Islands by providing expert advice, research and monitoring services and a link to foreign investments. This was rapidly followed by private investment in the sector and the first private commercial marine-based farm was established in Malta in 1991. Over the past decade, this industry rapidly developed so that by 1998 the total annual production of finfish for the export market from local aquaculture amounted to 2000 tons, as compared to 300 tons in 1992. In addition, approximately 100 tons per year are consumed locally. The total licensed production potential of existing farms is estimated at 3000 metric tons per year and is expected to be achieved by the year 2000 (Meilak, 1996). Marine-based farms account for 98% of the total aquaculture production in the country. In 1998, four companies operated five offshore units on an intensive commercial scale for the fattening of two marine finfish species: sea bass (Dicentrarchus labrax) and sea bream (Sparus aurata). Two small marine units were located in inshore sheltered areas and where used as nursery sites (Table 6.1) . In 1998, land-based coastal aquaculture consisted of a small scale ongrowing farm with a production of 50 tons of sea bream annually and two hatcheries for sea bream, one within the National Aquaculture Centre, with a total production of 2.5 million fry per year. By 2000, Aquaculture Development Ltd., and Sealand Ltd. did not remain operational. Hatchery production does not meet the local demand for fry, therefore, a high proportion of the required juveniles are imported from overseas hatcheries, mainly from Europe. A large-scale hatchery producing about 5 million fry per year is planned in Gozo, however, to date this has not proceeded beyond the planning stage.


Since summer of 2000, a major tuna penning project was started by Azzopardi Fisheries Ltd (Agius, 1999). This consists in a tuna farm, to be located off Is-Sikka l-Bajda. Initially, the farm will have a production capacity of ca.300 tonnes, rising to a maximum production of ca.500 tonnes over a period of a few years. There will be a maximum of 8 cages, each with a diameter of 40m, holding a net which would be 15m deep. The cages will be constructed of HDPE piping. There are no land-based facilities associated with these operations. A converted 550 tonne vessel that for the most part will be moored at least 2 miles offshore will service the tuna-cages. This service ship will occasionally sail to the farm site (approx. 20 days per year). A smaller craft will be used for daily transport between the service ship and the farm. Frozen bait-fish that will be imported in bulk for the purpose tuna feeding and stored in deep-freeze on board the tender vessel. At the end of the season the nets will be hauled on board the servicing ship by winches and cleaned by a standard, commercially available, net washing machine installed aboard the ship. This operation will be carried out about four miles offshore and the wash water will be discharged untreated. All nets will be treated with Netseal. This is a silicate-based (organic polymer) compound whose main function is to add strength to the net and to protect it against Ultraviolet light rays. It does not contain any metallic compounds such as copper or any other anti-foulant material. The following compliance assessment will be based on interviews made with the National Aquaculture Centre, Pisculture Marine de Malte (P2M), Malta Mariculture Ltd. and Fish and Fish Ltd. The tuna penning project was not in operation and therefore could not be included in the assessment. Nonetheless a brief review of its more likely environmental impacts will also be presented. In the following account, the general environmental impact of present fish farming units will be assessed on the basis of archived data. Subsequently, the impact of compliance for specific fish farming production units will be assessed. 6.2 Present Information on the Environmental Impact of Fish farming in Malta Intensive coastal fish farming can have significant detrimental effects on the marine environment through the generation of particulate and soluble wastes from uneaten


food and from fish wastes. Localised impacts from aquaculture practices are generally observed as: − nutrient enrichment − reduced oxygen levels − accumulation of particulate wastes on the seabed − alteration of benthic habitats. Other impacts of aquaculture on the natural environment are more widespread and difficult to quantify. These include impacts resulting from the use of additives in feeds, pharmaceuticals and antibiotics applied regularly for the treatment of disease, and the use of other chemicals such as anti-fouling coatings on cage nets. The information available from different sources of archived data on the potential impact of present fish farming practices in Malta is reviewed in the following sections. 6.2.1 Water Quality Reports by the National Aquaculture Centre:

1995-1998. Information on the impacts of local aquaculture practices on the marine environment is obtained from environmental monitoring programmes which are implemented at aquaculture sites, as required by the Planning and Design Guidance for Fish farming approved by the Planning Authority in 1994. Such programmes monitor a number of environmental quality parameters for the water column sediments as well as for the benthic environment. On request, the Planning Authority (Environment Management Unit) provided us with the results of water quality reports generated over the period 1995 to 1998 for a number of fish farming coastal sites. The National Aquaculture Centre has issued such reports. Unfortunately, this information is dated and according to the Planning Authority, no monitoring is currently being undertaken (Adrian Mallia, Manager, Environmental Management Unit, communication dated 4th August 2000). This situation is considered by the Planning Authority as unacceptable and the matter is in hand to ensure compliance. According to these results as issued by the National Aquaculture Centre, the impact of the present fish farming units on the water column is minimal. Water quality parameters measured on and in proximity of cage sites conform to levels at control sites. This was generally observed both for sites in semi-enclosed inshore waters and in semi-offshore and offshore sites, indicating that water exchange at local sites is sufficient to prevent build-up of significant pollution levels from aquaculture practices.


Anomalously high levels of pollutants such as faecal bacteria and nutrients measured occasionally in inshore areas (such as Mistra Bay) could be attributed to other sources of pollution, such as climatic factors, the presence of sewage overflows and possible underwater freshwater outlets. No data is available to determine the environmental impacts of land-based farms. Furthermore, little information on sediment quality is currently available. 6.2.2 Life Project: Monitoring Programme: 1997-1998

As a result of a LIFE Project (Environment Protection Department, 1999) a coastal monitoring programme was undertaken by the Environment Protection Department during two 8-week periods: August September 1997; and January-February 1998. The monitoring sites included:

a) 12 sites for sewage b) 30 sites for coastal waters c) 4 sites for ground surface runoff

The coastal sites included the Mistra and Comino fish cage localities. At such sites, occasionally high levels of dissolved nitrates and chlorophyll were recorded. Monitoring next to a discharge point from a land-based fish farming unit at Simar (St. Paul’s Bay) was also undertaken. The discharged effluents were found to carry relatively high nutrient loads (especially nitrites: mean 0.115 mg/L, sd 0.037 mg/L) as well as dissolved phosphates and nitrates) 6.2.3 Coastal water quality Monitoring Programme: 1998-2000 More recently, the present consultant on commission by the Pollution Control Coordinating Unit of the Environment Protection Department, started since 1998, a coastal water quality monitoring programme which includes most of the fish farming sites. The data for such monitoring programme is available in Axiak (1998,1999,2000). This data indicate that for the period 1998-2000, most water quality parameters in the vicinity of fish cages which are located over relatively deep waters and/or which are exposed to significant hydrodynamical diffusion forces, remain within acceptable limits and are not significantly different from similar parameters from control sites. Nonetheless occasional elevated levels of water turbidity (as measured by an in situ transmissometer, in terms of beam attenuation coefficients) and nitrate


levels were reported near the fish cages in the South Comino channel as well as il- Hofriet. For fish farming cages which are located within semi-enclosed bays such as Mistra and St. Paul’s Bay as well as Marsaxlokk, anomalous levels of water turbidity, and dissolved nitrates, and less so, for chlorophyll and phosphates, were more frequent. The more significant impact on water quality was reported for Mistra-Saint Paul’s Bay. For example, within Mistra Bay, the mean levels of dissolved nitrates and chlorophyll (5 surveys over the period 1998-2000), were 5.3 and 2.3 times higher than the same levels in reference sites within Saint Paul’s Bay, which are not under the direct influence of fish farming. Likewise, water turbidity as well as chlorophyll levels near the floating fish cages in Mistra were generally higher than the reference sites within the same locality. 6.2.4 Impact On Benthic Habitats Data on the impacts on benthic communities at marine cage sites have been recently reviewed by Schembri et al. (1999) are available only for Mistra Bay, St. Paul’s Islands and Mellieha bay (P2M sites) and refer to surveys carried out intermittently at the three sites between 1994 and 1996. The three cage sites are located in semi-enclosed areas and in relatively shallow water depths over sea-grass (Posidonia oceanica) meadows. A significant environmental impact was measured at the three sites. The Posidonia meadows have been modified to an extent by the high nutrient input from the cages in the form of fish faeces and leftover food. Sea-grass communities directly beneath the cages were greatly degraded and the seabed consisted of with dead Posidonia matte, anoxic sediment and bacterial mats. The conditions of the sea-grass meadows as measured by their phenological parameters (leaf length, live-to-dead shoot ratio and epiphyte growth) gradually improved with distance from the cages, however, due to the limited survey area, it was not possible to determine the distance at which the Posidonia meadows re-attained a healthy state. Impacts on the benthic communities were particularly acute in Mistra Bay and St. Paul’s Bay (Cassar, 1994). The Posidonia meadows there were in a clear state of regression. This may be related to the shallow water depths in which the cages are sited and to the enclosed nature of the bay. However, the effects of sewage overflows into St. Paul’s Bay were significant and could not be distinguished from the effects of fish-farm wastes, except for the areas directly below the cages. In Mellieha Bay, the observed impacts were less severe. The bare sand below the cages was moderately anoxic and supported a higher biodiversity. The Posidonia


meadows in the survey area were in a generally good state of health except for the area directly below the cages where patches of dead matte were present and a large proportion of the Posidonia shoots were dead. There is no information available for the other marine-based farms. However, given their location in more exposed and deeper waters, impacts on benthic communities are expected to be less severe than those described above. 6.2.5 Environmental Impact: Conclusion There is no evident significant impact of the sea-based fish farming units located in the South Comino Channel or at Hofriet. This is mainly due to the exposure of such sites to good water circulation and dispersive characteristics. For the case of fish cages in Mistra and possibly also Mellieha, In spite of the earlier reports that there was no significant impact on water quality which may be attributed directly to such activities, more recent reports indicate otherwise. Although the data is still fragmentary in nature and quite incomplete, there is evidence that such sites are exposed to occasionally high nutrient loads, and particularly at Mistra and in St. Paul’s Bay, there are indications that this may be leading to a localized increase in productivity. The benthic impacts of the fish cage units situated over shallow waters, eg. Mistra and ST. Paul’s Bay, has been now confirmed and are quite significant. Such changes may not be only attributed to sewage outflows and other land-based activities. It is evident, that in Mistra and St. Paul’s Bay, there are clear indications of long-term impact of fish farming, through occasionally high nutrient loads, and increased productivity, as well as degraded benthos. It could be argued that such undesirable effects may be not be attributed uniquely to the fish farming activities in this locality. But it is now reasonably certain that such activities are making a significant contribution to a general effect on the environment. 6.3 Legislation and Control of Local Fish Farming Schembri et al.. (1999) recently reviewed the various legislations and regulations controlling fish farming activities in Malta. In accordance with the Development Planning Act (1992) and the 1997 amendments to this Act, the establishment of a marine or land-based fish-farm requires full development permission. Furthermore, an Environmental Impact


Assessment (EIA) is required in accordance with the Planning Guidance for Environmental Impact Assessment in Malta of the Planning Authority and the Environment Protection Department. Structure Plan policies on aquaculture AHF 15 and AHF 16, encourage the development of offshore large-scale production units. Small-scale units should preferably be located on the coast within committed areas. The Planning and Design Guidance for Fish farming is the key policy adopted to regulate the development of fish-farming within the Maltese Islands. The Policy Guidance was adopted by the Planning Authority in 1994 and defines the requirements for the development of marine and land based fish-farms as well as for hatcheries. It also provides guidelines on farm management, and includes the protocol for the monitoring programs. Currently, the Guidance is being reviewed and updated. Control of aquaculture operations is the responsibility of several regulatory bodies including: • Planning Authority

− Policy formulation − Processing of applications for development permission − Co-ordination of EIA procedures − Enforcement of conditions within the development permission − Enforcement and management of environmental monitoring programs

• Veterinary Services Department

− Fish health and quality control, in accordance with EU standards. − Importation, use and disposal of chemicals

• Ministry of Agriculture and Fisheries/ National Aquaculture Centre

− Advice and policy development − Licensing fish farm operations − Importation, use and disposal of chemicals − Control of pesticide use

• Environment Protection Department

− Participation in the EIA process − Control of importation, use and disposal of chemicals.

6.4 Assessment of Individual Fish Farming Units


The results of individual investigations and assessments undertaken for respective fish farms are presented here. Synoptic compliance costs and required time frames are presented in Table 6.2 As indicated in Section 5, the time frame for compliance has been estimated in terms of the number of years required for implementation of the relevant compliance programme, which may be required, assuming that the necessary administrative decisions have been already taken and that the necessary financial and other resources would have been made already available. Therefore, no allowance is being made for undue delays in compliance-related policy and decision making by the respective authorities or companies, as well as for any difficulties, which may arise to allocate the necessary funds and other resources. It is not within the competence of the present authors or collaborators to be able to make such assessments. 6.4.1 National Aquaculture Centre (FF1) This Centre, which served a catalytic function for the development of the industry in Malta, currently contains a hatchery, as well as lab facilities, where vaccine potency testing is carried out. It has 24 personnel employed on a FT basis and an annual turnover of Lm180,000 to Lm 200,000. Waste waters are generated mainly from the fish tanks. There is a possibility (which could not be confirmed) that toilet waste is included in these effluents. Waste waters are discharged directly into Marsaxlokk bay in the vicinity of Fort Saint Lucian, at an approximate rate of : 3.2 m3 per minute. The discharged waters are occasionally monitored. No data was made available of any results from such monitoring. Based on a consideration of the nature of operations and activities carried out in this complex, it may be assumed that the discharged waters may contain a number of chemicals including: nutrients, BOD, and traces of antibiotics (oxytetracyclin and flumenquin) and formalin (against parasites), as well as phenoxyethanol (anaesthetic). Small traces of bleach (sodium hypochlorite) may also be found. Future development may include the introduction of other species of the bream family and possibly blue fin tuna. This may involve an increase in the production of waste waters and consequently in the discharge rate up to 5m3/min.


Compliance Provided that the toilet wastes are not included in the discharged effluents, it is unlikely that there will be the need for any additional treatments. If the toilet wastes are currently being discharged into the effluents, then in order to ensure compliance, there would be the need for some infrastructural modifications to connect to the public sewer system. The costs for such works is difficult to estimate, but it may be assumed that this will not be an easy task and that the costs may amount to Lm25,000. In the worst case scenario, if subsequent monitoring data will indicate the need for further treatment (especially with respect to suspended solids) then an estimated capital cost of Lm100,000 my be required for further treatment. Annual running expenses for such treatment will also have to be considered. More regular monitoring of the discharged effluents would be required at an additional cost of approximately Lm2000 per year. 6.4.2 Pisculture Marine de Malte, P2M: (FF2) This company services floating cages at Mistra, Mellieha and St. Paul’s Bay. It also owns a packing plant and a land-based net washing installation at Mistra. The company employs 19 FT and 18 PT personnel. No information was available regarding annual turnover. Waste waters from land-based sources are generated from net washing and from packing plant, at the following rates:

Net Washings: 3-12 m3 per week from land Mistra Packing Plant: 8 m3 per week (discharged through 1m wide pipe, at 6m depth).

No monitoring of the resultant land-based discharged effluents is carried out. Some monitoring data for water and benthic quality near sea cages, is available and has been reviewed in a previous section. Chemicals used by this company include

oxytetracyclin ( 90 kg in 1999). Phenoxyethanol (2 l per year)


Formalin (up to 200 l per year). The discharged waste waters from packing plant are bound to contain substantial amounts of suspended solids, and organics (from fish wastes) as well as possibly some nutrients. Such waters are treated (primary treatment) by passing through trickle filter prior to discharge into sea. Discharged waste waters from net washings are bound to contain elevated levels of suspended solids in excess of the threshold limits likely to be set by the forthcoming LN by EPD to control marine discharges. Compliance The review of available data in Section 6.2 concluded that the water and benthos quality in Mistra and parts of Saint Paul’s Bay under the influence of fish farming operations has deteriorated. As such this area may qualify as a ‘sensitive area’ under the provisions of the EU Directives. It is therefore quite likely that additional water treatment will be required in the case of nutrients and suspended solids being discharged from land-based operations. It is estimated that a capital cost of Lm 20,000 may be required for biological treatment of land-based discharges from this installation, in order to ensure compliance over a time frame of 2 years. Running costs (see Table 6.2) will include monitoring and reporting obligations. 6.4.3 Malta Mariculture Ltd. (FF3) This company services floating cages in Comino Channel. It also owns a packing plant and a land-based net washing installation at Marfa. The company employs 16 FT and 17 PT personnel. No information was available regarding annual turnover. Effluents from land-based sources are generated from net washing (36 m3 per week) and from packing plant. Only waste waters from net washings are directly discharged into the sea on the shoreline. Effluents from the packing plant are discharged into sewers. No monitoring of the resultant land-based discharged effluents is carried out except for flow rates and infrequently, for BOD.


Some monitoring data for water quality near sea cages, is available and has been reviewed in a previous section. No significant effects on nutrient levels, dissolved oxygen, and productivity (Chlorophyll a) was ever detected, except for infrequent cases, where the anomalies could not be directly and necessarily related to the fish farm. No details are available for the chemicals used by this company. However, it may be assumed that these are similar to those for the previous company. Compliance It is quite likely that a settling tank and primary filtration will be required for the net washing effluents being discharged from this complex at Marfa. This may entail an approximate capital cost of Lm10,000 (assuming land is already available) and may be available within a year. Other running costs are presented in Table 6.2 6.4.4 Fish and Fish Ltd. (FF4) This company services 9 floating cages off Hofra iz-Zghira. It owns a packing plant and a net washing installation. IT employs 5 Ft and 10 PT staff. Its turnover may be estimated at Lm0.5 million at current prices (300 tonnes per year production). Land-based waste waters are generated from net washings and packing plant and are discharged directly at sea. IN the packing plant, there is selection of fish (removing deformed ones) followed by weighing. Ice flakes are added and fish are packed into containers. Water is screened to remove fish scales prior to discharge at sea. No confirmed data on rates and volume of such discharged waste waters was available. However, it may be estimated that these would amount to 1080 m3 per year. (Assuming: net washings: 4 m3 per net. 6 nets per year; packing plant: 4m3 per day, during part of the year). Oxytetracyclin, is used infrequently. The working area of the packing room is regularly cleaned with Food Area Degreaser (MSDS available) Some information about the water quality near the fish cages of this company is available. Occasional elevated levels of nitrates and phosphates near cages were reported (approx. 40% higher). Also on infrequent occasions, the oxygen levels in


surface waters near cages were slightly lower than ambient. No effect on water turbidity was ever monitored. Compliance As in the previous company, it is probable that a settling tank will be required to remove suspended solids from net washing waste waters. The capital costs may amount to Lm10,000 if land area is already available. Running costs including monitoring are included in Table 6.2 6.5 Impact of Compliance on Fish Farming Marine discharges from four fish farming sites were assessed. Waste waters from these sites are generated from net washings as well as from packing plants. In the case of the National Aquaculture Centre (NAC) at Marsaxlokk, most of the discharged waste waters are from tank washings. In the latter case, the estimated annual volume of marine discharge is significantly high and may reach 240,000 m3. The other fish farms discharge waste waters at rates varying from 300 to 1000 m3 per year. The significant water quality parameters in such marine discharges which need to be addressed, are suspended solids and possibly nutrient levels, especially in the more ‘sensitive areas’ such as Mistra. The estimated global compliance costs for capital expenditure for this sector may vary from Lm65,000 to Lm150,000 (Table 6.2) These estimates cover the required costs for treatment plants to reduce suspended solids and nutrient levels to compliance levels. Total annual running costs due to compliance may estimated at Lm7,500 to Lm15,000. In addition, an approximate annual sum of Lm8000 will be required for monitoring obligations. References Agius, C. 1999. Azzopardi Fisheries. Tuna Penning Project Proposal Environmental Impact Statement Sikka l-Bajda. November 1999; 34 pp.


Axiak, V. 1998. Monitoring Programme for Coastal Waters.Progress Report: January – July 1998. Environmental Protection Department (Pollution Control and Co-ordinating Unit) and Marine Ecotoxicology Laboratory, Department of Biology (University of Malta). 14 pp Axiak, V. 1999. Monitoring Programme for Coastal Waters.Progress Second Report: December 1998-March 1999. Environmental Protection Department (Pollution Control and Co-ordinating Unit) and Marine Ecotoxicology Laboratory, Department of Biology (University of Malta). 14 pp Axiak, V. 2000. Monitoring Programme for Coastal Waters.Progress Third Report: September 1999. Environmental Protection Department (Pollution Control and Co-ordinating Unit) and Marine Ecotoxicology Laboratory, Department of Biology (University of Malta). 16 pp Cassar, M. 1994. Environmental impact of a marine cage fish farm. Unpublished M.Sc. dissertation. Faculty of Science, University of Malta Environment Protection Department 1999. LIFE Project TCY96/M/06. Unpublished Report. Evaluation of Pollution Risk and Prevention Measures in Malta. 105pp. Meilak, A. (1996) The aquaculture industry in Malta: country profile for 1996. Unpublished report, National Aquaculture Centre, Ministry of Agriculture and Fisheries; 5 pp. Schembri, P.J., Baldacchino, A.E., Camilleri, A., Mallia, A., Rizzo, Y., Schembri, T., Stevens, D.T. and Tanti, C.M. 1999. Living resources, fisheries and agriculture. Report prepared as part of the ‘State of the Environment Report for Malta 1998’ commissioned by the Environment Protection Department, Government of Malta]; Valletta, Malta: Malta Council for Science and Technology; 158 pp.


7. Impact of Compliance: Fuel Terminals 7.1 General Background The industrial sector dealing with fossil fuels is an important factor determining the national economy. Malta imports all its fossil fuel requirements, which may amount to a global volume in excess of 1,000,000 metric tones per year. In 1999, Enemalta’s Petroleum Division imported 900,000 metric tones of petroleum products, 55% of which were fuel oil. This sector has been recently reviewed by Mallia and Fsadni (1999). The dominant use for such imported fuels is for electrical generation Use of fuel for transport has also risen steadily over the past decade, after recovery from the price rises following the second oil shock. The other fuel-consuming sectors have not seen any dramatic changes; fuel for bunkering (diesel) saw a rapid rise over the first four/five years of MOBC but has remained almost steady ever since. 7.2 Environmental Impact of Sector on Water Quality in Malta 7.2.1 Risks of Contamination Axiak et al (1999) had recently reviewed the potential risks of pollution by oil and fossil fuels in Malta. Risks of oil pollution to our marine and coastal environment may arise from:

o Major or moderate accidents involving maritime traffic, including bunkering;

o Moderate to minor incidents of spills resulting from inshore or land-based activities;

o Illegal discharges of ballast waters by maritime traffic; o Operational and minor losses of fuel and diesel oils from small water

craft. o Land-Based Storage and operations dealing with fossil fuels.

Fortunately, no major oil spill has as yet been reported to occur in Maltese territorial waters which could lead to massive stranding of oil on our shores. However, the Central Mediterranean is an area with relatively high maritime traffic and the associated risks of incidents are evidently high.


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According to the latest information obtained by satellite (Petros Pavlakis, Joint Research Centre, personal communication) , the area around Malta and in the Sicilian Straits is one of the most oil polluted regions in the Mediterranean. This is well evident in Figure 7.1. In this area, more than 140 oil slicks were visible from space using radar sensors for 1999. There is evidence to suggest that most of these slicks have been discharged by passing ships. Such discharges of bilge oil in the Mediterranean is illegal. Bunkers are delivered off-shore inside Maltese territorial waters at 5 locations as shown in Figure 7.2. The Malta Maritime Authority controls all bunkering operations. At present, two companies are involved in bunkering, namely: the Mediterranean Offshore Bunkering Company Limited (MOBC) and San Lucian Oil Company Ltd. MOBC services all types of ships, both in harbours and in offshore areas. These include cargo ships, tankers, passenger liners, yachts, catamarans etc. Vessels carrying petroleum products, in a non gas-free condition, are bunkered 12 miles offshore at Hurd’s Bank. The total quantities of oil bunkered in Malta on an annual bases is approximately 400,000 metric tonnes, of which 65% is undertaken offshore. To date, only minor incidents have occurred during bunkering, and these have not resulted in the release of oil. Minor to moderate oil spills have been reported in inshore waters, resulting mostly from land-based operations such as oil storage, or fuel landings. Most fossil fuels are handled within Marsaxlokk and Grand Harbour, where all fuel terminals are located (see Figure 7.2) Minor oil spills have been reported in Marsamxett (March 1998), Grand Harbour (September and October 1997) and in Marsaxlokk, Birzebbugia (Summer, 1998). The estimated amounts of oil spilt in such incidents varied from less than 1 to 4 tonnes. The Pollution Control Co-ordinating Unit played a key role in successfully controlling such incidents. Some of these incidents were related to Enemalta and MOBC storage activities. Operational losses of fuel oils from small water craft, may also constitute a significant and chronic input of oil into the marine environment. This is mostly related to intense boating activities during the summer months.

7.2.2 Levels of pollution of coastal waters by oil and its products. Axiak et al. (1999), recently reviewed levels and trends in oil pollution levels in local coastal waters. In comparing and reviewing reported levels of oil in the environment, it is important to note that different analytical methods often do not yield comparable


59

quantitative data. Therefore, in the account below, trends have been identified only when the available data was produced from the same analytical methods. Using UV spectrofluorimetric analysis, the present consultant has produced a significant amount of data on levels of oil in superficial sediments. Heavily oil contaminated sites are found within the two main harbours, Marsamxett and the Grand Harbour. The highest values of PHCs were recorded in the innermost part of Msida Creek and in the vicinity of the Marsa Power Station. Levels of PHCs in the Msida Yacht Marina are also rather high (approx. 40µg/gDW chrysene equivalents) with respect to the cleaner areas. Negligible levels of PHCs were recorded from St. Peter’s pool. Also, Mellieha Bay can be considered as being mildly polluted (3.6µg/g DW chrysene equivalents). Studies, undertaken between 1987-1993, indicate that the levels of PHC’s (such as diesel, fuels, and oil products) in superficial sediments from several coastal areas show an upward trend. Within the Grand Harbour, PHC levels increased from 5 to 12 times over a period of five years. Development of yacht marinas in Marsamxett may have led to a five-fold increase in oil pollution load in the sediments in Pieta and Msida over this same period. These data indicate that although our coastal waters have not yet been exposed to any massive oil pollution accident, chronic low-level pollution by oil and petroleum products from yachts and boats is becoming increasingly significant (Axiak and Vella, 1996). Moreover, oil that is discharged by maritime traffic often ends up as tar deposits on oil beaches. Though it is common experience that a number of local areas are exposed to such risks of contamination (which may have significant economic relevance) the available data is too limited to enable us to evaluate this type of contamination with any confidence. In trying to establish the levels of contamination risks associated with fuel terminal, the Malta Maritime Authority (Captain David Bugeja, Malta Maritime Authority, written communication dated 25th July 2000) has commissioned monitoring of coastal wasters for oil by Saybolt Laboratories (Malta) Ltd., using IR analytical methods. Results made available to the present consultant for 1999, show that all levels of oil in surface waters are between 0.2 to 1 ppm (mg/l). The highest level was recorded at Enemalta Delimara Power Station discharge point at Hofra iz-Zghira. No trends could be identified through these data. For the purpose of the present study, Prof. Alfred Vella analysed a number of samples collected from surface waters as well as from various discharge points investigated here. The full results have been presented in Chapter 4. The levels of petroleum hydrocarbons as measure using GC with flame ionization detection,


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ranged from 0.2 to 2.6 mg/l. The highest levels were reported for effluents discharged from the Malta Drydocks Tanker Cleaning Facility (2.6 mg/l), and in dockwaters (1.7 mg/l). Surface waters from Pieta Marina also showed relatively high levels (1.3 mg/l), which were comparable to those found in discharged wastewaters from sewage outfalls (1.4 to 1.2 mg/l). 7.2.3 Levels of Oil Pollution: Summary In spite of the different analytical methods employed in the monitoring programmes reviewed above, as well as the different environmental phases analyzed, a number of conclusions may be reached. A number of potential sources of oil pollution have been identified including chronic low level of pollution resulting from small water craft and other sources, to occasional small to medium spills from land-based activities, and finally acute risks of massive pollution resulting from major maritime accidents. The available data indicate that to date, while the risks of massive spills are ever present, it is the chronic low level type of pollution which is most significant. In fact, a significant increase in the levels of oil pollution in superficial sediments from several coastal areas has been identified. Within the Grand Harbour, PHC levels increased from 5 to 12 times over a period of five years. Development of yacht marinas in Marsamxett may have led to a five-fold increase in oil pollution load in the sediments in Pieta and Msida over this same period. Different analytical methods have indicated that the areas which are mostly exposed to the higher levels of oil pollution are located within Grand Harbour, Marsamxett and Marsaxlokk. This is bound to be related to the various fuel handling activities in these areas as identified below and in other Chapters of the present study. 7.3 Assessment of Individual Fuel Terminals The results of individual investigations and assessments undertaken for respective fuel terminals are presented here. Synoptic compliance costs and required time frames are presented in Table 7.1 A total of 8 terminal were investigated, of which 5 were found to have direct marine discharges, while another was assessed to be a potential source of runoff


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water. Two other terminals or coastal fuel=related installations, were found not to have direct marine discharges. 7.3.1 Malta Drydocks Tanker Cleaning Facility (OT1) 7.3.1.1 Fuel Terminal Profile Malta Drydocks operates a slops and ballast water reception facility which provides all the services required to carry out tank cleaning and gas freeing. MARPOL Convention requires such port reception facilities for any port areas containing ship repair yards. They are indispensable to ensure the health and safety of the yard workforce, to protect the property of the ship owners, as well as to protect the marine environment from oily discharges. The Malta reception facility was in fact one of the first to be established within the Mediterranean. The installation employs 20 FT personnel and generates an annual turnover in the region of Lm 500,000. During a Workshop in 1997 (MCST, 1998) it was recognized that there will always be the need for slops and ballast disposal facilities within the Mediterranean, irrespective of legislation requiring vessels to be double skinned or to carry ballast water in segregated or dedicated tanks. The installation handles slops, bilge oils, tank washings and ballast waters at a capacity of anything up to 50000 m3 at any one time, and handling tankers to a maximum of 300,000 tons dwt. Only oils of mineral origin are accepted. The installation also provides equipment and services for cleaning and upgrading of vessels, gas-freeing, nitrogen purging and inerting facilities. Most vessels bound for the MD for any repairs, will often need the services offered by the Rinella installation. In fact over the past three year, an average of 62% of the ships entering the MD for repairs, had to make use of the MDTCF before. Lately, enquires for repairs at MD have been preceded with a request for a safety audit at the MD and a safety and environmental audit at the MDTCF. It is expected that the ship owners will increasingly be reluctant to bring their vessels for repairs at the MD unless there are certified facilities where oils, bilges and other wastewaters resulting from repairs may be legally disposed of. Spent lubricating oils, bilge and other tank washings are also accepted from the MD shipyard, from the Manoel Island yacht yard as well as from private industry.


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Oily waters are received in four settling tanks each of 3000 m3 capacity, where oil gravity separation is initiated. The oily fraction is then transferred into two smaller tanks (capacity: 200 m3 each) were it is heated and the water content reduced to less than 3%. Recovered oil is used to provide energy for plant operations and the rest is sold. The water effluents are passed on for primary water treatment into two gravity (API) separator. The effluents are subsequently discharged on the foreshore through a 24 inch pipeline. The operational features and constraints of the present plant include: a throughput of 500 to 400 m3 per hour (which may be increased to 1500 m3 per hour, but then oil separation becomes very much less efficient); an initial oil content of water/oil mixtures received from ships which may vary from 20% to 100 mg/l; and the limited land area available for plant expansion (approximately 1600m2). Furthermore there are plans to develop Ricasoli Fort into a touristic attraction and subsequently, the plant operations have to be compatible with this new land-use. The oily sludges which accumulate in all settling tanks amount to approximately 250m3 per year. These are disposed of at the Maghtab landfill. These sludges essentially consist of sand (approx. 30%) and rust (approx 50%) coated with oily residues. 7.3.1.2. Quality of Discharged Effluents The treated water which are discharged into the sea outside the Grand Harbour, consist of salt water admixed with oils of mineral origin and contaminated ballast waters. Toilet wastes are not included in the effluents received by the installation. At present, the discharge rates of such effluents range from 400 to 500m3 per hour over the period when the ship is being cleaned. Assuming that approximately 45 vessels use this installation per year, than it may be estimated that the total volume of marine discharges amount to approximately 225,000 m3 annually. Little data is available on the oil content of such effluents but it is expected that this may often exceed 100 mg/l. First analytical tests conducted by the present author (Axiak) have showed that there is a high variability in this oil content even for a single ship cleaning operation, where levels may range from 6 to almost 200 mg/l (mean level being 26 mg/l for 16 samples). Analysis of two samples of wastewaters from this installation carried out in July 2000 for the purpose of the present study has indicated that the levels of petroleum hydrocarbons in the separator tank varied from 0.4 to 2.6 mg/l (using GC as the analytical tool). Furthermore, the levels of heavy metals and of other potential


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contaminants were low. Nitrate levels on the other hand, were found to be relatively high, reaching a maximum of 65 ug N at/l. Evidently, even when the different analytical protocols are taken into account, the above investigations suggest that the levels of PHCs in the wastewaters discharged from this installation vary significantly and in a complex manner with time. However, it is evident that the oil content of such wastewaters generally exceed the 5 mg/l limit. In fact, according to some sources (IMO,1995), primary oil separation by gravity in API separators (as utilized at MDTCF) may generally reduce the oil content to 50 mg/l at best. Directive 76/464/EEC lists mineral oils and hydrocarbons of petroleum origin in Annex 1, List 1 and requires that an emission standard be laid down by the competent authority. The standard to be proposed by the Environment Protection Department and as already required by the Malta Maritime Authority is that of 5 mg/l. Evidently the present discharges wastewaters from MDTCF do not comply with the required limit of oil of 5 mg/l. 7.3.1.3 Levels of petroleum oils in water in the vicinity of the discharge point. In May 1998, the levels of petroleum hydrocarbons in the sea, in the immediate vicinity of the effluent discharge point of the installation (i.e. outside Grand Harbour) were monitored, when the installation was in operation. An oil tanker was serviced by the same facility on the 14th May 1998, with ballast waters being last received on land at 20.00h. These waters were kept in holding tanks until 11.00h of the following day. They were then passed through the oil gravity separator and released into the marine environment through the usual outfall, outside Grand Harbour. 30 minutes after the start of discharge of wastewaters, surface water samples were collected from 7 stations as indicated in Fig. 1. A sample of waste waters was also collected from the gravity separator tank. The oil content of samples was then analysed using UV spectrofluorimetry. The level of PHC in the oil separator tank was estimated to be 59 mg oil/litre (or mg/l), while those in the sea were all well below 5 mg/l.. This data is presented in Figure 7.2.


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Figure 7.2 also shows the spatial distribution of the oil contamination in surface waters in the area monitored. Evidently, this data is not complete and the same type of monitoring needs to be carried out under different climatic conditions. Nonetheless, the results of this single survey indicate that:

i) The oil content of the wastewaters after approx. 15 hours of standing in holding tanks, and after gravity separation was approx. 59 mg/l. This was considerably lower than the reported levels of oil in wastewaters discharged during flow-through operations, when holding tanks are not used.

ii) The oil content in the marine environment rapidly dropped by 94%

within a maximum of 5 m from the shoreline, and to background levels at 100m away from outlet. All marine levels were below the 5mg/l limit.

The surprising drop in the levels of oil at the point of discharge may be explained by:

Adsorption and evaporation of most oil residues from the wastewaters as they pass over almost 30m of rocky shoreline, after being discharged through the main outlet and before they reach the shoreline;


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Rapid diffusion by dispersive currents, once the wastewaters reach

the sea. Sea conditions at time of investigation were moderate with relatively strong winds blowing to the NW.

7.3.1.4 Upgrading the Installation Various possible improvements and potential operational developments were discussed at the MCST Workshop in 1997, with the aim of reducing the oil content of the discharged effluents to the 5mg/l limit. These included the possibility of various primary treatment techniques such as plate separators and skimmers; secondary treatments involving physical and chemical separations such as flocculation and flotation and also tertiary biological treatments. The various advantages and limitations of each option within the operational constraints of the present plant, were discussed. Apparently the currently available technology will not easily reduce the oil levels to 5mg/l for flow rates above 100m3 per hour. Preliminary investigations were made by MD over the period 1993-1996, in order to identify the technology and capital costs required to upgrade the present plant, in order to reach the oil content of the discharged effluents to 5 mg/l. One conservative estimate yielded a capital cost of Lm4.3 million, based on a throughput of 700 m3/h and with an available building space of approximately 1630 m2. However, subsequent enquires with a number of foreign manufacturers of water treatment plants, have indicated that such an estimate may not be reliable. Better oil-water separation would be achieved at slower rates of water input. Alternatively, slow oil separation by gravity may be allowed to occur in large retention lagoons (covering an area of approximately 100,000 m2). However this option is ruled out due to the lack of sufficient space for further development within this installation. Suggestions for the provision of storage space by a floating barge, or land reclamation at Rinella Bay, were made. Coffer damming the area behind the jetty of the plant could also provide a large reservoir for holding ballast water for eventual treatment. However it was agreed that such options were not cost-effective under the present circumstances. Evidently, more technologically advanced water treatments will need to be installed in this facility to ensure compliance to the 5 mg/l limit. These are bound to include secondary treatments involving physical and chemical separation (such as flotation, filtration hydrocyclones, etc…) and the chosen technology has to take


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into account the limited land space available, as well as the high rates of throughput of water to be treated (approx. 500 m3/h). Should such a treatment plant be technologically feasible, then the capital costs involved may well exceed Lm 5 million. 7.3.1.5 MD Tanker Cleaning Facility: Conclusions of Assessment The MD requires a fully functional wastewater reception and tank cleaning facilities. The existing facilities at the MDTCF does not have the required oil-separation plant to reduce the oil content of discharged waters to the required level of 5 mg/l. On the other hand , there is no evidence to suggest that the discharge of oil effluents is leading to significantly high levels of oil in the open sea, and in the vicinity of the present discharge point. The limiting factors in this upgrading process, are the limited space available for further development within the present complex, and the high rates of throughput of waters to be treated. A capital cost of Lm 5 million (or more) may be required for upgrading in order for the installation to come in compliance with the required limits of oil in water. In any case, it is recommended that an on-line oil sensor would be mounted in the discharge flow, and that monitoring of oil levels in the discharged waters and in the sea in the vicinity of the discharge point would be regularly monitored. 7.3.1.6 Potential Options to ensure Compliance In the light of the above, a number of options may be identified to ensure compliance. The advantages and limitations for each option are briefly reviewed in this section. These options are also tabulated below. Table 7.2 Compliance Options for MD Tanker Cleaning Facility

Option Feasibility Estimated cost Time Frame

Upgrading of present WTP to comply with 5ppm limit

still to confirm feasibility Lm 5 million 2 years

Relocation of whole plant feasible Lm 10 to Lm15 million 4 years


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Relocation of part plant feasible Lm 10 million 3 years Upgrading of present WTP to comply with 15 ppm limit feasible Lm2.5 million 1 year Upgrading the present Installation Upgrade the oil-water separation plant, using more advanced oil-separation technologies at a capital cost of Lm 5 million or more. More technical studies are required to establish the feasibility of this option. The required time frame for this option in order to ensure compliance, may be approximately 2 years from the final decision to adopt it.

Relocation of the whole Installation The whole installation may be relocated to another area, such as Kalafrana, next to the Oiltanking Malta Ltd. This would provide the required land space for effective retention lagoons with minimal energy and much less capital and operational costs for the oil-water separation process. However, the capital costs for such a relocation would be huge and may be in the region of Lm 10 million to Lm 15 million, exclusive of the costs of the lagoons and additional equipment required to lower the oil in water content to the required level. One breakdown for such an estimate is presented in ANNEX 6. Furthermore, ideally, the facility should be located close to the MD, arid within the Grand Harbour for the following reasons:

Vessels berthed at MDTCF could easily be shifted to MD even under moderate to rough sea conditions This would not be possible if the vessel~ were to be located at a berth outside Grand Harbour.

Short time duration of ship transfer from MDTCF to MD and sheltered conditions inside Grand Harbour makes possible the shifting of vessels in an otherwise empty (deballasted) condition.

Long time duration of ship transfer from the Freeport to MD and open waters conditions would necessitate that vessels be ballasted for stability and maneuverability thereby increasing the idle time of the vessels for ballasting and deballasting operations and therefore the total repair duration at MD

Ballasted tanks on vessels, even though previously washed and cleaned, which have been filled with water for stability and maneuverability purposes, need to be discharged into reception facilities before berthing


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or docking at MD. This would defeat the relocation of the preent reception facilities outside of Grand Harbour.

Ship movements from MDTCF to MD are carried out during daytime. This would allow ship transfer operations to be carried out when cleaning operations are finished even late in the afternoon. Due to the longer transfer distance from Kalafrana or Freeport to MD, ship transfer operations would have to start at midday at the latest. This would mean an additional day added to the repair period.

MD would loose the advantage of having the only ‘non-safe’ berth inside Grand Harbour if the facilities were to be relocated to an area outside the harbour.

It is evident that this option would require a substantial increase in the present level of subsidies and financial support to the MD. This itself may mean that Malta would require a longer transition period to phase out such subsidies. The required time frame for this option to ensure compliance will probably be approximately 4 years from the final decision to adopt it. Relocation of storage tanks only. The present berth inside Grand Harbour would be retained by MD while the reception facilities and separators would be relocated to the Freeport area. Pipelines passing through a subterranean tunnel would connect the jetty facilities and the tanks. The cost of this option is most likely to be of the same order of magnitude at that of relocating the whole installation, as that of having to construct a subterranean tunnel would offset the cost of not having to build a new berth. The advantages of this option would be: MD retains a ‘non-safe’ berth within the Grand Harbour Ship transfer to MD in adverse weather conditions would still be possible Ship transfer to MD would still be possible late in the day Ship transfer to MD from MDTCF would not be hindered by stability

(balssting) requirements. The disadvantages of such an option would be: Vessels would have to pump against exceedingly high back pressures due to

the length of pipelines (approx. 6 km) Blockage inside pipelines due to the heavily viscous oils usually handled


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Operating costs would increase as personnel would have to be assigned to on-bouard ship operations as well as shore (tank) operations

Maintenance costs would increase as well. Adopting a Higher Emission Standard International obligations as well as environmental protection require the establishment of an emission standard which would safeguard the environmental quality as well as the legitimate use of the marine environment by other users. It was recognized that both globally and at the regional level, no internationally recognized emission standards for oil reception facilities exist. For example, the MARPOL 73/78 Convention leaves it up to the state to establish the required waste management standards. However states are strongly advised to take responsible action within their national programmes to consider such standards along with land-generated wastes. In the setting of such a discharge standard for land-based reception facilities, a number of consideration must be taken into account, including: the characteristics, toxicity and persistence of the constituents of the discharged

effluents from the present plant; the characteristics of the discharge site and receiving environment;

the availability of treatment technologies;

the enforcement of best environmental practice in the light of operational

constraints; the need to establish the analytical means, and sampling protocol for the

measurement of oil content of effluent discharges, and to recommend measures to ensure compliance with the emission standard;

the need to avoid shifting oil pollution from the sea by ships to oil pollution by

land-based sources. This means that, since ships are required to discharge wastewater with a maximum of 15 mg/l of oil, the set standard for land-based reception facilities should not be higher than this level.

Therefore, it may be possible to provide for a higher emission level of 15 mg/l to be applicable to this installation, within the local legislation. This is reasonable to


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accept, in the light of the fact that the present levels of PHC reached at sea in the immediate vicinity of the discharge point are well below the 5mg/l limit. This 15 mg/l limit may possibly be achieved at the discharge point, through primary as well as further secondary treatment of the present effluents. The required additional treatment plants may be located within the existing boundaries of the installation. Furthermore, the resultant wastewaters may be discharged into the sea through a submarine pipe equipped with a diffuser, to ensure a minimum of 5 fold dilution within 1 to 5 metres from the diffuser. The estimated cost for this option may amount to approximately Lm 2.5 millions. The required time frame for this option to ensure compliance to a higher threshold standard for oil, will probably be approximately 1 year from the final decision to adopt it 7.3.2 Oiltanking Malta Ltd (OT2) 7.3.2.1 Company Profile Located in Kalafrana, Oiltanking Malta Ltd. offers warehousing and storage facilities for oil products and products for blending. They may up-grade or down-grade oil products according to client specifications. The mother company Oiltanking Ltd. is the 2nd or 3rd largest independent company in the world, with 58 oil terminals world-wide. This installation became operational in 1992. It may handle gasoline, gas oil, jet fuel, feedstocks, alcohols, heavy fuels as well as crude oil. Its present storage capacity is up to 359,000m3, with tank sizes ranging from 5000 to 35000m3. The company employs 25 FT staff and has an annual turnover of between Lm 3.5 to 4 million. All storage tanks are located within concrete bunded spaces and no oil may seep into the underlying ground or into the sea. 7.3.2.2 Wastewater Generation Water effluents arise from separation from fuel oils. These wastewaters (as well as rain water within the burdened area) are conducted to an horizontal plate coalescer plant for primary treatment and physical separation of oil. This plant has a maximum capacity of 60 m3/h. Wastewaters then pass on to a vertical coalescer


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plant and then to a sand filtration bed, and finally through activated carbon. Prior to discharge into the sea, the wastewaters are monitored on-line for PHC levels. The whole system is shut down automatically if the level of oil exceeds 5 mg/l. Oil sensors are calibrated annually. The annual volume of wastewaters discharged into the sea is approximately 100m3 per year. The rate of discharge greatly fluctuates, depending on the operation and rainfall. Analysis of wastewaters usually show that the level of oil does not exceed 0.6 mg/l. Treatment plants are periodically cleaned through backwashing. Carbon and sand beds are changed after 5-6 years. No cleaning solvents are discharged into the sea. Oily sludges are partly burnt in the boiler house and partly disposed off at Maghtab with the approval of the Environment Protection Department. Over 9 years only approx. 3 tonnes of such sludges were disposed off. This installation is already in full compliance with EU Directive. No additional compliance costs are required (except for discharge permits and reporting obligations to the relevant authorization system). 7.3.3 Mediterranean Offshore Bunkering Company Ltd. (OT3) 7.3.3.1 Company Profile MOBC Ltd., offers land-based and offshore bunkering services. It operates from the Grand Harbour Oil Terminal, which has been refurbished in 1996 and now has a maximum fuel storage capacity of 43,000 m3. It has 7 holding tanks with the following capacities:

36,000 m3 fuel oil 8,000 m3 gas oil 2,000 m3 Light Cycle Oil MOBC Ltd. employs 32 FT staff and 2 on a PT basis. Its annual turnover varies from Lm 15 to Lm 35 million. This depends on a number of market-driven factors. 7.3.3.2 Generation and Treatment of Wastewaters Water effluents arise from separation water from fuel oils. According to the managing director of MOBC :td., 12,000 m3 of fuel oil may produce as much as 10


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m3 of water. This water content varies greatly depending on the particular fuel cargo. Approximately 30 m3 of wastewaters may be discharged every month, into the Grand Harbour, through a shore-based pipe located near the Deep Water Quay 5 and the MMA building. Fuel tanks are equipped with closed water drains at the bottom. Water collects by gravity in these drains, and this is led to an inceptor tank, with a capacity of approximately 60 m3. Oil separated by gravity from here is returned to the oil tanks or burnt as fuel oil for boilers. Water from the inceptor tank is pumped into a VCT separator tank made by AFL industries inc. (U.K.). This is a primary treatment separator equipped with vertical tube coalescing units. It separates oil from water by gravity and can reduce oil content of wastewater down to 10 mg/l, removing oil globules down to 20 micro size. In fact, MOBC Ltd. claims that its water treatment plant may reduce the oily content of the wastewaters down to 5 mg/l. This VTC tank is frequently inspected, and generally is emptied of water every 2 months. It holds approx. 60m3 of effluents to be treated. Therefore approx 30m3 of water are discharged into the Grand Harbour per month. The residence time of water in the VTC tanks is approx. 1 month. This tank is able to process approx 300 gallons per minute. Rainwater collected from general surface of bunds and other areas is collected also in this VTC tank. Manual monitoring is carried out only through visual inspection. MOBC Ltd., claims that this would be enough to ensure that the discharged effluents are clean and below 5ppm of PHC. No on-line monitoring is available though MOBC Ltd., admits that this may be useful. The company is planning an increase in the capacity of its depot by 15000m3. This will entail no modification in the present water effluent treatment plant. However, it may increase the capacity of its present separator tank if external funds would be available. The required increase in capacity of the treatment plant may require a capital cost of approximately Lm40,000 (as estimated by Mr Frank Mifsud, General Manager of MOBC Ltd.)


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No sludges are produced as a result of water treatment, or operation. MOBC Ltd. claims that it operates in full compliance with regulations issued by the Malta Maritime Authority and LN8/93. A water monitoring programme conducted by the Malta Maritime Authority in 1999 shows that the maximum levels of oil in surface waters in the Grand Harbour, in the vicinity of MOBC outfall, was 0.4 ppm.

7.3.3.3 Degree of Compliance and Costs. The MOBC terminal in Grand Harbour, is a well-run plant, and during the site visit, it was evident that good standards of housekeeping are maintained. Furthermore, the company claims that its discharge of oily wastewaters into the Grand Harbour is in full compliance with the 5 mg/l limit. Nonetheless, the planned future expansion in the installation may entail a capital cost of Lm40,000 for the increase in capacity of the water treatment plant, within the next 5 years. Furthermore, it is recommended that an on-line oil monitor would be installed (estimated cost Lm 5000), which would be supported by periodic sampling and analysis of oil in the discharged waters (approximate annual cost: Lm2500). However, we may not confirm that the current treatment of wastewaters is adequate to limit discharges of oil to this level. Though there is evidence to show that MOBC has asked for such specifications for its VTC separator tank, no actual analysis have been carried out on the discharged effluents. Therefore, should a thorough investigation of the oil content of the discharged wastewaters reveal that the 5 mg/l may be exceeded, then there will be the need to upgrade the existing treatment plant. The estimated cost for such upgrading at a maximum throughput of 30 m3/h, may be in the region of Lm 300,000. 7.3.4 Waste Oils Company Ltd. (OT4)

7.3.4.1 Company Profile At present this installation, located in Marsa, is serving both as a depot for fuels, as well as for recycling and treatment of spent oils to turn them into alternative fuels. WAC Ltd., collects spent lubricating oils from garages, industry, marinas, from small vessels as well as from slops and bilge waters from some local ships.


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WAC Ltd., employs a staff of 8 FT. No turnover has been registered so far, since no alternative fuels have been sold, pending permits and approvals from the relevant authorities. However over a period of operation of 6 months, approximately 500m3 of alternative fuel oils were produced, through the treatment of 1000m3 of used oils. 7.3.4.2 Generation and Treatment of Wastewaters Spent oils, slops as well as bilge waters are received in a reservoir (max. capacity 1350 m3). This is dewatered by gravity. The separated water (as well as any rain water from the yard) is passed on to an oil-water separator. The rest of the oil may be further dewatered by heating and the application of a demulsifier (SOT-144 A.. MSDS provided). All waste waters are conducted to an oil/water separator of the coalescer type. This may deal with a maximum throughput of 1.2 m3/min.. From the separator, the water is passed through activated carbon and then discharged at sea. The flow is equipped with an on-line oil sensor which may shut the plant down if the level of oil in water exceeds 5 mg/l. The maximum rate of discharge, once the plant becomes fully operational , is estimated to reach 140m3/day. The amount of sludges produced have been estimated to be 2m3 per year. 7.3.4.3 Chemical Composition of Wastewaters To date, few discharges into the sea were made. Discharges are made into the Marsa Menqa. The Environment Protection Department had recently carried out chemical analysis of the wastewaters which were held in a reservoir prior to discharge. The levels of several metals including lead, zinc, copper and chromium exceeded the threshold limits, while PCBs were always below detection limit. 7.3.4.4 Degree of Compliance The WAC plant is of recent design, well-planned and well managed. The wastewater treatment plant should be capable of reducing the oil content of any discharged wastewaters to less than 5 mg/l and therefore be in compliance with the stipulated limits. There may however be a problem with the elevated levels of heavy metals found in such discharge waters. If such levels are confirmed through further analysis, when the plant is in full operation, then further water treatment would be required to control such heavy metals. The capital costs for such treatment may be in the


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region of Lm 300,000, with annual running costs of Lm 5000. Costs for monitoring the chemical composition of discharged wastewaters may be in the region of Lm 6000 annually. 7.3.5 ENEMALTA Petroleum Division (OT5) 7.3.5.1 Profile and Wastewaters Production The Division is responsible for the procurement and marketing of all petroleum products in the Malta as well as supplies of Aviation Fuels to international customers. The Division also offers storage facilities to third parties for Gas Oil, Jet A-1 and Light Fuel Oil. The Division owns three major fuel installations for storage, transhipment and bunkering. No fuel/oil processing takes place at any of its installations. Its storage facilities and underground installations were originally built for military purposes by the British forces The Division employs 225 FT staff and has generated an annual turnover of Lm 57.3 million in 1998. B’Bugia 31st March Installation. (OT5a) This installation has a maximum storage capacity of 36,400 m3 for Petrol, Jet A1, as well as Diesel Jet fuel is loaded from ship by peer and transferred to intermediate storage at Wied Dalam. This is then led by pipe line to the airport. Petrol/Diesel loaded by ship and mostly distributed for local consumption by bowsers. The main sources of waste water production are: pipeline flushing, rainwater and condensation water. Tanker vessels calling to discharge their product, do so through two pipelines. One of the pipelines is dedicated to diesel while the other is used to discharge Jet A1, leaded petrol and unleaded petrol. It is the practice, and in the case of the second pipeline a necessity, to displace the product in the pipelines with seawater after the receipt of every fuel cargo. The tanker itself, after discharging the fuel, does this flushing operation into the shore cargo tank. All the seawater that ends into the cargo tank is then drained and passed through an oil-water separator before being discharged at sea.


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Approximately 50 m3 of such seawater pipe flushing is generated per loading operation. This volume is discharged into the sea on the shoreline in front of the installation. Approximately 56 loading operations are currently handled annually (possibly to decrease). This will produce an annual volume of discharge into the sea of pipe flushing of 2,800m3. The normal discharge rate for such wastewaters is approximately 0.7 m3/min. Approximately 13,000 m3 of rainwater are collected annually over the operational areas (included bunded spaces) of this installation and these may carry varying amounts of traces of oil products. Condensation water separates out of the fuel product during tank storage. It is estimated that approximately 8 to 10 m3 are produced per year. All waste waters are led to an oil interceptor ( two VTC300 models in parallel), treating waters to a discharge limit of 10 mg/l of oil. No on-line monitoring is carried out. One sample analyzed by Seybolt Laboratory yielded an oil level of 2.5 mg/l. PCCU recently collected some more samples but no results are available as yet. Mr. Philip Borg (the Installation Manager) said that according to the water treatment industry, it is difficult if not impossible for the 5 mg/l limit to be reached by such treatment plants. The capital costs for this treatment plant was 68,500USD in 1994. The current running costs are approximately Lm1000 per year (exclusive of overheads). Solids sludges are not discharged at sea, but at currently being stored temporally until a satisfactory disposal method is indicated by the Environment Protection Department. At this point it is worthwhile to refer to a significant problem of underground oil leakage which may be associated with this installation, at Birzebbugia and which has created great concern to the local residents over the past few years. Petroleum hydrocarbons are known to have been leaked into the rock foundations of the area and these deposits occasionally find their way into the sea. Enemalta has never admitted that its tanks are responsible for this problem. However a tank refurbishing programme is currently underway. An Italian company ECO is monitoring oil underground and will be advising on how to extract it. A report is expected by September 2000. An oil recovery programme is planned for the next 2 years. No details about the costs of this programme are available but there are some plans to recover such costs through a LIFE project. In the meantime, the storage tanks are being treated with SIGMA NOVAGUEARD


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treatment (by the MDD). No leaching of chemicals is expected from such lining. In fact this product is certified as being suitable for contact with liquid foodstuffs, Has Saptan and Ras Hanzir (Corradino) Installations (OT5b and OT5c) These two installations have a maximum storage capacities of 140,000 m3, and 56,000 m3, respectively. No pipe flushing is carried out here, and little or no rainwater runoff is generated, since these installations are located underground. Larger volumes of condensation water are produced from the storage tanks of these installations due to the lower storage temperatures. Approximately 8 to 10 m3 of condensation water may be expected to be generated per loading. Assuming 30 ship operations per year, it may be estimated that the annual volume of such wastewaters generated may amount to 300 m3 . Such wastewaters are discharged at San Lucjan sub-plant after passing through an oil separator tank (equipped with baffles, and less advanced than the VTC oil interceptor). The level of treatment most likely exceeds 10 mg/l. Moreover, in these underground installations, aquifer water percolates and needs to be drained from the tunnels. This is mostly discharged in the Grand Harbour (Ras Hanzir) after passing through an oil separator (similar to that located at San Lucian). The generated volumes and rates of discharges of such wastewaters are unknown. 7.3.5.2 Compliance and Costs Oily wastewaters originating from the various installations reviewed above, will require further water treatment to reach the 5 mg/l emission level as would be required by the LN to be issued by the Environment Protection Department. The B’Bugia installation will be eliminating the need for pipe flushing, by laying down fuel dedicated pipes. A capital sum of Lm120,000 will be spent by 2001 to deal with this problem. This cost is already planned and as such may not be viewed as a cost due to compliance with EU Directives. Furthermore, there is an ENEMALTA commitment that by the year 2010, the whole installation will be closed down. Storage will be transferred to an above-ground location at Has Saptan. PA and Land permits are being sought. This will greatly reduce the volume of liquid wastes produced. However, in the meantime, at least two improved oily water separators will be required, one for the B’Bugia installation and another for the Hal-Saptan/Ras


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Hanzir Installations). In the worst case scenario, three such installations will be required. These separators could be of the advanced type as owned by the Oiltanking (Malta) Ltd., equipped with activated carbon filtration and on-line oil sensor. The estimated capital costs for such compliance will range from Lm800,000 to Lm 1 million. The resultant running costs is difficult to determine, since these will be greatly dependent on the type of technology to be adopted as well as on the location of such plants, which would in turn determine the associated infra-structural (and piping) costs. However an order of magnitude estimate could be Lm20,000 to Lm25,000. Annual monitoring costs may be in the region of Lm5000. The required time frame for compliance may be up to 2 years, depending on the level of infra-structural modifications required for additional water treatment. 7.3.6 Maritime Base (Armed Forces of Malta) (OT6) 7.3.6.1 Relevant Activities and Operations This Maritime Base for the Maritime Squadron of the Armed Forces of Malta is located at Hay Wharf, Marsamxett. Strictly speaking, this is not a fuel installation, and no crude oils or major fuel storage plants are located here. No direct and intentional marine discharges originate from this location. Nonetheless, this base serves as a servicing (as well as fuelling) station for the patrol boats of the Armed Forces and it may be considered as a land-based source of pollution by oil or its products. Furthermore, the amount of rain runoff from this area may be quite significant and as such this may give rise to a ‘diffuse’ source of land-based pollution . It will be briefly reviewed here. One of the potential risks of oil contamination is a fuel barge, which has permission to fuel other boats in the nearby Msida marina. According to bunkering regulations of the Malta Maritime Authority, such a vessel should be rigged up to prevent oil spills. The working time for this study could not ascertain whether this is done is a satisfactory manner. A land-based mail fuelling system is also present. This is the property of Enemalta. Spillages of diesel from this fuelling station have been known to occur. The location of this Maritime Base at the foot of Floriana Bastions, often lead to significant amounts of rainwater to rush down these bastions. This rainwater runoff end up mainly in the sea. Such runoff water also leads to cess-pits, which however are unlikely to cope with the significant volumes of water generated.


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A 3-year extention project for Hay Wharf quay is currently underway. This project aims at improving the present maritime facilities available at this site for the Maritime Squadron of the Armed Forces of Malta. The project envisages the re-organisation of the present layout into three areas; operational, logistical and accommodation for personnel. The extension of the present quay will improve the present berthing facilities and will be able to accommodate additional petrol boats. The new quay extension covers an approximate area of 750 m2, being 60 m long and from 10 to 13 m wide. The new extension will be provided with a service duct along its whole length . Surface drainage from the service duct inwards, will lead to 6 drain pits; while the surface drainage of the periphery of the new quay will lead water runoff directly into the sea. 7.3.6.2 Risks of Pollution by Oil This Maritime Base is well managed and inspection has shown the level of housekeeping is satisfactory. However, petroleum hydrocarbons, diesels, gasoline and other similar products have been identified as important marine contaminants in the inner half of the harbour. The already high levels of oil pollution in this area, is an additional argument for the need for strict control over these potential future sources of pollution by oil. The sources of oil pollution from the present as well as extended quay include:

- medium accidental spills from the fuelling station; - chronic operational spillages of fuel, bilge oil and lubricating oils

from patrol boats; - rain run-off water from quay pavements, and slipway which may be

contaminated with fuels and oils; Such risks may be effectively controlled by appropriate measures. For example, the operations of the fuelling station will have to be conducted under proper supervision. Operational losses of fuel oils may constitute a chronic source of pollution which may be difficult to control and which would depend on the good management of the boats themselves as well as of the workshop facilities located within the base. Rainwater runoff contaminated with oil residues may also reach the sea from the extended quay surface, unless special provisions against such eventualities are made. In fact, the risks of oil pollution as identified above, may be controlled and


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properly managed if dealt with within a comprehensive base management programme as recommended in subsequent sections of the present report. 7.3.6.3 Level of Compliance As already indicated above, there are no direct and intentional point sources of marine discharges at this site. Nonetheless, this locality may be considered as an important diffuse source of pollution (especially of oil and its products) which will need to be controlled under the provisions of the relevant EU water quality Directives (as reviewed in Chapter 2). Unfortunately no provisions have been made in the quay extension project to minimize and control oil pollution through surface runoff. One option was to have reverse grade quay surface paving, which would ensure that rainwater runoff will not be discharged directly into the sea, but will be channeled to a settling tank first. This would prevent the discharge of the rain runoff from this site, and to subsequently treat such water and remove traces of oil contaminants prior to its discharge into the sea. Similar provisions have been already incorporated in the development of the marina at Portomaso (Hilton). Numerous objections were raised to these recommendations, including:

(a) one cannot dig deep enough to install underground reservoirs for runoff catchment and temporary storage)

(b) Oil may still reach the sea; (c) The option is not economically feasible for the amount of oils which

may be expected to end up in the sea. At this stage, it is difficult to assess the cost of compliance for this site. However, as already noted in Chapter 2, the EU water Directives also aim to control diffuse sources of pollution such as those originating from this base. Compliance may involve the introduction and full implementation of a general waste (and wastewater) management programme. This could involve additional costs which may not be estimated at this stage. In the worst case scenario, treatment of runoff water would have to be implemented. 7.3.7 Other Fuel Terminals Two other fuel terminals were investigated for the purpose of the present study. These were: San Lucian Oil Company Ltd. and Enemalta Gas Division.


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The Enemalta Gas Division Installation in Marsaxlokk, uses water for gas cylinder testing. The filled gas cylinders are tested by immersion in a water tank prior to reaching the consumer. This water is periodically emptied in the yard of the complex, from where is reaches the shoreline via a gutter. Approximately 600 gallons of water are discharged every 2 weeks. No contaminants are expected in such wastewaters. In the case of San Lucian Oil Company Ltd., no dewatering of the stored fuels is carried out. Subsequently, unlike the other fuel terminals, no wastewaters are directly discharged into the sea. On the basis of available data, no compliance costs are envisaged for these two sites. 7.4 Impact of Compliance on Oil and Fuel Terminals Seven fuel terminals and another site with potential pollution by oil were assessed. Five fuel terminals were found to discharge a global volume of 242,100 m3 per year, of which, almost 93% originate from a single terminal (MD Tanker Cleaning Facility). Wastewaters from these sites are mainly generated from dewatering of fuels during storage, or from oil-water separation of ballast waters, or from rainwater runoff. In all cases, except for the Oiltanking (Malta) Ltd., the present treatment of oily waste waters do not conform to the 5 mg/l limit. MOBC Ltd. has claimed that its wastewaters do conform to such limit. In the case of Waste Oils Co. Ltd., in addition to oil, relatively high levels of heavy metals may be found in such wastewaters due to the nature of the oil (i.e. spent oil) being handled. The estimated global compliance costs for capital expenditure for this sector may vary from Lm3.6 million to Lm16.6 million (Table 7.1) In the worst case scenario, there will be a need to relocate the MD Tanker Cleaning Facility from Grand Harbour, and this option explains the higher limit of the range of estimated capital costs required. Total annual running costs due to compliance may estimated at Lm55,000 to Lm90,000. In addition, an approximate annual sum of Lm20,500 will be required for monitoring obligations.


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References Axiak, V., Pace L., Axiak, M. 1999. The Coast and Freshwater Resources. Unpublished report prepared as part of the ‘State of the Environment Report for Malta 1998’ commissioned by the Environment Protection Department, Government of Malta; Valletta, Malta: Malta Council for Science and Technology; 46pp. International Maritime Organisation, 1995. Comprehensive Manual on Port Reception Facilities. IMO, 341pp. Mallia, E.A., and Fsadni, M. 1999. Energy: Transformation, Use and Environmental Impact. Report prepared as part of the ‘State of the Environment Report for Malta 1998’ commissioned by the Environment Protection Department, Government of Malta; Valletta, Malta: Malta Council for Science and Technology; 30pp. Malta Council for Science and Technology, 1998. Workshop on Controlling Wastes from Shipyard Activities (Task Team on Industrial Waste Management) Malta Council for Science and Technology and Malta Drydocks; Malta: 1 and 2nd December 1997. Edited by V. Axiak.


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8. IMPACT OF COMPLIANCE: ELECTRICITY GENERATION AND FRESHWATER PRODUCTION

8.1 General Background Assessment of these two related sectors is being presented in the same chapter. 8.1.1 Electricity Generation Enemalta owns two power stations at Marsa and at Delimara. Both stations work together in a network. The Delimara plant has a production capacity of 305 MW, of which 75 MW are only produced when the country is in a state of emergency (Enemalta Chairman as reported in Malta Independent on Sunday, 19 Nov. 2000). The Marsa plant has a capacity of 270 MW. The average demand for electricity is 280MW, although it peaks at 350MW on the coldest days in winter. According to data available from reports published by Enemalta Corporation, for 1998, the winter peak demand for electrical energy rose to a record high of 353Megawatts in February, which was 16% more than the winter peak of 1997. The Summer peak also rose to a record 311 Megawatts reflecting the sustained increase in the summer demand. There is insufficient information at present for a very detailed breakdown of electrical energy by user; but an adequate picture can be drawn from Enemalta and WSC annual reports. The following account is based on Mallia and Fsadni (1999) Over the period 1994 to 1998 around 6% of generated power has been actually used at the generating stations, which is about the going rate for isolated power stations. Losses in the distribution system were of the same order of magnitude (~5%), which compares favourably with continental networks. That still leaves 7-8% of generated units unaccounted for, variously assigned to billing anomalies and plain theft. Despite numerous court cases, Enemalta has had little success in bringing energy theft under control. In either case, these ‘lost’ units form part of total units actually consumed, rather than wasted. As such the problem is a financial rather than a technical one. As far as units sold are concerned, Enemalta has three classes of consumer: domestic commercial and industrial, each taking approximately a third of generated units, with industry in the lead.


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Electrical energy from the power stations is the source of practically all of the secondary energy used in industry. Over most of the period 1981 - 1997, electrical energy consumed by industry has risen at the same rate as the general increase: 9% p.a. compound up to 1994. Thereafter, the rise in demand from industry alone has eased off. Although there may be some contribution from an alleged reduction in industrial activity, the main contributor to this easing off has been the largest single user of electricity, the WSC. Between 1995 and 1998 the electrical energy devoted to the production and distribution of water fell from 19% to just 9% of units sold by Enemalta. There was no corresponding easing off in demand in the combined commercial and domestic sectors. 8.1.2 Freshwater Production The water availability on the Maltese Islands is basically determined by climate and by their catchment’s characteristics. Rainfall is the only natural source of water. Based on considerations of rainfall and ambient temperatures, Malta’s climate may be best described as semi-arid and typically Mediterranean. The seasonal distribution of rainfall defines a wet period (October to March with 70-85% of the total annual precipitation) and a dry period (April to September). The average annual precipitation is circa 530mm. However, rainfall is highly variable from year to year. More than half of Malta’s drinking water supply is produced by the reverse osmosis desalination of sea water. There are four main RO plants operating at Lapsi, Marsa, Cirkewwa and Pembroke, which are operated by the Malta Desalination Services . The RO plant at Penbroke produces the largest amount of water (as much as 54% of the total volume in 1996-1997). A fifth RO plant at Tigne’ had proved to be the least efficient and in its 1996-97 report, the WSC had indicated that its production could easily be replaced by the Pembroke plant from the point of view of distribution of product. The Marsa RO plant has also not been in operation for some time (partly due to the problem of sewage pollution from the Marsa Sewage Pumping Station) and currently only three RO plants are operational. In 1994, the RO plants suffered only 5.6% downtime (due mainly to interruption of power supply). They produced an average of 79, 800m3 water/day. In 1995 - 98,the average daily production was of 581m3/day. The operation of the plants is susceptible to contamination by sewage pollution. Very often the operation of the Marsa RO plant has been regularly interrupted for long periods of time due to contamination by sewage of the water boreholes.


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There is evidence to suggest that the demand for water has been decreasing steadily since 1995, and this is partly due to water conservation, improvement in leakage control and increased water tariffs. 8.1.3 Trends In Water Consumption And The Impact On Energy Consumption The demand for water in 1996 was lower than the previous year’s demand. In Malta the reduction averaged 8% and in Gozo 10%. In general, the demand for water has been decreasing steadily for the past years. This is due to more effective water conservation measures namely the improvement in leakage control. With improvements in the distribution network and the use of more efficient pumps, the power demand on groundwater sources declined. The exception was the demand on pumping stations in 1995-1996 where heavy rainfall and subsequent contamination meant that some water was diverted (and thus lost) to drain after being pumped to the surface. In 1996, water production by RO desalination was 16% less than the previous year, this being due mainly to a decreased demand of water and to fuller utilisation of the ground water that was harvested (better conservation mentioned above). RO desalination is a high energy consumer as indicated in the table below. In 1988, the electricity consumption by the RO plant sector was of 79.77 GWh, which was 11% of the total electricity produced (Axiak et al. 1999). In 1995-96 the WSC accounted for 19% of the total electricity produced (includes energy for RO plants and groundwater production and distribution). The energy requirement of this sector has practically doubled in 10 years. Published data (WSC Annual Reports) indicate that the RO production consumed from 14 to 20% of the national energy production, over the past few years. In 1995, energy consumption was 13.3% less that that in 1994 due both to reduced production and to more efficient energy utilization (WSC Annual Report, 1995-96). This trend is attributable to increased efforts to minimize energy consumption per unit product by the RO plants, improve RO performance and water conservation measures. In fact , there is evidence to suggest that improved efficiencies and management of RO plants have reduced the amount of electrical energy required per m3 of RO water production from 6.06 kWh to 5.81 kWh. Water from the Reverse Osmosis (RO) plants still forms about 50% of daily production. For 1996/97 R.O. production amounted to 24.5 million m3 at 5.8kWh


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per m3. WSC thus remains the largest single user of electrical energy, even if its annual consumption has seen a marked decline over the last three or four years. The drop in energy consumption is mainly the result of a decline in demand for water. Most of the decline is real, as it started soon after the 1995 water price increase; but the efforts of WSC to cut back on leakage losses may also have appeared as an apparent drop in consumption, as more of the water produced would have been reaching the end user 8.2 Assessing Impact of Compliance by the Power Stations 8.2.1 Marsa Power Station (PP1)

8.2.1.1 Operations For 1998/99 this power station generated over 492,500 MWh of energy. It includes 8 steam turbines (commissioning dates: 1966 to 1987) and 1 gas turbine which has been commissioned in 1990. All fuel is currently heavy and/or light fuel oil. For 1999, the rate of consumption of fuel oils per year were 350,000 m3 heavy fuel oil and 2800 m3 light Fuel Oil. The Marsa Power Station complex includes a fuel oil storage capacity of 35,000 m3 of heavy fuel oil and 1400 m3 of light fuel oil. All fuel oil tanks are bunded. The annual consumption of chemicals for this installation is tabulated below:

Table 8.1 Annual consumption of chemicals

Trisodium phosphate 500 kg Caustic soda 40 MT Belgard 8 tonnes Belite 0.5 tonnes Oxygen Scavenger 10 to 15 tonnes Hydrazine 500 kg Chlorine 52 tonnes Clamtrol 30 tonnes Cyclohexylamine 400 kg Sulphuric Acid 2500 tonnes Hydrochloric Acid Variable Light sodium carbonate Variable Silica gel Variable

Fuel Oil Emulsifier 7800 kg

MgO based additive 26000 to 52000 kg


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8.2.1.2 Generation of Waste waters

Figure 8.1 is a graphical presentation of the various operations within this installation which generate various wastewater streams. All streams are discharged directly on the shoreline at inner Marsa (along Church Wharf).

The dewatering of fuel oil (Discharge 1) during storage produces approximately 800 m3 of waste water per year. This is led to settling tanks (as does all rain water runoff) and then to an oil interceptor. This primary treatment plant is insufficient to reach the 5 mg/L level. The levels of heavy metals in this wastewater stream are unknown. Boiler Washings produce an annual volume of discharge of approximately 760 m3. The rate of this discharge is not regular but is usually at 0.1m3/min. These effluents (Discharge 2) would carry high levels of suspended solids, in excess of threshold levels as would be required by the forthcoming LN of the Environment Protection Department. Other chemical additives may be expected in these effluents.

Boiler blow-down waters also generate another waste-water stream (Discharge 3) with a number of likely contaminants including: : suspended solids, copper, iron, silica and other additives (such as trisodium phosphate, sodium hydroxide and synazine. Currently these waters are not led to a settling tank to reduce suspended and settable solids. There is also no pH control. By far, the most significant wastewater stream generated in a power station is that of cooling waters (Discharge 4). For Marsa Power Station, the annual volume of such cooling waters which are discharged into the Grand Harbour (inner Marsa) may amount to 250 million m3. The rate of discharge is usually at 500 m3/minute. Enemalta officials claim that these effluents are discharged at approximately 4o to 8o C above ambient. These effluents also contain antifouling agents: chlorine at 1-2 mg/L (for 3 hours every 24 hours) and Clam- trol at 18 mg/L (for 24 hours every 1.5 months). At the Demineralization Plant (which produces water of the correct quality for the boilers, waste waters (Discharge 5) are produced during regeneration of ion resins. The estimated annual volume for this stream amounts to 150 m3. The likely contaminants are suspended solids, and chemical additives. Finally, brine water from the evaporators (Discharge 6) are produced an annual estimated volume of 641000.m3 and at a discharge rate of 1.25 m3/min. The likely contaminants in this discharge stream include suspended solids and other chemical additives such as Belgard as antiscale and Belite as antifoam.


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8.2.2 Delimara Power Station (PP2) 8.2.2.1 Operations For 1998/99 this power station generated over 824,400 MWh of energy. It includes 2 steam turbines (commissioning dates: 1991-92); 2 gas turbines (1995) and one combined cycle turbine. All fuel is currently heavy and/or light fuel oil. For 1999, the rate of consumption of fuel oils per year was 186 000 tons/year. The Delimara Power Station complex includes a fuel oil storage capacity of 50 000 m3 of fuel oil. All fuel oil tanks are bunded. 8.2.2.2 Generation of Waste waters

Figure 8.2 is a graphical presentation of the various operations within this complex which generate various wastewater streams. All streams are discharged directly on the shoreline from a single point at Hofra iz-Zghira.

The dewatering of fuel oil (Discharge 1) during storage produces approximately 100 000 m3 of waste water per year. This is led to settling tanks (as does all rain water runoff) and then to an oil interceptor. This primary treatment plant is insufficient to reach the 5 mg/L level. The levels of heavy metals in this wastewater stream are unknown. Boiler Washings produce an annual volume of discharge of approximately 400 m3. These effluents (Discharge 2) ware discharged at sea after settling and pH neutralization. No detailed information regarding their chemical composition is available. Suspended solids in such a stream may contain sulphur, nickel, vanadium and iron compounds.

Boiler blow-down waters also generate another waste-water stream (Discharge 3) at a discharge rate of 0.7 m3/hour. These waters are led to a settling tank and a neytralization pit to reduce suspended and settable solids as well as control pH. By far, the most significant wastewater stream generated in a power station is that of cooling waters (Discharge 4). For Delimara Power Station, the annual volume of such cooling waters which are discharged into Hofra iz-Zghira may amount to 250 million m3. The rate of discharge is usually at 500 m3/minute. Enemalta officials claim that these effluents are discharged at approximately 4o C above ambient. These effluents also contain antifouling agent: chlorine at 1-2 mg/L (for 3 hours every 24 hours).


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At the Demineralization Plant (which produces water of the correct quality for the boilers, waste waters (Discharge 5) are produced during regeneration of ion resins. The estimated annual volume for this stream amounts to 155 m3 at a discharge rate of approximately 3m3 per week. The likely contaminants are suspended solids, and chemical additives. Discharges containing residual sulphuric acid and caustic soda are neutralized before discharge in the sea. Finally, brine water from the evaporators (Discharge 6) are produced an annual estimated volume of 570 000 m3 . and at a discharge rate of 1.1 m3/min. The likely contaminants in this discharge stream include suspended solids and other chemical additives such as Belgard as antiscale (annual consumption: 8 tons per year).

8.2.3 Analysis of Marine Discharges For the purpose of the present study, three samples of discharged waste waters from Marsa Power Station and two samples from Delimara Power Station were collected and analyzed for contaminants relevant to the EU Directive. The results of this monitoring are presented in Table 8.2. These also include the levels of the relevant contaminants in seawater samples collected from the Marsa area. It is evident that the levels of pollution in this part of the Grand Harbour are relatively high and therefore, the quality of waters used for turbine cooling at Marsa is low, even at source. At this stage, the contribution of the Marsa Power Station to these relatively high levels of contaminants (such as organotins) at Marsa, may not be properly assessed. This will require a thorough environmental audit exercise to be undertaken. These results are incomplete due to the limited samples available and should only be used as an indication of the potential situation. Nonetheless, it may be suggested that the levels of oil in the waters being discharged by the Marsa Power station are comparable to the background levels in the sea at Marsa. The same applies to heavy metals, except for possible copper and nickel. In the case of marine discharges originating from Delimara, the levels of organotins were highly variable for the two samples. The levels of some metals were also appreciably high (e.g. Zinc and nickel), though not beyond the thresholds to be set by the LN of the Environment Protection Department.

8.2.4 Thermal Discharges Very limited data is available on the thermal discharges originating from the two Power Stations.


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Some data is available which has been generated by the present consultant during the period 1997-2000 , as part of a research programme funded by the Italo-Maltese Financial Protocol on the application of remote sensing for water quality monitoring. Such data is presented in Table 8.3. For the case of Marsa Power Station, it is evident from the data that the region of intake for this Power Station is under the influence of the thermal discharges of the Power Station itself! In fact, near the intake, surface temperatures were in the region of 2 to 3o C above ambient. In this case, ambient temperature was taken at that at the mouth of the Grand Harbour at the same water depth. It is worth to note that the surface temperatures as presented in Table 8.3, were monitored not in the actual point of discharge but at least 15 m away. Therefore, it is quite likely that the temperatures of the discharged waters were at least 1-2o C higher than those shown in the third column of this table. This data shows that this Power Station is emitting thermal discharges which are at least 4 to 8o C above ambient. The extent of the thermal discharges emitted from the Marsa Power Station may also be visualized using LANDSAT 5 TM data (Figure 8.3). This data shows that most of the inner half of Grand Harbour is under the influence of such thermal discharges. Similar satellite images taken in 1995 show comparable effects (Geraci et al. 1997). The thermal effects emitted by the Delimara Power Station apparently cover a less extensive area. However, some reports (e.g. Jones, 1996) are available to show that such discharge is having an ecological effect at Hofra iz-Zghira. The draft format of the LN controlling marine discharges to be issued by the Environment Protection Department, which was made available for the purpose of this study, did not include any maximum permissible limit values for thermal discharges. In fact, according to personnel from the Pollution Control Co-ordinating Unit (EPD) such limit values are still under consideration. It is recommended that in establishing such limits to thermal discharges, which are applicable to the local Power Stations, the following considerations will be taken into account:

a) The ecological sensitivity of the area under the influence of the discharge, (e.g. that of Hofra iz-Zghira);

b) The need to stipulate an upper limit of increase in temperature at the discharge point above ambient, rather than above intake temperature. This will take into account the case of the Marsa Power Station, where


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the intake region is already under the influence of the thermal discharges from the same Power Station.

8.2.5 Compliance and Costs for Power Stations In the case of Marsa Power Station, there is a need already identified by Enemalta, to construct a settling tank and neutralizing pit similar to the one available at Delimara Power Station. No detailed cost estimates are available for these works. Furthermore, there is an evident need to improve on the oil-water separation plant, and as in other similar cases, it is estimated that the cost of a suitable treatment plant to achieve the 5 mg/L limit, would be Lm300,000. This sum will be applicable, assuming that the oil wastewater stream will be treated separately from the other stream as identified in the above account. Therefore, in the best case scenario, the approximate capital sum required for both recommended improvements may be in the region of Lm 350,000. In the worst case scenario, the thermal discharges would need to be controlled, by some cooling plants, to displace the heat from water into the air. At this stage it is impossible to provide an estimate for this option, even an approximate one. Such a cost will be greatly determined by the setting of the thermal limit for these discharges, in the local legislation and legal notice to be issued by the EPD. In the case of the Delimara Power Station, the same capital costs apply, less that required for a settling tank and neutralizing pit for some of the wastewater streams. Other annual compliance costs for the running of the proposed treatment plants as well as for monitoring and reporting obligations are presented in Table 8.4. The required time frame for compliance may be estimated at 1 year. As indicated in Chapter 5, the time frame for compliance has been estimated in terms of the number of years required for implementation of the relevant compliance programme, which may be required, assuming that the necessary administrative decisions have been already taken and that the necessary financial and other resources would have been made already available. Therefore, no allowance is being made for undue delays in compliance-related policy and decision making by the respective authorities or companies, as well as for any difficulties, which may arise to allocate the necessary funds and other resources.


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To conclude, while in the best case scenario, a total estimated capital sum of Lm 0.65 million may be required, in case that thermal effluents will need to be controlled, then the estimate will be much higher. 8.3 Assessing Impact of Compliance by Reverse Osmosis Plants 8.3.1 Malta Desalination Services (RO1,RO2,RO3) The company which is a subsidiary of the Water Services Corporation, employs 120 FT staff and 1 PT. The company supplies more than half of Malta’s drinking water supply by the reverse osmosis desalination of sea water. There are four main RO plants operating at Lapsi, Marsa, Cirkewwa and Pembroke, which are operated by the Malta Desalination Services . The RO plant at Penbroke produces the largest amount of water (as much as 54% of the total volume in 1996-1997). A fifth RO plant at Tigne’ had proved to be the least efficient and in its 1996-97 report, the WSC had indicated that its production could easily be replaced by the Pembroke plant from the point of view of distribution of product. The Marsa RO plant has also not been in operation for some time (partly due to the problem of sewage pollution from the Marsa Sewage Pumping Station) and currently only three RO plants are operational. 8.3.2. Marine Discharges from RO plant The existing RO plants make use of Du Pont Permasep B-10 permeators membranes. Several chemicals are used for their cleansing and further treatment. Brine waste waters as well as membrane wash waters produced during back-flushing of the membranes, are discharged directly into the sea. Marine Discharge rates as well as the amounts of chemicals used for membrane treatment per RO site, are presented in Table 8.5:


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Table 8.5 Volumes of brined discharges and annual consumption of chemicals in RO Plants

unit Lapsi Marsa Pembroke Cirkewwa Brine Discharge m3/day 24000 5500 32400 20000 Citric acid kg 2480 880 9300 3678 Ammonia kg 832 350 4440 1218 Ultrasil kg 1040 310 4704 1686

Caustic soda kg 120 30 300 150 Sodium bisulphate kg 456 180 2352 936 Tannic Acid (PTA) kg 24 6 75.6 27 Polyvenyl-methylether kg 36 6 108 37

The use of formaldehyde has now been phased out completely. Brine waters are discharged at approximately 1o C above ambient temperature. Their pH is in the range of 6.2 to 6.8. Only flow rates are monitored for the discharged waste waters. For the purpose of the present study, one sample of undiluted discharged waste waters was collected and analyzed for the relevant chemicals, from each of the three RO plants being investigated. The results are tabulated in Table 8.6. The complete set of analytical data has been commented upon in Chapter 4. Evidently, the amount of quantitative data available is insufficient to be able to make a thorough assessment. Nonetheless, a number of indicative observations may be made at this stage. The main chemicals of concern which were detected in these discharged waste waters are: boron, and to a lesser extent, arsenic and nitrates. It is more likely that such chemicals or potential marine contaminants are originally found in the feed waters and are being concentrated in the discharged brine stream. In fact, boron background levels in the seawater may already be high. Evidently there is a need for a more thorough study of this issue. 8.3.3 Level of Compliance


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The total amount of waterwaters generated from this sector and which are discharged directly in the marine environment, is significantly high and represents approximately 5% of the total waste waters being currently discharged at sea. It is most likely that there will be no compliance problems with this type of discharges. Nonetheless, monitoring of these waste waters undertaken within the framework of the present study has revealed elevated levels of boron (2 to 6 ppm) and possibly other metals. The levels of boron and other heavy metals in ambient waters next to the inputs of the plants may be already high, but evidently by its very nature, the plant is essentially concentrating such potential contaminants and discharging them back into the marine environment, from where they originated in the first place. If the LN for the control of marine discharges to be issued by EPD, will take into consideration this reality in a sensible manner, in setting standards for heavy metals (and especially with respect to boron), then no compliance capital costs will be incurred for this sector. However, it is recommended that a more detailed monitoring programme would be undertaken for these marine discharges as well as for the ambient levels of contaminants at the inputs of these RO plants. The estimated costs of such a study may be Lm20,000. This study should be undertaken as soon as possible and should ideally be completed within 3 months. The resultant data would serve as a scientific basis on which to determine the required maximum permissible limit values, taking into consideration the ecological sensitivity of the areas under the influence of these discharges. References Axiak, V., Pace L., Axiak, M. 1999. The Coast and Freshwater Resources. Unpublished report prepared as part of the ‘State of the Environment Report for Malta 1998’ commissioned by the Environment Protection Department, Government of Malta; Valletta, Malta: Malta Council for Science and Technology; 46pp. Geraci A. L., Fargione, G.A., Axiak V., And Tabone Adami E. 1997. Monitoring of environmental water quality of Maltese coastal waters using remote sensing techniques. In. Remote Sensing. Integrated Applications for Risk Assessment and Disaster Prevention for the Mediterranean. Edited by A. Spiteri. A.A. Balkema, Rotterdam, Brookfield. pp 241-248.


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Jones S.J., 1996. Thermal Effects of Delimara Power Station. Elective Projects Abstracts 1995-96, D. Dandria ed. Mallia, E.A., and Fsadni, M. 1999. Energy: Transformation, Use and Environmental Impact. Report prepared as part of the ‘State of the Environment Report for Malta 1998’ commissioned by the Environment Protection Department, Government of Malta; Valletta, Malta: Malta Council for Science and Technology; 30pp.


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9. IMPACT OF COMPLIANCE: SHIP YARDS AND SHIP REPAIRING

9.1 General Background This sector is one major component of the local industrial context, both in terms of employment, as well as in terms of reserves of foreign currencies and the multiplying effects it exerts on other industrial sectors. For the purpose of the present study, marine discharges from three shipyards were assessed, including: Malta Drydocks (including Manoel Island Yacht Yard) , Cassar Ship Repair Ltd. and Bezzina Shipyard. The latter two sites claim to have no direct marine discharges. However, the waste water generated from their docks as well as other runoff, will need to be taken into consideration. 9.2 Malta Drydocks (SY1a) 9.2.1 Introduction: Malta Drydocks (MD) is one of the major ship repairing yards in the Mediterranean. It comprises 7 docks, the biggest of which can accommodate vessels of up to 300,000 tonnes. These docks, and the various operational units of the dockyard, are located in close proximity of the three cities of Cottonera, which is possibly one of most densely populated regions of the Maltese Islands (approximately 9500 inhabitants per km2). The various operations of Malta Drydocks are bound to generate significant amounts of industrial wastes which have environmental implications on these residential areas as well as on the working conditions of its own workforce. There is an urgent need to identify and assess the environmental performance of this industry and to mitigate and control such impacts in a way so as to protect human health and the natural environment in a manner which would sustain the economic and industrial feasibility of this yard. This would require a thorough environmental audit which goes beyond the scope of the present study. We recognize the fact that any one environmental issue resulting from waste generation and its management within MD can only be effectively tackled within a wider context of a waste management programme which in turn is only one component of environmental quality management. Standards on environmental


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management, life cycle assessment and environmental performance evaluation have been applied to the shipping and shipbuilding industry elsewhere, and the relevant authorities should facilitate the undertaking of similar exercises at MD, in collaboration with the appropriate agencies. 9.2.2 Assessing Marine Discharges For the purpose of the present report, only those MD operations leading to direct marine discharges in the sea, will be discussed and assessed. Over 10 potential marine discharges were initially identified. Separate interviews were held for each. This review includes the Manoel Island Yacht Yard, which is part of the MD. The Tanker Cleaning Facility at Rinella is dealt with in a separate section of this study. A synoptic review of the various identified discharges is presented in Table 9.1. This table gives the various data available for each section within the Malta Drydocks. It includes:

a) The estimated annual volume of waste waters discharged into the sea;

b) The annual consumption of chemicals and reagents; c) The potential presence of contaminants in such effluents.

Most of the separate streams of effluents are currently discharged through two main outlets for marine discharges leading from the Cleaning Bay of the Machine Shop. These are located immediately above the water line and are approx 1m in diameter each. They empty waste waters into French Creek along what is sometimes called, Factory Wharf. No algal growths were observed in the immediate vicinity of these outlets (evidently because of the toxic effects of the effluents). Furthermore, there is evidence of huge deposits of sludge in the area, since when seawater is agitated (as a result of dock activities or ship propellers) then the water in the area becomes murky with re-suspension of such sludge. The originating source of the various effluent streams will now be separately assessed. 9.2.2.1 Machine Shop This shop is responsible for the overhauling of diesel engines and other machines as well as for other engineering works. 70% of such works require cleaning from oil,


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grease, inorganic and organic residues such as rust and paints. All cleaning is carried out in a specially designated Cleaning Bay. Machines are first cleaned by immersion in an alkali bath to degrease (alkaline buffer: 1000kg per year). Alkali baths are kept at elevated temperatures (above ambient). Then, the items are immersed in dilute acid (HCl: Descalant RD 10001/year) to remove other residues. Sewage valves are cleaned in concentrated acid (Descalant RD) to disinfect properly prior to works. Certain works (e.g. thermochangers) are cleaned by high-pressure waters jets only. Aluminum works are cleaned with air cooler cleaner (1000 l/year) as well as with a degreaser (156D: 5000 l/year) Seawater and tap water are used for cleaning down to remove residues of acid etc. All washings as well as any spent alkali/acids/residues/sludge are disposed off in gutters which lead to the sea in front of Main Office, as identified above. Sludge which accumulate at the bottom of cleaning tanks are disposed off along with the liquid effluents into the sea. Spent cutting oils are disposed off in sewers. Approximately, 6001/year of such cutting oils are disposed off per year. It is difficult to assess volumes and rates of discharges into the marine environment. A rough estimate may amount to 500 m3 per year. No on-line or manual monitoring is carried out on such discharges. No treatment of effluents is carried out. Some years back, it was originally proposed that all discharges will be temporarily stored in reservoirs, which could then be emptied periodically by bowsers. However, no one then knew how to dispose of such material (liquid and solid). Therefore, such an idea was shelved (Mr. F. Mifsud, Shop Manager, personal communication). According to Dr Vincent Scerri, (MD) when LN8/93 came into force, MD applied for sewer discharge permits, through its Development Office and Civil Eng. Department.


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9.2.2.2 Electrical Shop and Electronics Department This department is responsible for the repair and overhauling of electrical motors, windings, generators, etc.. Some tin electroplating is carried out using a bath of stannic salts. The approximate volume of this bath is 0. 5m3, and this is changed very infrequently (once every 10 years). Vecom Descalant HD BA-60 (HCl acid bath) is also used. The estimated volume used per year amount to 200 1. Bath contents are disposed of down the common drain (into sea). Most items to be serviced are first power washed using clean fresh water at high temperature. This washing water flows into the common gutter and into the sea. Acid baths (HCl and some HN03) are also used. Volumes: 1001 of HCl and 101 of HNO3 per vear. Acid bath contents are disposed off (down the common gutter) only when these are spent, i.e. no longer corrosive. Such contents are again disposed off down the gutter. The common gutter is communicated to the drain pipe from the Machine shop. It leads directly to the sea as indicated above. Approx. 0.5m3 of water washings are discharged per day. Transformers and welding reactors are serviced and their insulation oils are replaced. These are first drained of the old oil (which may contain PCBs) and then water hosed under high pressure to remove all traces of the old oil. Water washings are discharged down the gutter (PCBs may be reaching the seawater). The old oil is stored. MD is in fact presently holding a significant amount (40 drums of 200 litres) of spent oils containing PCBs. This may be sent abroad for proper disposal now that Malta becomes party to the Basel Convention. In the past the old transformer oils were replaced with SHELL DIALA B, which contained PCBs. This product is now being replaced with AGIP ITE 360. This contains a paraffinic base stock, severely solvent refined (99.9% wet ms) CAS 64741-95-3, together with additives. This transformer oil is NOT discharged into the sea. (MSDS provided). 40001 of degreaser 156D are also used for motor cleaning by dipping or spraying. Some of this mav reach the gutter. A full list of chemicals used in the shop was supplied (dated 20 July). Approx 0.05m3 of sludge in the various baths are produced per year. These are disposed off through the gutter.


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Again, the Electrical Shop had plans to store all liquid wastes in special reservoirs, rather then discharge them into the sea. The problem however, was what to do with the stored liquid contents. No advice or direction was available. 9.2.2.3 Galvanizing Shop Metal structures are first pickled in acid bath (35% HCI 65% water 0.25% Descalant accelerator 0.2% Degreaser Metfin ADOI and ADI I). This is to clean metal surface from residues grease etc. Then metal structures are hot galvanized by immersion in molten zinc (450o C). The dross (sludge) from the zinc baths are recycled and reused. Managers responsible for this shop, confirmed that acid baths do not discharge into the sewers or sea. The contents of the baths are rarely' changed. The last time that this happened for one bath was in 1998. The operation of bath change occurs very infrequent (approx even 2-5 years). When this happens the baths are washed with fresh water and the waste waters run into the sea. The shop is planning a further development to the current galvanizing process. This is as follows: after treatment by pickling in acid bath the structures will be rinsed in a water bath and then immersed in a fluxing bath. This will contain a solution of zinc ammonium chloride (1.5 kilo per 51 of water). This will help improve the process of galvanizing and reduce the amount of zinc consumption. This change in production may increase the current amount of waste waters which are discharged into the sea. (8-10m3 per year). A contractor may be possibly involved in the recycling of the contents of the fluxing bath. This will greatly reduce the generation and discharge of liquid wastes from this fluxing bath.

9.2.2.4 Acetylene Plant Acethylene is produced in two reactors by treating calcium carbide with water. The plant produce waste water which is passed through a series of sediment traps prior to discharge into the marine environment, through the main discharge outlets as identified above. Approx 1200m3 of alkaline waste water (pH 9-10) are discharged per year . 9.2.2.5 Motor Plant Repair Shop Machinery is washed down by pressure washing with fresh water. Degreasant (156D) is used on a much smaller scale then in other shops.


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The volume of washing waters produced is very small and only approximately 1m3 per year. This flows down into the dock area. It is possible to collect this water in a basin and then to send to a common treatment plant. 9.2.2.6 Dock Works The various dock activities which may generate waste waters are briefly reviewed here. (a) Hull blasting and cleaning This is carried out by dry grit blasting. Most solids, including grit and paint residues are collected from the dock bottom and discharged at sea (outside territorial waters) by a hopper barge. Approximately one barge load is disposed off per month. Each barge may carry approx. 160 m3 of solid wastes. It may be estimated that approximately 2000 m3 to 3850 m3 of spent dry grit is produced annually. Marine disposal of dry grit and paint residues should be discontinued. This may be considered as hazardous waste and should ideally be disposed on a special engineered landfill. In the Netherlands such grit wastes are treated as hazardous wastes and collected in barrels for off-site disposal. It is often disposed off in landfill as an in-between layer. In many European countries, such disposal has to meet with the standards for landfill disposal, which are: content of hazardous substances; leaching characteristics. Dry blasting is still in high demand within the maritime industry. MD attracts many customers on the basis of its services of dry grit blasting. Possibly, such operations will continue in the foreseeable future, though it is possible for hydro blasting or more so, slurry blasting, to become increasingly important and possibly to replace 15% of the present dry grit blasting. Shipyards in Greece and Turkey still do dry grit blasting. However in these cases, shipyards are not in the vicinity of densely populated areas such as the MD. An increase in productivity of the yard, (as planned and hoped for) will lead to an increase in dry grit blasting for the next 5-10 years. The resultant annual mass of the resultant spent grit may amount to 7120 tons. Estimating Costs of Disposing Spent Dry Grit in a landfill


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In order to comply with the EU Directive, spent grit should no longer be discharged at sea, but disposed off in a landfill such as Maghtab. The costs of compliance with this recommendation has been estimated as follows: Lm Capital costs to collect spent grit and transport it to land fill: 17,000

Annual running costs (including labour and transport) 10,600

Annual landfill disposal fees at current rate (Lm10 per ton) 71,200 Slurry blasting may become more predominantly employed. The resultant cost implications, especially with respect to marine discharges have been assessed as follows: In the MD the slurry blasting which has been employed to date is of the low volume high pressure type. For the treatment of a total hull area of 30,000 m2 per year, it may be estimated that this will generate approximately 1500 to 2000 m3 of waste waters which need to be disposed off. This estimate is based on the following assumptions: 1 to 2 m3 of water are used per hour per outlet. 3 outlets at a time are used on each ship. each outlet will cover 30-40m2 of hull surface. The resultant waste waters will probably contain high levels of organotins, metals and suspended solids. (b) Spot Tank Cleaning This is carried out using detergent and high pressure washing. This produces waste waters which are oily and contain detergents. Approximately 5,000 l of Tankleen (aliphatic solvent) may end up in the docks per year (out of a total of 10,000l used) . Approx. 1000 m3 of waste waters are produced per year through this operation. These waters will be rich in oil content. At present, this operation may start before the dock is completely empty of water. Therefore the contaminants are released into the sea., with the dock water. It would be possible to improve on this and to stop this discharge into the dock. This washing may be collected into portable tanks. The approximate costs involved for


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this modification in current dock practice (i.e. to collect and deliver the wastewater arising from tank spot cleaning) may be estimated as follows: Estimating Costs for Collection and disposal of waste waters from spot tank cleaning. Costs will have to cover: portable pumps, some pipework, and some holding tanks. It will then be disposed off for the proposed common MD treatment plant. To treat this type of oily waste waters, approx. Lm2500 of de-emulsifiers will be required, to recover the oil. This is because the dosage rate of de-emulsifier to waste oil is approximately 2:1, and the cost of one 20-litre drum is approximately Lm250. The resultant re-oiled water will be treated in the common treatment plant. The costs involved for collection of such waters from the tanks: Submersible pumps 6XLm 500 Lm 3000 Piping/hosing: 15 lengths X Lm200 Lm 3000 Holding tanks along dock 3X Lm1300 Lm 3900 Total: Lm 9900 (d) Hull painting and preparation Ship hulls are washed with clean water. The results effluents are relatively free from relevant contaminants. (e) Cleaning of boilers and coolers This cleaning of boilers and coolers while the ship is at dock, involves the use of alkali and acids. The volume of this water washing may be estimated to be 115 m3 / year per dock. This amounts to 500 m3 per year for the whole MD. At present, the generated waste waters are discharged in the sea. The costs for collection of such waters from the dock, would be covered by the estimate provided for the collection of waste waters arising from spot tank cleaning. (f) Discharges from ship while at dock. These discharges are mainly of cooling waters and are normally not contaminated. Toilets are not used while in dock. Septic tanks are never empted in docks.


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Estimating the total volume of waste waters produced in the docks. To recapitulate, the volumes of waste waters generated from the various dock activities may be summarized as follows: a) hull blasting 2000 m3 b) tank cleaning 1000 m3 c) hull washing 500 m3

d) boiler cleaning 500 m3 total 4000 m3 The following chemicals and materials are involved in all these operations: Grit

Detergent and Degreaser Acids/Alkali Paints Thinners

The volume of total dock water released, when ship moves out of dock, is highly variable and may not be estimated easily. However, this would run in the order of millions of m3 per year. (approx. 20 dock volumes per year). It is evident that the operational waste waters as identified above, should not be allowed to reach such dock waters. If so, the treatment costs required to treat the resultant dock waters so as to recover their contaminants would be excessively large. The more sensible alternative would be to collect the separate waste waters from the dock prior to the flooding of the dock, as indicated above. The resultant 4000 m3 of waste waters would then be treated as described below. Monitoring contaminants in dock waters. For the purpose of the present study, samples of dock waters were taken from a collecting gutter of a dock, on two consecutive days. During this period the dock was dry and occupied by a ship undergoing normal repair operations. Results are presented in Table 9.2


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Chemical analysis of these samples indicated that the main contaminants of concern, include the following: TBT, petroleum hydrocarbons, , zinc, copper and to a lesser extent chloroform and perchloroethylene. Evidently these results do not give a complete picture and should be considered only as a first indication. 9.2.3 Compliance: Common Wastewater Treatment Facility for the MD.

The above account has indicated that various operations in shops as well as within the docks generate varying amounts of waste waters. Fluctuations in the amount and quality of such waste waters are bound to be high and will depend on the time of year as well as level of production of the docks. However for the purpose of the present study, the total annual amount of such waste waters generated from MD operations may be estimated as 7000 m3. At present these waste waters are being discharged untreated into French Creek. This discharge may be considered to be in contravention of the relevant EU Directive and water treatment will have to be introduced. It is recommended that a common treatment facility will be set up within the MD, in order to deal with such waste waters. A separate feasibility study will need to be undertaken to determine the proper operational modalities and the most cost-effective water treatment technologies to be employed. Nonetheless, in the present study, preliminary enquires have been made to a number of foreign manufacturers of industrial water treatment plants, in order to be able to provide an order of magnitude estimate of the costs for such treatment. On the basis of these preliminary enquires, it may be estimated that the capital costs involved in the setting up of a common treatment plant to ensure compliance with the EU Directive would amount to Lm1.5 million to Lm 2 million. This plant would be able to deal with an input rate of 30 m3/day. In the worst case scenario, and in the case that the volumes to be treated are higher than estimated above, then this cost may increase to Lm4.0 million. The running annual costs may not be estimated at this stage with any certainty at this stage, since these would be largely determined by the type of treatment methodology employed. 9.3 Manoel Island Yacht (SY1b) The yard is a section of the MD. It employs 92 FT and has a turnover of approx. Lm 0.75 million. It offers yacht repairs and berthing for such repairs. Work is carried out afloat on slipways, on hard standing area or in dry-docked area.


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Boat hulls are pressure washed using fresh water to remove antifoulings etc. This water is bound to contain significant amount of copper (antifouling agent). Approximately 200 gallons of water are used per boat. On the slipways, the volume of wash water used is approximately 6m3 per year (20 gallons X 50 boats). This water is directly discharged down the slipways into Sliema Creek. On the hard standing area approximately 6 m3 of wash water are generated annually. According to the Boat Yard Manager, most of this wastewater seeps into the ground and are unlikely to reach the sea. However rainwater may then wash any resides (eg. Copper) into the sea. In the peak season, approximately 1 boat per 2 days, requires hull washing. There is no special arrangement for surface drainage of runoff water. The yard Manager has agreed to consider the possibility of including provisions for such a surface drainage system, (which would collect all runoff into holding tanks prior to discharge into the sea) for the new planned extension (land reclamation) of the hard standing area. This will not entail any significant extra capital costs. A new washing sump and drop keel is planned for the new extension. This will ensure that boat washing presently occurring on the hard, will be collected. This may be possibly treated by filtration through sand and/or carbon, prior to disposal into the sea. This may cost approx. Lm 5000. Wash water generated on the slip ways may not be treated in a similar manner. It is quite likely that the Copper limits are exceeded for this water. However due to the small volumes involved, this may be only of moderate significance. On the other hand, it may be possible to remove the slipways altogether and replace them with some other means (e.g. floating dock). This may cost approx. Lm 3 million for slipways to be eliminated and the dry-area to be extended and upgraded. Some solvents and resin epoxy fillers are used and residues of these may end up in the sea. Cuprinol wood preservative is often used, as well as degreasers and thinners. Paint residues are stored and disposed off as solid waste by the MD waste collectors (possibly dumped in Maghtab). Some grit blasting is carried out in this yard. Copper slag (approx. 6 tonnes per year) and fine grit (approx. 10 tonnes per year) are used for aluminum surfaces. Some of this may reach the sea. Lubricating oils, gray water (showers, etc) and black water (toilet tank contents) are removed from boats and disposed of by MD. Lube oils are sent to MDTCF. Other liquids are possibly discharged into sewers.


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Approximately 5m3 of lube oils and 5m3 of black (sewage) water are generated annually from the servicing of boats. The yard management is fully aware of the importance of keeping the creek waters free of oil or diesel, as this would ruin the paintworks of the boats being serviced With regard to antifoulings, most boats now use copper based paints. Tin based paints are used only on the larger boats (1-2 boats per year). A single sample of wastewater running down the slipways was analyzed during the present study. The results show a moderately elevated level of TBT (470 ng Sn/l) and traces of zinc (0.1ppm) and arsenic (2.1 ug/L). This data is insufficient to assess the quality of waste waters reaching the marine environment from this installation. The yard has the potential for further development to increase its productivity by up to three times. Only administrative problems may hold back such plans. Since the yard will now be incorporated in the Manoel Island Development Project, it will need to improve its technology and upgrade its activities to make them less polluting. Reduced blasting. It is also possible to acquire a floating dock. Other proposed improvements have been referred to above. 9.4 Summary of Compliance Costs for MD (not including MDTCF) Compliance costs as identified above are being summarized in Table 9.3. The capital costs required to ensure compliance range from Lm2.05 million to Lm7.73 million. These are quite significant costs, as a result of which the operations of the Malta Drydocks will comply with the relevant EU Directives. More so, the activities of this important industrial complex, which is located in a locality in Malta with probably one of the highest population densities, will be controlled and managed in such a way so as to reduce its ecological impacts to acceptable levels. Moreover, the estimated annual running costs are also quite high. This is mostly due to the proposed changes in the current practice of discharging spent grit at sea. The resultant costs are mainly due to landfilling fees which will be charged to the MD. These costs would greatly increase if such fees would be upgraded in the near future. In each case, the required time frame for implementation is given as the number of years required from the time of deciding and giving the ‘go ahead’ for that option.


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Furthermore as proposed in Section 9.2.1, a full environmental audit will need to be carried out for this industrial complex, and the costs for such an audit have not been included here. 9.5 Cassar Ship Repair Ltd. (SY2)

9.5.1 Company Profile Cassar Ship Yard Ltd provides comprehensive marine services and carry out marine works on ships and marine craft. This company has been established in 1962 and currently has one floating dock (max. capacity 5000 tons). It specializes in afloat repairs, where riding squads provide services to a marine craft while at sea. It also owns tugs and barges. The company is the sole agents and stockists of grit blasting. It also specializes in hydroblasting, having a machine with an output capacity of 2000 bars. In fact most blasting is now carried out with hydroblasting at this industrial complex. The company employs 90 FT and 10 PT staff and generates a annual turnover of approximately Lm 1.2 million. 9.5.2 Operations The dock activities for this company are similar to those of MD as discussed above, but on a much smaller scale. 85% of hull blasting is carried out with hydroblasting, while hull washing is carried out by high pressure hosing. No chemical additives are used. Tank cleaning is carried out manually, with residues being recovered in drums and disposed off at Falzon Oil Recycling Ltd. The General Manager for this company claims that discharges of oily waters is very limited. No galvanizing work is undertaken within the complex.


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The annual use of chemicals and other materials is as follows: Table 9.4 Chemicals use by Cassar Shipyard annually.

Base Oil 45 l Perchloroethylene (Air cooler cleaner): Unitor 500 l Descalant HD (HCl) 25 l Soap paste Hydrochloric Acid some Solvent Degreaser some Varnish some Thinner 200 l Degreaser 200 l Paints Supplied by ships

Most chemicals are disposed off with spent oils and sent to Waste Oils Co. Ltd. The production of the yard is often limited by the poor water quality of the Marsa Creek. This is mostly due to sewage overflow from the Marsa Pumping Station and often from the Marsa Power Station. The Genera Manager for this Company claimed that very often, underwater marine works need to be suspended, due to their divers being unable to continue work due to health risks. 9.5.3 Marine Discharges There are no point sources of discharges into the sea. Nonetheless, the nature of operations as identify above, is bound to lead to wastewasters being generated, which would eventually end up in the sea through runoff. As already discussed in previous chapters, such diffuse land-based sources of marine discharges are also to be controlled by the various provisions of the relevant EU water directives.


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Most marine discharges originate from hull works and preparations on the floating dock. Also washing waters originating from machine works in the various workshops, may reach the waterline by runoff. The available data is insufficient in order to quantify and identify the various marine contaminants in such waste waters. In general, it may be assumed that the situation is as in MD but on a much smaller scale. Houskeeping in such small and private companies may be of a better standard, and could be easier to enforce. 9.5.4 Volumes of Marine Waste waters For the purpose of the present study, it may be assumed that approximately 500 m3 of waste waters would be generated annually from the various operations of this company. This is equivalent to less than 10% of the total volume of waste waters generated by the various shops and sectors of the MD, not including the acetylene plant (which is not available in the smaller shipyard) 9.5.5 Costs of Compliance The estimated costs of compliance are included in Table 9.3 In order to comply with EU water directives, the waste waters being currently generated would need to be collected and properly disposed off. The current dock and workshop practices may also be modified so as to ensure that a minimum volume of such waste waters are generated. The cost of treating such collected dockwaters is difficult to estimate in the absence of quantitative and qualitative data on such waters. However, assuming that the contaminants to be treated for would be the same as those for MD, and that a volume of approximately 500 m3 would be generated annually, the order of magnitude estimate for a treatment plant would be Lm 350,000. The required time frame for this option may be estimated to be 1-2 years. Alternatively it will be more cost-effective to ensure that dock practices will produce minimal waste waters and then to collect such waters and transfer them to MD for treatment there. The charges for such treatment may not be evaluated at this stage, but an ‘educated guess’ would be Lm10,000 per year (i.e. at a flat rate of Lm20 per m3).


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Running costs for improved housekeeping and modification of work practices to reduce the volume of waste waters generated, may not be estimated at this stage. Running costs for a whole treatment plant may amount to Lm9000 per year. The costs for monitoring to ensure compliance may amount to Lm4000 per year.

9.6 Bezzina Ship Yard Ltd. (SY3) Unfortunately, attempts to interview the management of this company did not yield any useful data on which to base any assessment and evaluation of impact of compliance. For the purpose of this study, it is therefore assumed that the operations of this company are very similar to those of Cassar Ship Repair Ltd, and that subsequently, the costs of compliance would be of the same order of magnitude.

9.7 Other Ship Yards and Maritime Related Installations Likewise, attempts to get information for further assessment from other companies failed. Therefore no separate assessment of impact of compliance may be made for Marsa Ship Building. Furthermore, it was also not possible to assess impact of compliance on the Malta Freeport. The management claimed that there are no direct marine discharges arising form this complex.

9.8 Summary of findings for the Ship Yard and Ship Repairing Sector

Marine discharges from this sector, may be discrete point sources such as those found at MD, where waste waters are led to the shoreline through a pipeline, or be of a diffuse nature, where waste waters generated through land-based activities, may ultimately end up at sea, through runoff. Both types of discharges are covered by the relevant EU water quality Directives.


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However, while the point discharges are much more easy to evaluate and assess, as well as to control, those of a diffuse nature are difficult to quantify and therefore to assess. The control of such diffuse sources is more likely to be possible through the control of the land-activities which originate them. For example, it may be possible for an authorisation system to be able to issue permits for certain land-based activities which are known to generate waste waters which may indirectly reach the marine environment, through land runoff. In the case of the ship yard and ship repairing sector, these activities may include: operations along slipways, on quays as well as within floating or fixed docks. The issuing of permits for such activities should be covered by provisions for:

a) how to collect, manage and dispose of any solid and liquid wastes generated through such land-based activities;

b) how to minimize spillages which may residues on land and which subsequently be washed off by rainwater into the sea.

Furthermore, it should be possible to control such ‘diffuse’ sources of marine discharges by controlling the use and importation of substances listed in CD 76/464/EEC or its daughter Directives. For the purpose of the present study, it was relatively easier to assess impact and cost of compliance of point sources of discharges, than of the diffuse sources. Nonetheless, special considerations were given to dock practices and operations (as reviewed in Section 9.2.2.6) for MD, which may generate diffuse marine discharges. In this case, specific recommendations were made on how to improve dock practices. Moreover, the costs for such improved practices were estimated to the fullest extent possible. The two smaller shipyards, which were included in the review, both claimed that they have no direct marine discharges. However, the wastewater generated from their docks as well as other runoff, was taken into consideration. Unfortunately, we were unable to assess activities at Marsa Ship Building and the Malta Freeport. Therefore the estimated costs indicated below, do not cover such industrial areas. To conclude, the total volume of waste waters generated by this sector amounts to approximately 8000m3 per year. Such waters probably exceed several discharge limits for various contaminants, including oil, heavy metals, organics, etc.. The required capital costs for treating such industrial waste waters range from Lm2.05 million to Lm7.73 million, depending on the compliance options to be adopted (Table 9.3). The global running costs may be estimated at approximately


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Lm 130,000 per year, while the costs to cover monitoring and reporting obligations may amount to Lm 17,000 per year. The required time frame for compliance may be up to 2 years. As indicated in Chapter 5, the time frame for compliance has been estimated in terms of the number of years required for implementation of the relevant compliance programme, which may be required, assuming that the necessary administrative decisions have been already taken and that the necessary financial and other resources would have been made already available. Furthermore, no provisions were made for undue delays in the initial phase when certain management decisions need to be taken regarding the various options of compliance to follow.


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10. IMPACT OF COMPLIANCE: OTHER INDUSTRIES

10.1 Introduction 10.1.1 Industrial Discharges into Sewers The discharge of industrial waste waters from industries into public sewers was discussed in Chapter 3. Only the more relevant points will briefly reviewed here. Most industries generate waste waters (both industrial effluents and sewage) which are discharged in the public sewers. Such discharges are controlled by Legal Notice 8/93 dealing with Sewer Discharge Control Regulations, established under the Environment Protection Act of 1991 and the Water Services Corporation Act of 1991. Council Directive 76/464/EEC requires that the authorization system take appropriate steps to stop contraventions. The administrative setup for such enforcement of discharges into sewers is already available at the Drainage Department (DD) and it is expected that all provisions will be fully enforced by the end of 2002. The feasibility for the local industry to comply with the relevant provisions controlling its wastewater discharges into sewers, will depend very much on a number of factors, as reviewed in Chapter 3.

10.2 Industrial Wastewater Discharges into the Marine Environment The present Chapter will include an assessment and evaluation of impact of compliance on some small industries which could not be easily classified with the other sectors, which have been already reviewed in previous Chapters. These include a food processing company and a pig farm, both of which have confirmed marine discharges. Furthermore, a brief account is given of an whole industrial estate from which industrial waters are currently reaching the sea.


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10.2.1 Half Far Industrial Estate (IN1) 10.2.1.1 General Description of the Estate At present, industrial waste waters being generated at Hal Far, are not being discharged into the public sewers, but are reaching a dilapidated and unused treatment plant from where, they overflow to the sea. While this is not in contravention of the present local legislation, it is highly undesirable to allow such discharge into the marine environment to continue. In fact, due to the commitment of the DD to ensure that no industrial or domestic effluents be discharged directly into the marine environment, arrangement are in hand to stop such marine discharges from Hal Far. In any case, it is also possible that the industrial effluents generated from this estate will contain contaminants which should not be discharged at sea, under the provisions of the EU water quality Directives. Hal Far Industrial Estate has currently 59 industrial units, with a total floor space of 277,495 m2. This makes it the largest current industrial estate in the Maltese Islands, in terms of floor space, (as well as in terms of total estate area: which is 1,062,624 m2). The type of industries currently available in this industrial estate is graphically presented in Figure 10.1. 10.2.1.2Generation of Waste waters No data was available for the purpose of the present study, regarding the current and expected rates of production of waste waters for this Industrial Estate. According to estimates made in 1992 (COWIconsult,1992) Hal Far Industrial Estate was expected to generate 1410m3 of waste waters per day. According to MDC, it is expected that the number of units will increase so as to almost triple the number of employees in this Estate. Evidently the volume of waste waters generated now and over the next 5 years, is expected to increase significantly . Callus and Camilleri (1997) provide a useful account of a survey they undertook on the type and quantities of wastes generated by different type of industries in Malta. From this data and survey, one may arrive to a general idea regarding the type of contaminants which may be currently present in the waste waters generated by the Hal Far Industrial Estate. For example, this survey showed that the units dealing with food, beverages and tobacco, as well as those for metals and non-metal manufacturing, produce relatively large amounts of waste waters, as well as liquid chemical wastes. The latter type of industries also produce relatively large amounts


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of spent oils. Furthermore, tanneries and units producing electronics (i.e. printed circuits) are more likely to release heavy metals and cyanides in their waste waters. For the purpose of the present study, one sample was collected from the waste waters flooding the unused treatment plant at Hal Far. The full results are presented in Chapter 4. Evidently, no conclusive observations may be made on a single sample! Nonetheless, this is the only available data and it shows presence of oils, fluorides, chloroform, as well as a range of heavy metals such as copper, nickel, chromium, lead and boron. Nitrites and phosphate levels are particularly high indicating the discharge of domestic and toilet wastes along with these industrial waste waters. 10.2.1.3Treatment Plant at Hal Far The treatment plant at Hal Far was built as part of the planned development of Hal Far which started towards the late 70s. Following its completion in 1981/82, a trial phase was carried out and it was ascertained that the plant was fully functional, and could possibly deal not only with urban waste waters but also to a certain degree with industrial waste waters. In fact the original designs incorporated both biological and physical treatment. The total cost of the plant was in the region of Lm247,000 (excluding design, planning and other professional fees), of which around Lm200,000 were for infrastructural works. However, due to the recession in the early 1980s, the development at Hal Far Industrial Estate was put on hold ( Marco, Abela, MDC, written communication dated 25th October 2000). Thus, MDC claim that for a period of time (1982-1987) the plant could not be used since little or no waste waters were being generated. During this period of non-use, the plant suffered severe vandalism, wherein it was stripped of all pumps, switch gear, dosing machines and other vital components. Since then, this plant has been left unused, while an increasing volume of waste waters are reaching the plant and subsequently finding their way to the sea in the limits of Hal Far. This illustrates the fact that compliance in practice with EU water quality Directives will not only involve the setting up of waste water treatment plants, but also their efficient management and operation. This holds both for privately owned treatment plants as well as those to be run directly or indirectly (through private partnership, etc..) by the Drainage Department or the relevant Government authority. 10.2.1.4Compliance


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The Sewage Master Plan Implementation Unit (SMPIU) plans to connect this industrial estate to the main sewer network discharging at Wied Ghammieq through B’Bugia. The sewage will be pumped to Zejtun via the existing pumping station and rising main which will be upgraded as necessary to cater for the additional flow. It is assumed that the estimated costs for this infrastructure work has been included in the estimates for the implementation of the Malta South master plan. Ing. S. Cachia of the SMPIU indicated that this situation might be regularized by 2003, provided that deadlines are met for the submission of the feasibility study for the Malta South Treatment Infrastructures upgrading to the Planning Authority, and for its subsequent approval. Therefore, in the best case scenario, it may be assumed that no additional compliance costs (other than those included for compliance by the DD) would be incurred to ensure that the marine discharges from this Industrial Estate will be discontinued. In the worst-scenario for this sector, it may be assumed that a separate water treatment plant will be required for this industrial estate at an approximate cost of Lm 0.5 million (possibly more). This treatment plant will fulfill the original plans for the Hal Far industrial Estate. The running annual costs for such a plant may be in the region of Lm 12,500. 10.2.2 Comino Pig Farm ( Koperatiiva ta’ min irabbi l-Majjali Ltd.) (IN2)

10.2.2.1 Profile KIM controls the entire pig industry in Malta. At its Comino Pig Farm, it breeds and rears pigs for the local industry. The farm was partly financed by FAO and was originally designed for a maximum capacity of 6000 pigs. It includes a water treatment plant which was never in use and which is now dilapidated (with many engineering items removed). On the farm there are on the average, approximately 700 pigs at a time. The management claims that farm is not run on a competitive basis, and it is usually running at a loss. It started operation in 1980 and has been operating under the present management since 1997. The Comino Pig Farm employs 4 FT staff. No. of FT employees: The overall turnover for the whole KIM commercial activities is approximately Lm 12 million.


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10.2.2.2Generation of Waste waters Most of the liquid wastes are generated from pig and pen washings. This includes a large proportion of pig manure. Water is obtained from a bore hole. A number of rain reservoirs are available to store drinking water. Approximately 1000 gallons (4.5 m3) of washing waters are used daily. This washing water is led to a settling reservoir, where most of the settable solids are removed. From here the wash water moves through a cascade of three other settling tanks by gravity. Eventually the water reaches the rocky shore, from where it is led to the sea (not through any pipe or culvert). The actual volume reaching the sea is unknown. It may be estimated to be approx. 1000 m3 to 2500m3 per year (not taking into account the rain run off). Often, a visible plume results from this discharge (see Figure 10.2). No monitoring of the liquid wastes is carried out. Solid sludges are reused as fertilizers. 6 tonnes of Pig Starter Food and 2 tonnes of Sow Pellets are consumed annually on this pig farm. It is worthwhile to note that Pig Starter Food is know to contain a significant amount of copper as a growth stimulant. (approx. 10 ppm) KIM Ltd. wishes to increase the productivity of the farm at least to 2300 pigs. This could increase the volume of waste waters discharged into the sea to approx. 2500 m3 per year. When this Pig Farm was built, it originally included a wastewater treatment plant. Due to a number of reasons, this treatment plant was never fully operational and has been unused for a number of years. It is in a dilapidated state (similar to that at Hal Far). The unused treatment plant was originally built in 1981 and commissioned in 1983 at an approximate 1983 price of Lm0.2m million. Its original design was based on the activated sludge method with mechanical surface aerators, and the design capacity was 43 m3/day. According to Mr. Sammy Vella (a former manager of this Pig Farm), the main reason for the fact that this treatment plant was never fully successful, was that it depended mainly on biological treatment, and that this was ineffective, due to the relatively high levels of disinfectants that are used on the farm, and that subsequently reach the biological activated sludge. COWIconsults had prepared detailed proposals on how to render this treatment plant operational again as well as upgrade it. Unfortunately, no details of costings were available.


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10.2.2.3 Quality of Marine Discharges Evidently, the quality of marine discharges originating from this installation is bound to fluctuate significantly depending on the level of production and type of operation which is ongoing. Monitoring of water quality for the floating fish cages located in the South Comino Channel, included a station next to the Pig Farm discharge point. Levels of nutrients, chlorophyll and oxygen were never significantly different from other stations being monitored. Occasionally, elevated levels of faecal streptococci were however recorded. For the purpose of the present study, one sample was analyzed for the various potential relevant contaminants. Such analysis showed that the levels of zinc and copper where close, though below the thresholds. Furthermore, the levels of nitrates, nitrites and phosphates were exceedingly high. Suspended solids and BOD5 are also bound to be very high. 10.2.2.4 Compliance Costs Evidently, the present marine discharge does not comply with several regulatory threshold limits. A proper wastewater treatment plant (probably of improved performance than that proposed by COWIconsult) which would ensure full compliance with the set thresholds for organic matter, nutrients, as well as for zinc and copper, will need to be constructed. It is very difficult at this stage, to estimate the capital costs involved for such a treatment plant. A tentative, order of magnitude estimate may amount to Lm 500,000 to Lm 1 million. Running costs may amount to approximately Lm12,000 annual, while costs for monitoring and reporting obligations may amount to Lm2000. No cost estimates may be made for the disposal of the resultant sludge. COWIconsult had originally proposed that these sludge will be used for agricultural lands on Comino.

10.2.3 Vernon’s Food (IN3)


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10.2.3.1 Company Profile Vernon’s Food Ltd. is a relatively small company, mostly involved in tomato processing and packaging. It regularly employs 2 FT staff, but a larger number of casual workers (maximum 22) depending on the time of year (and production cycle). No details regarding the annual turnover were made available by its top management. 10.2.3.2 Discharge of cooling waters Water effluents arise from the cooling of the condensor unit required for the vacuum line used for tomato processing at the Marsa plant. Seawater is used as cooling water, which is taken up from the same Marsa Creek, (near Bezzina Shipyard). It is discharged at the rate of 90m3 per hour. This is discharged onshore at the Jetty’s Wharf. The time period of marine discharge is limited to approximately 50 days per year. Hypochlorite is added to the seawater flow to disinfect as an antifouling agent. This is particularly important due to the fact that most of the time the area is exposed to sewage pollution from overflow from the Marsa Pumping Station. The temperature of the discharged water ranges from 40o to 45o C. No on-line monitoring is available. Manual monitoring is carried out to assess the levels of chlorine. No treatment is carried out. No modifications or production expansions are envisaged. 10.2.3.3 Compliance Cost Based on the current data available, it is quite likely that except for thermal discharges, no significant contaminants in these waste waters need to be addressed to ensure compliance. However, in the worst case scenario, if the thermal discharges from this company will exceed the upper permissible thermal limits to be set in the forthcoming LN of EPD to control marine discharges, than an air cooling plant will need to be installed. No information on the likely costs of such a plant were available to the


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present consultant. An ‘order of magnitude’ estimate may put this cost at Lm20,000. It is worthwhile to record this company’s top management reaction, when asked whether they would be ready to comply with the relevant EU water quality Directives controlling marine discharges. They argued that as long as the governmental authorities themselves remain by far the biggest polluters in the area (from the Marsa Pumping Station Sewage overflow) they see no reason why their small discharge could make a difference on the environment. This is a recurrent argument raised by a number of SMEs interviewed during the present study. It shows how SMEs and micro-industry often perceive environmental legislation as nothing but an additional, and often unfair burden they are made to carry by the competent authorities. They are often quick to point out that such a burden will render them uncompetitive due to the capital costs involved in ensuring compliance. Some of them claim that they will be willing to abide with the regulations only if the government agencies themselves or their competitors (including from EU Member States), likewise comply with such regulations. It is recommended that the competent authorities will be sensitive to such perceptions and that while enforcing strict compliance with all regulations, they will have make big efforts to educate their ‘clients’ about the need and benefits of such compliance. 10.2.4 Other Industries During the present study, we infrequently came across cases of specific industrial establishments, who either directly refused to provide the necessary information, or who achieved the same result by procrastinating in providing us with an appointment to be interviewed, or worst still, by failing to turn up for such appointment. Fortunately, such cases were a very small minority and most industries interviewed, cooperated fully with the present consultants and their work team. Nonetheless, we feel it is our duty to report that due to this problem, we could not present a full and comprehensive assessment for all direct or indirect marine discharges. For example, our attempts to interview wineries located in Marsa, proved to be unsuccessful. It is quite likely that such wineries normally discharge their waste waters directly into sewers and not into the sea. However, we have evidence to suggest that marine spillage of waste waters from at least one of such wineries did occur in Marsa during the course of the present study. This occurrence may be considered as an accidental one, but such incidents will also fall under the


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provisions of the relevant EU water Directives. Compliance costs for such illegal discharges may not be estimated at this stage. Rinella Film Facilities owns a few large water basins which are filled with seawater and which are regularly used for film productions. The seawater is pumped from the vicinity of the main sewage outfall at Wied Ghammieq and therefore it is often contaminated by bacteriological agents. In order to protect against the associated health risks, such seawater is dosed with chlorine, at an unspecified level Such waters are discharged back into the sea when filming is over. As such this point discharge will fall under the provisions of EU water quality Directives, covering point source marine discharges. No proper assessment of impact of compliance is possible, due to insufficient data available. Nonetheless, it is most likely that no problem of compliance will exist for such a discharge. 10.3 Summary of findings for Other Industries Marine discharges from this sector, may be discrete point sources such as those found at MD, where waste waters are led to the shoreline through a pipeline, or be of a diffuse nature, where waste waters generated through land-based activities, may ultimately end up at sea, through runoff. Both types of discharges are covered by the relevant EU water quality Directives. Such diffuse marine discharges and the possible manner to control them , have been discussed in the previous Chapter. In the present Chapter, three present point sources of marine discharges of waters were assessed. The required capital costs for treating such waters arising from industrial or other premises, range from Lm0.5 million to Lm1.52 million, depending on the compliance options to be adopted (See Table 10.1). The global running costs may be estimated at approximately Lm Lm14,000 to Lm39,500 per year, while the costs to cover monitoring and reporting obligations may amount to Lm 2,200 per year. The required time frame for compliance may be up to 2 years. As indicated in Chapter 5, the time frame for compliance has been estimated in terms of the number of years required for implementation of the relevant compliance programme, which may be required, assuming that the necessary administrative decisions have been already taken and that the necessary financial and other resources would have been made already available. Furthermore, no provisions were made for undue delays in the initial phase when certain management decisions need to be taken regarding the various options of compliance to follow.


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References Callus, J., and Camilleri R., 1997. Pollution Prevention. A tool in the Management of Industrial Waste in Malta. Unpublished Dissertation B.Sc. (Hons) University of Malta. COWIconsult. 1992. Ministry for Development of Infrastructure, Malta. Sewage Master Plan for Malta and Gozo. Working Papers 1 and 2.


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11. IMPACT OF COMPLIANCE: HOTELS AND RECREATION ESTABLISHMENTS

11.1 Introduction: Tourism Development Tourism is considered to be a key sector in the economic development of the Maltese Islands. Since 1959 tourist arrivals have grown from a mere 12,500 to 1,182,240 in 1998. Receipts for the period 1959 - 1997, grew from around Lm 750,000 to over Lm249 million. Tourism in 1997 contributed around 22.9% to the export of goods and services and employs a total of 9445 or 6.9% of the total gainfully occupied in hotels and catering establishments. The number of tourists increased by 160,442 or 15% over the period 1995-1999. Gross foreign exchange earnings from the sector reached an estimated Lm207.1m in the first nine months of 1999 increasing by about 7% on the same period in 1998. During the latter period, tourism generated 199,362 full time equivalents jobs (The Economic Impact of Tourism p46). This reflects the total number of full time working an average of forty hours per week plus the total number of part-time equivalents i.e. two part-time working twenty hours per week are equivalent to one full time employee. Jobs were generated in accommodation, catering, car hire air traffic as well as in handling agent institutions such as NTOM/MTA, MIA and tourist guides. It also includes the tourist related proportion of those working in retail outlets e.g.. clothes shops, recreational and cultural spots (e.g. museums) and public transport. Tourism expenditure is estimated at Lm319.49m. This implies an employment multiplier of 60.60. Thus for every Lm1 million of tourism expenditure 60.60 full time equivalent jobs are created. Tourist development, particularly in the form of tourist accommodation developments, has been heavily concentrated in specific localities and, although the pattern of tourist arrivals has spread into the shoulder months (i.e. March - June & October), nonetheless tourist arrivals still peak during the summer months (July - September). The development of tourism and the future success of this sector depends particularly on the level of attractiveness of a destination. If this attractiveness is lost then the destination is likely to suffer and tourists will no longer be attracted to that destination. Therefore, tourism depends on the quality of the natural and cultural environment for its continued success.

The monthly pattern of tourist arrivals is such that most of the tourists are coming to the Islands during the summer period i.e. July to September. Although recent years have seen a gradual spread of arrivals into the shoulder months, nonetheless, the seasonality pattern has shown minimal changes over the last ten years. For example, for 1998, 36.4 % of tourist arrivals were for summer, while only 19% of arrivals were for Winter.


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11.2 Tourism, Hotels and Tourist Related Recreation

Mallia et al. (1999) reviewed the environmental aspects of tourism in Malta. There has been an ongoing development in the number of hotels for the tourist industry, over the past two decades. The location of such hotels (and other touristic accommodations) is quite unevenly distributed so that 32.4% of the beds available are currently (for 1998) located in Bugibba and Qawra, while St. Julian’s and Sliema areas carry 31% of such available beds.

Over the period 1993 to 1997, the Planning Authority approved an average of 2.4 major hotel units per year. This trend has still persisted since then. The Sewerage Master Plan for Malta and Gozo (COWIconsult, 1992)estimated that each tourist uses on average 235 l of water each day. Using this estimate the annual demand for water supply in 1998 was around 2.66 million m3. It is important to note that the figure used is an average and therefore it is very likely that the daily demand during summer is much higher, and, therefore, since most tourists come during the summer months the demand for water for tourism use may be somewhat higher, possibly even close to 3 million m3. In 1998 the total amount of water consumed was 36,838,109.7m3 (Water Services Corporation). Therefore, water consumption for tourism purposes constituted 7.2% of total water consumed. During the summer months, as indicated, the percentage would be higher. Most of the water used for tourism purposes is disposed untreated into the sea through the main sewage outfalls. It is estimated that 80% of water used is disposed of as sewage, according to the Sewage Master Plan. Therefore, total amount of sewage produced as a result of tourist activity is estimated at around 2.13 million m3. In 1992 (COWIconsult, 1992) four coastal hotels and touristic accommodations (Danish Hotel Complex, Ramla Bay Hotel, Salina Bay Hotel and Ghajn Tuffieha Hotel) were equipped with sewage treatment plants. Since then, other hotels have become equipped with sewage treatment plants, e.g. the new Hilton Hotel. However, besides such discharges into public sewers, a number of these hotels which are located along the coast, have direct marine discharges to be reviewed in the present chapter. For the purpose of the present report, a letter requesting information was sent to all coastal hotels. Of these 10 hotels answered confirming that they discharge directly into the marine environment. No data is available for hotels from Gozo. Furthermore, there are bound to be other hotels which discharge into the marine


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environment, and for which due to lack of time, or other reasons, no data is currently available. Nonetheless, the results of the assessment on 10 hotels (and 1 marine attraction) should serve as a representative analysis for the whole sector. 11.3 Assessment of Marine Discharges by Hotels A summary of results and data collected from 10 hotels and one marine attraction center are presented in Table 11.1. 11.3.1 Comino Hotel (HR3) This hotel located on Comino, employs 80 FT and from 15 to 20 PT staff. At present the sewage as well as other wastewaters generated from this hotel are discharged untreated directly into the sea. This discharge is through a submarine pipe extending 25 m offshore, off Santa Maria Bay. The sewage is not undergoing any form of treatment prior to discharge. A septic tank is not presently in use. COWIconsult (1992) report that the resulting plume at the discharge point may have a negative impact on water quality to swimmers and divers alike. These consultants had proposed a treatment plant for this hotel, but presented no costing. Other marine discharge streams originate from air-conditioning chillers and RO plants (brine). The total estimated volume of marine discharges generated from this hotel and annually discharged into the marine environment is 55,000 m3. The management of the hotel is fully aware that they will need to invest in a wastewater treatment plant in order to come to comply with current and future regulations. They estimate a capital sum of Lm60,000 would be required for such a plant. This may be an under-estimate, and in a worst-case scenario, this capital sum of investment for a new treatment plant may be up to Lm200,000. Estimated recurrent costs are shown in Table 11.1.

11.3.2 Other Coastal Hotels


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Nine other hotels had confirmed direct marine discharges and are listed in Table 11.1 None of these hotels discharge untreated sewage into the sea. Three main types of discharge stream have been identified from these hotels, which are discharged at sea. These are:

a) Cooling waters for air-conditioning chiller units; b) Brine produced from reverse osmosis desalination plants c) Swimming Pool waters and backwash waters

Several of the hotels use cooling waters pumped from shoreline boreholes. Seawater is pumped into a heat exchanger, which in turn is re-circulates freshwater through the chillers. The heat exchanger is sometimes flushed with copper sulphate for cleaning. These cooling waters are discharged at temperatures which are in the region of 24o C to 34oC. Pool waters are regularly chlorinated (1–2 ppm) and more often monitored for bacteriological quality. Sometimes pool backwash waters (which normally contain appreciable amounts of suspended solids, are discharged into the sewers. Often the brine waters from RO plants are treated with 3.5 ppm Hypersperse AF200. Chemicals used to control pH of incoming water for RO plants include: hypochloride and caustic soda. Membrane cleaners more often used such as citric acid, polymethylvinyl ether, tannic acid, alkaline detergents, polyacrylic acid and even formaldehyde. Most of the chemical additives which may find their way in the various marine discharge streams being discharged at sea, are not dangerous or are found only in trace amounts. While the use of such chemicals as formaldehyde should be discouraged an substitutes should be used instead (as is currently done by the Malta Desalination Services Ltd.), they are probably found at very low concentrations in such discharge streams. Thermal discharges from cooling waters may be relatively high at times, depending on operational conditions of the air conditioning. Nonetheless, it is unlikely that the present practices would not be in compliance with the EU water discharges directives.


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There may be some problem with suspended solids in waste streams such as pool backwash water. However, these could easily be controlled, given the relatively small weekly volumes of such discharge waters being generated. Therefore, in spite of the relatively large volumes of waters discharged into the marine environment ( an estimate global volume of 1.5 million m3 from 10 hotels) it is quite likely that for most coastal hotels reviewed above (except for Comino Hotel) there will be no additional costs of compliance in terms of capital expenditure or running costs of additional treatment plants. Some annual costs to cover monitoring and reporting obligations may be incurred. 11.3.3 Mediterraneo , Marine Land Ltd. (HR11) This marine attraction park located at Bahar ic-Caghaq holds a number of marine organisms including dolphins. The installation obtains its seawater from two boreholes, and this is then supplied to two pools and two aquaria. The rate of exchange of seawater is such so as to change the volume of such reservoirs 6 times every 24 hours. Seawater and any aquaria/tank washings, are then discharged into the sea. Some bacteriological monitoring is carried out for the inflow water. No chemical additives are used. Animals are fed on natural frozen food which is imported specifically for this purpose. While it is possible to have occasional elevated levels of suspended solids and possibly nutrients in these discharge waters, the levels are not expected to be high and would be in full compliance with the EU water discharge Directives. 11.3.4 Other Discharges During the course of this study, some marine discharges were identified which could not be properly assessed, due to a number of reasons, but especially due to time constraints. One such example is a discharge point found at Balluta Bay (on the side of the water polo pitch). Unfortunately repeated attempts on the part of the work team to identify the source of such a discharge, proved futile. It is quite probable that this marine discharge is originating from the cooling system of a nearby block of apartments, which have a single outlet for all air-conditioning water.


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References Mallia, A. Brigulio, M., Ellul,A.E. and Formosa,S. 1999. Population, Tourism, Land-Use and Non-Renewable Resources. Report prepared as part of “State of the Environment Report for Malta, 1998” commissioned by the Environment Protection Department, Ministry of Education; Valletta, Malta: Malta Council for Science and Technology; 105 pp. Cowiconsult, 1992. Sewerage Master Plan. Ministry for Development of Infrastructure.


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12. IMPACT OF COMPLIANCE: MARINE DISCHARGES FROM PUBLIC SEWERS.

12.1 Introduction The generation and disposal of sewage, as well as the local environmental impacts of untreated sewage discharges have been reviewed by Axiak et al. (1999). Only the major relevant features will be reviewed here. The sewerage system on the island of Malta collects both domestic and industrial wastes, as well as some storm water runoff, and consists of two main networks (Malta Structure Plan, 1990). The largest of these networks services the southern part of the island and most of which converges at the Marsa Sewage Pumping Station, from where it is pumped either to the submarine sewage outfall at Wied Ghammieq, or to the only sewage treatment plant, at Sant Antnin (Malta Structure Plan, 1990). Currently, the Sant Antnin Plant treats approximately 20% of the wastewater produced on the island (COWIconsult, 1992). The rest is disposed

untreated at Wied Ghammieq. This may be estimated to be 19.7 million m3/year (Cstaglia, 1996).

Sewage effluents are discharged into the marine environment via two types of point discharges:

a) Official sewage outfalls, discharging continuously; b) Sewage Overflows, mainly from pumping stations discharging in

emergency situations. 12.2 Sewage Outfalls The Wied Ghammieq outfall (SG1) is situated on the north-eastern coast of Malta. Close to the coastal settlement of Xghajra. The sewage is released into the sea via a 716m long submarine pipeline, running at right angles to the coastline, the terminal diffuser being at a depth of some 36m (COWIconsult, 1992). When operating normally, the Wied Ghammieq pumping station discharges raw

sewage through the outfall at an average rate of 58,000 m3/day. This value varies with season and is less when the sewage treatment plant at Sant Antnin is in operation. The Wied Ghammieq submarine outfall is designed to produce an immediate dilution of 1:200 at the point of discharge, and a further dilution of 1:1000 as the freshwater plume rises to the surface above the point of discharge, under calm sea conditions (Rizzo, 1996). However, frequent rupture of the pipeline


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along its submerged section results in undiffused sewage being discharged at a distance much closer to the shore than actually intended. In such cases, sewage emerges in a jet with minimal dilution and is carried by surface currents, usually in an easterly or south-easterly direction, since the prevailing winds are westerly and north-westerly. The northern Malta catchment of wastewater is conveyed to two outfalls on the western coast, at Mellieha (Anchor Bay) (SG3) and ic-Cumnija (SG2). Both outfalls discharge approximately 4.3 million m3 of effluents per year, at the shoreline. In Gozo, almost 90% of all wastewater is discharged through a submarine outfall at Ras il-Hobz (SG4). Another two outfalls are located on the northern coast at Wied Mielah (SG5) and in San Blas (SG6). These outfalls discharge minor quantities of wastewater. At Wied il-Mielah, it was intended to convey wastewaters through a septic tank upstream to the outfall, however this is presently out of use. In San Blas, wastewater from Nadur is discharged through a short pipe.

In 1992, the total amount of wastewater discharged into the marine environment was estimated to be 23.2 million m3 per year. (COWIconsult, 1992). More recent estimates (Castaglia, 1996), put this figure of annual volume of discharged effluents at 25.8 million m3 . The sewerage system is presently being upgraded. Within the next few years, it is expected that all domestic and industrial wastes will be treated to secondary level and that the effluents will be discharged into the marine environment through submarine outfalls equipped with proper diffusers. A Storm Water Master Plan is also presently being implemented to make full and efficient use of storm water and to prevent overloading of the sewerage system which would have negative environmental impacts. The number of sewage outfalls will be reduced to one in Gozo (Ras il-Hobz) and two in Malta (Wied Ghammieq and Cumnija).

12.3 Sewage Overflows (Emergency Discharges) (SGe) A number of coastal sewerage pumping stations are required to ensure that the generated wastewaters in a given locality reaches the main sewers, which eventually lead to the major outfalls or to the Sant Antnin Water Treatment Plant. These coastal sewage pumping stations are generally equipped with an overflow system, which leads sewage into the sea, in case of an emergency. Such emergencies usually include: pump failures; maintenance; power cuts and flooding


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with rain storm waters. All these pumping stations are potentially marine discharge points, and as such are being included in the map for marine discharge points (ANNEX 5) Some pumping stations apparently have recurrent operational problems and to a certain extent may be considered as semi-permanent discharges, rather than emergency discharges. A case in point is that of Marsa Pumping Station which was discharging raw sewage into inner Marsa for most of the period under study (August-September). The resultant quality of water within the area under its influence was extremely degraded. Furthermore, this discharge should be considered as a potential health hazard to the many workers who are employed in various industries and companies within this locality: such as those of Cassar and Bezzina shipyards, the Marsa Power Station, Vernon Food Ltd., the two wineries, etc.

12.4 Wastewater Composition Wastewater effluents in Malta have been described as having a high organic load when compared to that of other regions. This is mainly due to the discharge into the municipal sewers of untreated agricultural and animal husbandry wastes. This fact, in conjunction with the relatively low water consumption in Malta, render the local sewage more concentrated in organic content. There is very limited information regarding the chemical composition of sewage and resultant wastewaters produced in Malta. COWIconsult (1992) had reviewed data available until 1992. This was mostly based on results generated through the MEDPOL monitoring programme (Phase 1). More recently, a LIFE funded project (Environment Protection Department, 1999) produced some quantitative data for the major sewage outfalls during the period. The monitoring was undertaken during two 8-week periods: August September 1997; and January-February 1998. For the purpose of the present report, samples were taken from the main sewage outfalls for three consecutive days, and analyzed as indicated in Chapter 4. A synopsis of the results is presented in Table 12.1, along with data for the LIFE project. Evidently, insufficient data is available to make a definite assessment of the chemical quality of such discharges. Nonetheless, the main features of this data will be reviewed hereunder. Organotins evidently feature quite prominently in all outfalls, indicating that the absence of control over their use as antifoulings, through local legislation, is having a negative impact. Sewage from the Cumnija outfall generally had the lowest values for organotins.


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The highest levels of petroleum hydrocarbons were found in the main outfall at Wied Ghammieq, though comparable results were also found in Ras il-Hobz. Sewage from Ras il-Hobz carried surprisingly high values for cyanides, when compared to the other outfalls. On the other hand Cumnija wastewaters carried the highest levels of fluorides. Of all the organics analyzed for, perchloroethylene and chloroform featured more prominently. This may be explained by a number of factors, including the relative stability of the respective compounds. No significant differences in such levels were found between the three outfalls. Furthermore, such levels were relatively low. With respect to levels of heavy metals, COWIconsult (1992) had reported that such levels were relatively low and indicative of absence of ‘severe industrial loads’. The heavy metals which featured most prominently in all the sewage outfalls during the present study, were copper and nickel. These metals also featured prominently in the data collected in 1990-91 and reviewed by COWIconsult (1992). On the other hand, lower levels for lead and other metals were reported in the present study. The levels of nutrients were relatively high and typical to those normally found in raw sewage. The levels of BOD5 reported recently were comparable to those reported in 1988-1990 by COWIconsult. Evidently, the current practice of discharging untreated sewage into the marine environment is not in compliance with the relevant EU water quality Directives.

12.5 Wastewater Treatment At present we have a single sewage treatment plant which has been recently upgraded to treat 17000 m3 per day. The treated waters are used for agriculture (with requirements fluctuating seasonally) and for industry. This plant has been commissioned to an Italian firm who was responsible for its upgrading and now is responsible for its operation for the next few years. A consultancy contract has been issued for the formulation of a plan with the presentation of alternative proposals including treatment facilities which might not be of a centralized nature. One (or possibly more) other treatment plant is planned for the southern region in Malta. This will treat up to 58,000 m3 per day and it is most likely that this production will exceed the present industrial and agricultural demands. It is also likely that this plant will be sufficiently advanced so as to


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produce water of high quality which could be used to recharge our aquifers. New disinfection techniques alternative to chlorination, are being considered. Other treatment plants are planned for ic-Cumnija (max. production: 7500 m3 per day) and Ras il-Hobz, Gozo (max production: 6500 m3 per day). These two relatively small plants will produce water mainly for agricultural use. It is hoped that plans will be finalized in the near future through a consultancy contract for the North of Malta which is currently in progress.

Axiak et al. (1999) reviewed the current operations of the Sant Antnin Sewage Treatment Plant and identified a number of administrative and technical problems which need to be solved. The need was felt for better coordination in the administration and technical operations of such plants. All the Government entities as well as the private and public sectors (as represented by constituted bodies and local councils) must be actively involved in such coordination. The SAWTP plant which has been recently upgraded is able to produce a maximum of 17000m3 per day. At least for its first year of operation, the maximum production never exceeded 9000m3 per day and this usually varied from 2000 to 8000m3 per day. This represents only 12 to 47% of maximum expected output. The demand for treated water fluctuates with time of year and is at a maximum during summer. During this period, the present plant was not capable of satisfying such a level of demand, at least for 1998-1999. A number of problems may be have lead to this unsatisfactory situation. Foremost amongst these would be the sudden and unpredictable fluctuations in the rate of wastewater reaching the plant for treatment. This in turn is mostly due to: (i) Low pumping rates from Marsa Pumping station or other stations (40% of

the time); (ii) Power failures; (iii) Mechanical blockage of input screening section due to solid wastes in

sewers. There is an evident need to upgrade the pumping stations upstream of the plant. Moreover, all modifications or future developments in the sewerage system needs to take into account the requirements of such a treatment plant, as well as of the future plants currently being planned. The supply of energy also needs to be stabilized and rendered more adequate.


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Agricultural produce and wastes including animal waste, and dead carcasses are causing most of the mechanical blockages of the intake section. Surprisingly enough, pig waste (and poultry) feature prominently in such waste. It is evident that this is due to illegal dumping of such waste into the sewer inspection manholes (many cases are reported during the weekends). 12.6 Disposal of Activated Sludge The SAWTP plant is producing a significant amount of activated sludge which is potentially enriched in heavy metals and other contaminants. This sludge is presently being discharged into the marine environment (through the Wied Ghammieq submarine outfall). This essentially means that the major benefit being derived from the SAWTP is that of waste water reuse, and not of environmental protection from sewage discharge into the marine environment. The setting up of additional sewage treatment plants will necessarily lead to the production of bigger volumes of activated sludge. Therefore there is urgent need to invest in treatment facilities capable of adequately treating such activated sludge. No data was available on the volumes and rates of production of activated sludge from this plant. The discharge of such sludge into the marine environment is not in compliance with the EU Directives. 12.7 Compliance The total annual volume of waste waters being discharged from the official sewage outfalls of the Drainage Department is estimated to be 25.8 million m3. Details about the implementation of the Sewerage Master Plan were provided by Ing. S. Cachia (written communication dated 9th October 2000). The DD has confirmed that any resultant discharges into the marine environment, which may arise directly from the treatment of sewage or from the treatment of sludge, will be in full conformity with the relevant EU Directives. 12.7.1 Malta North and Malta South Plans


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The Sewerage Master Plan Implementation Unit SMPIU has issued two tenders for the provision of consultancy services relating to the Malta, Northern and Southern catchments, respectively, such that the necessary transmission main/s, pumping station/s, sewage treatment/s plant/s and outfall/s are defined and sited and the problems outlined in the Master Plan itself resolved in the proposed schemes. For the Northern catchment, a series of alternative proposals were formulated and the resulting matrix of alternatives submitted to the Planning Authority. Once a selection is affected, a detailed EIS on the same will be submitted for approval to the Planning Authority follow which the SMPIU will proceed with full design and implementation. Related studies and designs are expected to be completed by 2001. The consultancy for the South of Malta will perform on the same lines, with designs expected to be ready by the end of 2001, beginning of 2002. The consultants will be responsible for outlining methods to identify the potential of reuse of the treated waters for agricultural and industrial purposes. Furthermore, they are expected to supervise works during the construction phase of such treatment plants. The Malta North and Malta South sewage treatment infrastructure is expected to be set up and fully operational in compliance with EU Directives, by 2005.

12.7.2 Gozo Plans The SMPIU has established the site for the construction of a sewage treatment plant in the vicinity of Ras il-Hobz, sewage outfall. This plant should be constructed by 2003 at the estimated cost of Lm2.5 million. Moreover it is the intention of the SMPIU to phase out the sewage outfalls at San Blas and Wied il-Mielah, by redirecting these discharges to Ras il-Hobz. This diversion of sewage will require an approximate cost of Lm 2.1 million. 12.7.3 Treatment Technology to be Adopted The treatment technology to be adopted is the activated sludge method utilizing extended aeration and final settlement. The predicted quality of wastewater will be in line with the limit values stipulated in the EC Directive 91/271/EEC. The parameters for treated waters to be discharged at sea will include:


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BOD5 25 mg/l Suspended Solids 35 mg/l Ammonia-Nitrogen 2 mg/l Furthermore, such treated wastewaters will need to comply with the maximum permissible limit values for marine discharges as stipulated in the forthcoming LN of the EPD controlling discharges to the marine environment. 12.7.4 Treatment and Disposal of Sludge Currently, sludge produced from the SAWTP is being discharged at sea. As already pointed out, this is not in compliance with the relevant EU water quality Directives. The DD has confirmed that such sludge will no longer be discharged at sea. Assuming a 20% dry solid content, the estimated yearly amounts of sewage sludge to be generated in Malta and Gozo by the year 2005, are as follows: Wied Ghammieq 25,500 m3 Cumnija 3,400 m3 Gozo 2,300 m3 No details are available regarding the current and future amounts of treatment sludge which are or will be produced by 2005, from the SAWTP. The consultants responsible for the Malta, Northern and Southern catchments, will also be required to propose a Waste Management Plan to handle the sludge produced by the treatment plants. It is assumed that the such a Waste Management Plan will consider all treatment sludge produced, including that of SAWTP. The actual treatment of sludge and its eventual disposal is still under consideration. However according to Ing Stefan Cachia, this will involve pre-thickening, anaerobic digestion, post-thickening and dewatering, for application to agricultural land. In a recent report (European Commission, 1998) assessing the implementation of the urban water Council Directive, it was estimated that the quantity of sludge produced by Member States as a result of its implementation would increase by at least 50% from 1992 to 2005. In general, the Commission considers that re-use of the sludge should be encouraged since it represents, a long-term solution provided that the quality of the sludge re-used is compatible with public health and environmental protection requirements.


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The data on the quality of sludge which is currently being produced by the SAWTP is very limited, and was not made available for the purpose of the present study. In view of the low level of compliance with the LN8/93 regarding the disposal of industrial liquid wastes into the sewers, there is a possibility that the levels of heavy metals and other potential contaminants may be significantly high in the resultant treatment sludge. This may restrict the use of such sludge for application to agricultural land. Evidently, a more thorough study on this aspect of sludge production and treatment will need to be made. 12.7.5 Compliance Costs The compliance costs to be incurred by the DD to ensure that sewerage discharges will be in full compliance with EU Directives have been globally estimated to be about Lm 38 million (Arch. A. Abela, Director DD, written communication dated 18 September 2000). No breakdown for such cost estimates is available. These costs will cover: administrative upgrading, institutional strengthening, monitoring and infrastructural expenditures. They do not include consultancy fees and sludge treatment. 12.7.6 Cost of Investment in the Sewage Master Plan per population Equivalent According to a report prepared by the Working Group on Water Quality to discuss and advise on the Transposition, adoption and implementation of the E.U. Environmental Acquis, the capital costs required for the implementation of the Sewerage Master Plan will be about Lm27.29 million. This sum is equivalent to 58.908m Euro at 1995 prices. If the population equivalent is estimated at 420,959, this implies that the average cost for Malta is 139.93 EUROS per population equivalent. In a recent report by the Euopean Commission (1998), it was estimated that the amount of investments per population equivalent for Member States, required for collection and treatment of urban waste waters ranged from 112 EUROs per population equivalent in Greece and 602 EUROs in Germany. The cost for the 14 Member States as a whole is 307 EUROs per population equivalent. If we assume that these investments are paid over thirteen years, the average investment cost at constant 1995 prices is 10.764 EUROS per year per population equivalent. This figure, which is exclusive of financial cost and depreciation, is lower than the average cost for the 14 Member States as a whole.


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If Malta joins the EU, it may qualify for aid from the Commission towards such investments under the Structural funds and the Cohesion Funds. Investments carried out in 1995-1999 under the Cohesion Funds in the environment sector were given priority rating. In fact about 30% of the total Spanish investments were co-financed by these funds. References Axiak,V., Gauci,V., Sammut, J., Pace,L., Axiak, M. 1999. Solid and Liquid Wastes. Report prepared as part of the ‘State of the Environment Report for Malta 1998’ commissioned by the Environment Protection Department, Government of Malta; Valletta, Malta: Malta Council for Science and Technology; 51pp. Castaglia s.p.a. 1996. Volume 1: Marine Pollution Sources. Malta Civil Protection Master Plan (Marine Antipollution Scheme). Unpublished report. Cowiconsult, 1992. Sewerage Master Plan. Ministry for Development of Infrastructure. Environment Protection Department 1999. LIFE Project TCY96/M/06. Unpublished Report. Evaluation of Pollution Risk and Prevention Measures in Malta. 105pp. European Commission. 1998. Implementation of Council Directive 91/271/EEC of 21 May 1991 concerning urban waste water treatment, as amended by Commission Directive 98/15/EC of 27 February 1998.


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13. ASSESSING IMPACT AND CONTROL OF NON-POINT DISCHARGES

13.1 Introduction Throughout the present report, several references have been made to the issue of non-point diffuse sources of discharges of waste waters into the marine environment. The present Chapter discusses some of the more relevant issues for such diffuse sources. A more detailed consideration of this subject goes beyond the scope and terms of reference of this study. Such discharges which may be located both along the coastline, as well as inland, may lead to a significant contribution of the pollution load reaching the marine environment. Indeed, in some cases such as nutrient loads, these sources may be equally significant as point sources of discharge. It is extremely difficult to assess the pollution loads from such diffuse sources. When such sources are more defined than others and when their geographical location is known, such an assessment may be less difficult to undertake. However in other cases, such as car traffic (diffuse source of heavy metal pollution), a detailed and quantitative assessment is almost impossible to perform. Furthermore, since such diffuse sources may be located some distance away from the coastline, it is difficult to prove that the pollution being detected at sea is in fact necessarily the result of such inland sources. This is because there are various factors which will affect the actual proportion of pollution loads which reach the sea from such inland sources, including: land topography and drainage areas, pattern of land-use (including location of roads), meteorological factors as well as rock and soil types. Very limited information is available on such non-point sources of pollution in Malta. Castalgia (1996) made a preliminary and very useful assessment based mostly on agricultural and animal husbandry sources. 13.2 Agricultural practices Castaglia (1996), identified the more commonly used pesticides in Malta. The brand names include: Carbaryl, Diquat, Pyrethrins and Zineb. Furthermore, the same report estimated the pesticide runoff loads from the various localities (in kilograms per year) assuming a 1% loss in runoff. These estimates indicate that the Western Region of Malta had the highest runoff load for pesticides. This data is


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presented graphically in Figure 13.1, which also includes the location of the island’s major watercourses, engineered works along valleys and the predicted location of significant runoffs. The same report, makes estimates for the nitrates and phosphates loads which are expected to arise for the application of fertilizers in different agricultural localities. Based on 1995 data, it was estimated that the total nitrate load and phosphate load reaching the marine environment from runoff amount to 143 tonnes and 179 tonnes respectively. 13.3 Animal Husbandry

A variety of animals are bred locally in farms located all over the island, but mainly inland. The number of breeders of caprines, ovines, poultry and rabbits is particularly high in Gozo. Most of these farms are either directly connected to the main sewers or connected regularly to cesspits. Nonetheless, a number of cases are known, where localized accumulation of manure on such farms, is washed down into the sea, along major watercourses, during heavy rainstorms. This will lead to significant nutrient pollution loads in those inshore coastal waters under the direct influence of such sources. One example to illustrate this possible inland source of pollution, was documented by Axiak and Zammit (1998) in the limits of Xlendi, Gozo. The authors described how the locality comprising Ghajn Tuta, Lunzjata and is-Saqwi areas (leading to Xlendi Bay), constitutes one of the most fertile agricultural lands in Gozo. There is a plentiful supply of groundwater springs. Two natural springs are located at Ghajn tal-Hasselin; two springs at Ghajn Tuta and there are a large number of bore holes. A number of farms with animal husbandry are also located here including poultry farms; and a cattle farm. Dung deposits on these farms are quite frequent. Rain runoff from this area posed risks of water contamination by excessive nutrients at Xlendi Bay. There is very limited data on the chemical characteristics of rain runoff. In fact, we could only get access to data from a LIFE project (Environment Protection Department, 1999), which was also very limited. In this project some runoff samples from Wied il-Lunzjata, Xlendi, Chadwick, and Bahrija, were analysed for the level of nutrients. This data indicate that the maximum levels of phosphates, ammonia, nitrates and nitrites in such samples were close to 19 mg/L, 55 mg/L, 290 mg/L and 1.1 mg/L respectively. 13.4 Marinas and other Maritime Related Activities


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There has been significant development of marinas in various localities in Malta over the past two decades. This was especially so in Marsamxett area. Unless liquid and solid waste management in such areas is properly supervised, there are significant risks of pollution by oil and its products, as well as by other contaminants such as antifouling paints. As already discussed in Chapter 7 (Section 7.2.2) the available data indicate that the levels of PHC’s (such as diesel, fuels, and oil products) in superficial sediments from several coastal areas show an upward trend. Development of yacht marinas in Marsamxett may have led to a five-fold increase in oil pollution load in the sediments in Pieta and Msida over the period: 1992-1999. Likewise, bad housekeeping and mismanagement in port areas, may also lead to pollution by diesel oils, spent oils, and other contaminants. The same may apply to chemicals, in cases where chemical cargos are not handled with proper care. 13.5 Landfills

In a recent study (Saliba, 1999) on the Maghtab landfill, the data from chemical monitoring as well as laboratory-based leachate experiments, indicate that lead, nickel and copper are leaching into the sea and that the landfill could be in part responsible for this. The same may be true with respect to petroleum hydrocarbons. Although lead in sediments could be contributed by lead in dust on the coast road, the leachate test shows that the landfill is also contributing to some degree. Levels of lead, nickel and copper in marine sediments collected near Maghtab, were higher than those at a control site, especially in Qala San Marku, which always showed the highest concentration. Qala San Marku had maximum lead, nickel and copper concentrations of 127.24, 10.10 and 15.51 mg/kg Dry Weight (DW) respectively, whereas the respective control values were 4.62, 6.71 and 3.6 mg/kg DW. The levels for the other metals were below that of the control. Petroleum hydrocarbon concentration decreased from summer to winter in all sampling sites. Qala San Marku had the highest of 48.44µg/g DW chrysene equivalents while the control value was 3.26µg/g DW chrysene equivalents. On the other hand, runoff water collected from Maghtab area had very low values for heavy metals and petroleum hydrocarbon. 13.6 Control to ensure Compliance


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As will be pointed out in various sections of this report, the control of non-point or diffuse discharges is extremely difficult. Nonetheless, the EU water quality Directives also require control over such sources. The Competent Authority may in fact exercise a measure of control over such sources through:

a) the setting of standards of good practice with respect to the land-based activities which generate such risks of marine contamination.;

b) control over the use and application of chemicals in such activities;

c) education and sensitization of the personnel and workers in the

relevant sector giving rise to such diffuse sources of contamination. It is crucial that the setting of standards and codes of good practice, will be carried out by the Competent Authority in close collaboration with the relevant target sectors. Furthermore, the control strategy to be adopted by the Competent Authority will need to be fully integrated in other programmes controlling agriculture, industry and other sectors. References

Axiak, V., and Zammit A. 1998. Environmental Quality and Beach Management in Xlendi. Final Technical Report. Unpublished. Malta Council for Science and Technology. Environment Protection Department. 32pp Castaglia s.p.a. 1996. Volume 1: Marine Pollution Sources. Malta Civil Protection Master Plan (Marine Antipollution Scheme). Unpublished report. Environment Protection Department 1999. LIFE Project TCY96/M/06. Unpublished Report. Evaluation of Pollution Risk and Prevention Measures in Malta. 105pp. Saliba, M. 1999. Environmental Impact of the Maghtab Landfill on the Marine Environment. Unpublished B.Sc. (Hons)., Dissertation. Department of Biology. University of Malta.


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14. CURRENT ECONOMIC BACKGROUND AND FUTURE DEVELOPMENT IN RELEVANT SECTORS.

14.1 Introduction

So far, the report dealt with the current status of marine discharges. The aim of the present chapter is to try and assess those predicted industrial and economic developments which may have a bearing on the current status. The chapter starts with a brief overview of the manner in which market factors such as demand and supply may affect marine discharges. Then the recent and current changes in such market factors as well as other economic indicators are identified. Trends in the importation and use of the various chemicals relevant to this study are identified for the period 1995-1999. The chapter concludes by identifying the more relevant future trends in the economy, especially in the manufacturing sector, which are expected to have a bearing on the generation of marine discharges. 14.2 Demand and Supply Conditions

Marine discharges are directly related to the output of goods and services in a country. This output is dependent on the demand for commodities in question and also on the supply conditions. Therefore, one may consider these interrelationships as a series of factors, each one impinging on the other, and, ultimately, influenced by the respective cost considerations on the supply side and the several influences affecting the respective demand. Marine discharge is a composite of the volume of discharge and the components that make up this volume. Therefore, the mineral, chemical or biological elements being discharged in the sea may be considered as the outcome of two sets of forces, namely the total output and the technology being used both in producing it and in discharging it. Thus for example, the discharge of a ship repair yard reflects the volume of work carried out, the method used in carrying out the ship repair and the method of disposing of the effluent. Again, in the case of fish farms, the marine discharge reflects the volume of fish cultures reared, the type of feed used, the size and type of fish cultivated, the method used to clean the cages and to dispose of water used in the hatching cages, if any.


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The supply of the output depends on the method used to carry out an activity. It is also determined by the technology used at the time. This, in turn, reflects the costs of production at the time the operation was introduced and the market demand and, hence, the price which consumers in the respective markets are prepared to pay. An additional condition affecting supply such as the discharge compliance costs or health and safety measures are bound to alter the cost composition, and therefore, induce a reconsideration of the technology in use. In turn, the market in which they sell their commodities also affects producers. If the market is competitive, and they are price takers, they have to adapt the production method, and, hence, their cost composition to suit such a market. Failure to review current costs and absorb additional costs will eliminate them out of their particular market. Hence the flow of demand/supply of discharge has to be seen as a continuum, undergoing recurrent changes. The above may be summarised in a series of equations given below: For a firm demand for a product is a function of personal income (Yp), the price of the product (I) (Pi), and the prices of complements and substitutes (Pj….Pz). Therefore Di = f(Yp, Pi, Pj….Pz)………………….(1)

In aggregate, demand for good I is determined by GNP (Y), the price of good I (Pi), the prices of other goods and services [Pj],[Pz], and the size, age structure and the geographical distribution of the population (Pop). D = f(Y, pi, [Pj],[Pz], Pop)……………….(2)

Individual supply by a firm is influenced by the technology used to produce the good or service (T), the price of the commodity produced (Pi) and the price of inputs used to produce these goods or services (Pj…..Pz). Therefore S = f(T, Pi, Pj…Pz)……………………...(3)

The aggregate quantity supplied is a function of all the different technologies used to produce the goods or services (Tt), the price of goods produced (Pi) and the prices of inputs used to produce them [Pj],[Pz]. Hence Total supply S = f( Tt, Pi,[Pj]..[Pz]………(4)


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Both individual and aggregate supply are highly influenced by the market structure in which firms are operating. Therefore in summary, marine discharge is indirectly affected, via demand and supply conditions, by income (Y), population (Pop), Prices (P), technology (T) and the market structure (MS) in which producers are carrying out their economic activities. These parameters are examined below. Compliance costs affect the supply of goods and services and hence the discharge, given a technology. If the compliance costs are high, they may impinge on the price of the various goods and services produced depending on the market structure in which the firm is operating. Forward shifting may be inadvisable and the increase in prices may be socially unacceptable especially if the sum of the various increases in the prices of different goods and services will substantially reduce their disposable incomes. In such cases anyone or a combination of the following alternatives may be considered: • Definite time frames are given to allow the industry to undertake the necessary

changes. If this option is chosen costs may be spread over a longer period, thus evading becoming uncompetitive or instigating social unrest.

• Analyse the production systems and their related costs. If production methods are inefficient, restructuring may reduce costs and increase efficiency. Thus all or part of the compliance costs may be recovered without having to increase prices and lose competitiveness. Alternatively, other technologies may be more feasible and less costly.

• Evaluate the different pricing policies that condition demand. Price discrimination between sectors and during different times may spread demand for the good or the service and hopefully reduce pressure on supply in peak production periods.

14.3 Current Status

14.3.1 Demographic Review Population changes are measured as the sum of the rate of natural change i.e. birth rate less death rate and the net migration. Besides, one may distinguish between the population of Maltese origin, naturalised Maltese and settlers in the Maltese islands. In addition for the purpose of this report, account has to be taken of the population equivalent of the number of tourists who come to visit Malta each year. Between 1995, Census year, and 1999, the population in Malta grew by 10,164 or 2.69 % overall rising from 378,132 to 388,296. However, the natural rate of population growth slowed to 0.3% in 1999 compared to 0.71% in 1995. The


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number of returned migrants and non-Maltese nationals settling in Malta in 1999 were 708. The Maltese population is projected to grow by about 7904 to 396200 in 2010. This figure is assuming a nil migration rate. During the same period i.e. between 1996 – 1999, the total number of tourists visiting Malta rose by 15% from 1,063,594 in 1996 to 1,230,126 in 1999. Of these, 891,557 demanded hotel, tourist village or guesthouse accommodation during their stay in Malta. The average rate of stay of these tourists was 9.1 days. This is equal to an equivalent population of 22,326 per annum. In 1999, another 388,296 tourists spent an average 10.4 days in hostels or lived in private and other accommodation. This amounts to an additional increase in population equivalent of 96,47 persons per annum. If these equivalent population were added to the local population, the real population size would be 420,977 instead of 388,296. This implies that infrastructural facilities would have to cater for an 8.4% increase in population Ideally, more detailed analysis on the seasonal patterns of tourist arrivals, the various accommodations used and the occupancy rates should be carried out. The demand for electricity and water will vary accordingly. Peak power generation may result in higher marine discharge rates than if the supply of power were spread equally throughout the year. 14.3.2 Household Income and Expenditure Over the period 1995-1999, the Gross National Product at constant 1995 market prices rose by Lm198.8m or 17.2%. Income per capita increased by 14% from LM 3,061.1 to Lm 3,493.2 in 1995 and 1999 respectively. As the per capita income improved, consumer expenditure and imports rose from Lm700.4m and Lm1, 231.2 m in 1995 to Lm829.5m and Lm1, 273.6m in 1999 respectively. Imports of consumer goods rose by 15.9%. During this period the demand for electrical appliances and private cars soared. The number of licensed and commercial vehicles rose from 14240 and 31674 respectively in 1995 to 176,264 (1137.8%) and 42,687 (34.8%) in 1999 respectively. This increased demand for energy consuming goods was accompanied by an increase in fuels/ lubricants (44.5%) and machinery and transport equipment (11.37%). During this period exports of goods and services increased (14.4%). Moreover, a number of 5 Star Hotels, which are high consumers of electrical power and water, were constructed and started operations during this period. This investment had a twofold effect: It generated employment, income and consumption. But, at the same time, the opening of several 5-Star Hotels put further pressure on Malta's infrastructure. It may also contribute to higher marine discharges 14.3.3 Industrial Growth


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Over the past five years, there was a shift in economic activity from the manufacturing to the service sector. In fact, the contribution of the manufacturing sector to GDP at factor cost fell from 24,4% to 22.82% during this period. Conversely, the contribution of the services sectors rose by 2.62% from 69.2% in 1995 to 71.82% in 1999. The contribution of agriculture and fisheries fell slightly from 2.87% to 2.5%.

Table 14.1 Percentage contribution to Gross Domestic Product

1995 1999 % change Agriculture &

Fisheries 2.87 2.5 - 0.37

Manufacturing 24.36 22.82 -1.54 Services 69.2 71.82 +2.62

Source: C.O.S., 2000, Malta in Figures, p25.

14.3.4 Agriculture and Fisheries Although the percentage contribution of this sector to Gross Domestic product at factor cost fell, employment income from agriculture and fisheries rose from Lm3.37m to Lm4.27m between 1995 to 1999. Fish landing increased by 11.7% from 926 tons in 1995 to 1034 tons in 1999 possibly because of the expansion of fish farming. Exports of fish fell by 253.6 tons or 19% in the first nine months of 1999 compared to the same period in 1998. If this trend persists, it may have a negative impact on the fish farming industry. The production of pork also rose by 20.7% from 8497 tons in 1995to 1025.8 tons in 1999, whilst the output of beef declined by 5.7% from 1735 tons in 1995 to 1635 tons in 1999. 14.3.5 Manufacturing Industry Over the last five years, this sector has shown signs of decline. In spite of this, total output in this sector increased by 6% in the period 1995-1998. Sectors that are still expanding include food and beverages, chemicals, rubber and plastic products,


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machinery and equipment and electrical machines. Investment outlays in the chemical industry increased from Lm0.6m in the first nine months of 1998 to Lm2.3m during the same period in 1999. Printing and publishing also improved performance in 1999. Exports from this sector increased whilst investment by the printing and publishing sector more than doubled reaching LM2.0m in January –September 1999 14.3.6 Plastic and rubber In the first nine months of 1999, the total turnover for the plastic and rubber sectors totaled Lm26.6 m, an increase of Lm3.6m over the Jan –Sept 1998 level. This noteworthy performance was the result of increased turnover in both the domestic and external markets. During this same period there was a significant expansion of capital outlays. Investment increased from Lm1.3m in Jan-Sept 1998 to Lm3.9m in 1999. 14.3.7 Basic Metals and Fabricated Metal Products The basic metals and fabricated metal sectors are characterised by a large number of micro and small enterprises engaged in the casting of metal and manufacture of structural metal products. Sale of basic metals increased because of an increase in local turnover. Sales of fabricated metal fell but investment by this sector improved. 14.3.8 Machinery and equipment In 1999, there was a shift in output for the export market as local sales declined. Exports in this sector doubled to reach Lm5.1m compared to Lm2.5m a year earlier. 14.3.9 Electrical machines This sector includes a number of important export oriented manufacturing enterprises engaged in the manufacture of electrical distribution goods and equipment. Total turnover increased by Lm1.5m to Lm22.6m in Jan-Sept 1999. The driving force behind this positive performance was Lm1.2m increase in domestic exports. 14.3.10 Communication Equipment and apparatus


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This is the most important cluster of manufacturing activities in the domestic manufacture industry. It is primarily composed of electronic components and other precision communication products essentially directed towards the export market. The turnover of the communication and apparatus sector rose from LM280.3m to Lm306.4m. This is an expanding sector and one that consumes a large amount of electricity. 14.3.11 Services Industries

Since 1995, the services sector sustained its contribution to output growth, new job creation and foreign exchange earnings. The improvement in this sector was sustained by a growing contribution by tourism, financial services and Freeport activities. The growth of these services has, over the last years, contributed to a rise in demand for water, electricity and sewage disposal and has consequently led to increased marine discharges. As indicated earlier , the number of tourists increased by 160,442 or 15% over the period 1995-1999. Gross foreign exchange earnings from the sector reached an estimated Lm207.1m in the first nine months of 1999 increasing by about 7% on the same period in 1998. During the latter period, tourism generated 199,362 full time equivalents jobs (The Economic Impact of Tourism p46). This reflects the total number of full time working an average of forty hours per week plus the total number of part-time equivalents i.e. two part-time working twenty hours per week are equivalent to one full time employee. Jobs were generated in accommodation, catering, car hire air traffic as well as in handling agent institutions such as NTOM/MTA, MIA and tourist guides. It also includes the tourist related proportion of those working in retail outlets e.g.. clothes shops, recreational and cultural spots (e.g. museums) and public transport. Tourism expenditure is estimated at Lm319.49m. This implies an employment multiplier of 60.60. Thus for every Lm1 million of tourism expenditure 60.60 full time equivalent jobs are created. 14.3.12 Malta Financial Services The Malta Financial Services Centre (MFSC) regulates and promotes the growth of domestic financial sector. The centre is responsible for the supervision and monitoring of international commercial activities including trusts, collective investment schemes, investment service providers and insurance activities.


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Business in these financial services is growing. Investment services activities are also on the increase. Employment in banks and financial institutions rose by 213 or 5% from 3796 to 4009 in 1996 and 1999 respectively. This was reflected in an increase in factor incomes earned by insurance and banking sectors. 14.3.13 Malta Freeport Corporation Ltd. In the first nine months of 1999, transshipment increased from 731,077 TEU (Twenty Equivalent Units) to 744,586. Moreover, ship call at the container terminal rose by 8.4% to 1251 vessels during the first nine months in 1999. The infrastructural work completed before October, 1999, extended the processing capacity of the Freeport which now offers additional total area of 210,000 square metres and 4040 container ground slots. Activities at the Malta Freeport include the storage and the blending of oil products. In the first nine months of 1999, Oil Tanking (Malta) Ltd. increased its activity by 69.3%. It handled 2,345,130 m tonnes of product compared to 1,385,020 metric tons during the corresponding 1998 period. 14.3.14 Recent Trends in Importation of Chemicals In an effort to detect trends in the use of industrial compounds relevant to the EU water quality directives, data on importation quantities was obtained from the Department of Statistics for the period 1995-1999. This data is presented in Table 14.2. This data shows that over the past 5 years, over 5800 tonnes of relevant chemicals were imported in Malta. Of these, almost 55 % by weight were phosphorus containing compounds. However the relative share of such compounds of the global amount of chemicals imported has dropped over the past few years, as may be seen in Figure 14.1. On the other hand, metal-based compounds are being imported more, though the trend has stabilized since 1997. The biggest share of such metal-containing compound is for pigments and preparations based on titanium oxide, for the paint industry. The importation of organics as a class of compounds, as well as of other substances such as cyanides, do not show any significant trend.


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Of the organics, perchloroethylene and tichloroethylene feature most prominently in imported organics, followed by chloroform. These organics are much used as industrial solvents and cleaning and degreasing fluids, amongst other things. Insufficient information was available for the purpose of the present study, in order to enable us to pinpoint the exact reasons for the various fluctuations in the use of individual chemicals, by specific industrial sectors. 14.3.15 Summary of Recent Trends As indicated earlier, marine discharges are directly influenced by the supply of and the demand for goods and services as reflected in the G.D.P. G.D.P at constant 1995 market prices rose by 17.5% from Lm1145.5m in 1995 to Lm1345.5m in 1999 (Malta in figures 2000, p.25). The increased demand was brought about by a buoyant economy and growing economic activity in various economic sectors. These sectors increased the output of goods and services. In the process, the demand for water and electricity generation and sewage disposal rose. Moreover, the demand for industrial inputs like fuel and to a lesser extent, chemicals also increased. Economic growth, in turn, generated new employment opportunities. Income and expenditure rose further inducing demand for consumer goods and services such as cars, houses, white goods, health and recreational facilities. 14.4 Future Development The volume and quality of marine discharges at any one time, depends on the ability of the Maltese economy to sustain its economic growth, the types of industries operating in Malta and the feasibility of collecting, treating, re-cycling and re-using industrial and domestic wastes. Projects to conserve water and reduce leakage in the water distribution system may reduce the need to increase the supply of RO water and hence minimise the need to generate electricity and consequently reduce marine discharges. 14.4.1 Predicting Development in the Manufacturing Sector


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Although no sector by sector growth analysis is available to-date, it is expected that the present rate of industrial development is maintained, and hopefully improved in the future. As already explained, the manufacturing sector is in general contracting when compared to other sectors. Economic development over the past decade was characterized by a relative shift towards the services and other sectors. Nonetheless, the manufacturing sector was kept at a roughly constant level, in absolute terms, with an approximate level of 30,000 employees being maintained. However, there are signs of growth in certain industries such as chemical, printing and publishing and especially industries producing communication equipment and apparatus. The current trend is towards ‘low batch, high value added’ type of industry. Main industrial sectors which are experiencing growth include: the precision engineering industry; the specialized injection moulding plastic industry; pharmaceutical and medicinal industries, etc.. There are no indications that any chloro-alkali electrolysis or pesticide production industries will be established in Malta over the next decade. The present electroplating industry is unlikely to expand and is currently operating with an over-capacity. The paint industry (including the manufacture of paint pigments) is likely to experience a decline, mainly due to the removal of the current levies. The local fishfarming industry has presently reached a ‘bottleneck’ stage’. Unless it will be able to expand (by at least 100%), through the development of hatcheries etc…, it is more likely experience a decline. The new industry of tuna penning may well increase, though it is still too early to confirm this. The success of the manufacturing sector also depends on whether Malta succeeds in attracting foreign direct investment and on the ability of existing enterprises to restructure their production and remain competitive. The New Business Promotion Act introduces a range of incentives that may help offset part of the costs which are incurred to realign with EU legislation. 14.4.2 Other Developments The service sector is expected to expand. If the present level of tourist activity is to be maintained, some firms may need to upgrade, their infrastructural facilities.


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Growth in the financial and insurance sectors may demand new offices and I.T. equipment which may change the present level of energy and water consumption. EneMalta Corporation is at present anticipating an additional projected demand of 61MwH of electricity. The energy is needed to supply new projects such as the Manoel island project, the Cottonera Waterfront project, the Hilton project, San Rafaelle Hospital and St Microelectronics ltd. Although, expansion of existing projects or the development of new ones imply a higher demand for water, and energy, this may not necessarily mean an equal increase in supply. This is more so if efforts are made at the micro or firm level and at the macro level to make the most effective use of existing resources. First, industry may utilise alternative energy sources e.g. renewable or co-generation, to a meaningful degree. Moreover, recycled water may be used for manufacturing. This is possible if firms have the right infrastructure. Some firms, like St Microelectronics (Malta) LTD have already succeeded in substantially reducing their demand for water and electricity energy needs. (The Environmental Statement, Kirkop Site, Malta, Dec. 1998). In 1994 this company consumed 465.52MWh of electrical energy to produce US $(1m) worth of products. This figure has been reduced to 346.60MWh representing an increase in the efficiency of electricity use of 25.5% Moreover, the main use of water at the site is at the dicing saw processes and the plating processes in production. Other industrial uses include the make-up water to cooling towers and boilers. In addition, water is used in sanitary facilities, in the canteen and for irrigation. The total water consumption per million US$ (M$) of product sold, decreased from 3055m3/M$ in 1994 to 441 m3/M$ in 1998. This represents an increase in the efficiency of water use of 85.6%. The company has decreased the absolute quantity of water used by the site between1994 and 1998 by over 61%. Reduction in demand was due to two projects. The first project involved the recycling of process wastewater from the dicing saw machines and the second involved the use of treated wastewater from the plating process. The first step of the water recycling project achieved a reduction of 20% of the total raw water of the site. Another 5% reduction in mains water was achieved through the use of EDR brine for toilet flushing. The installation of the Plating water recycling plant achieved a further 10% reduction. Moreover, utilisation of the site’s rainwater reservoir during 1998 also contributed to a further 18% reduction in the total raw water on the site.


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Such efforts at improving efficiency and cutting the volume and the cost of water and electricity consumption contribute to minimise the volume of marine discharges without negatively impacting on economic growth. The Water Services Corporation (WSC) itself has been striving hard to contain supply by improving its distribution network, thus reducing leakages and implementing a programme of water demand management which has helped to reduce RO production of water which is very costly. Although the population equivalent in Malta rose by 4% between 1995 and 1999, water production fell by 14,406,159 m3 or 27.9% Moreover, in 1999 though the total volume of water produced increased, only 49.7% of total water was produced by the RO system compared to 60.74% in 1995. This did not only improve the efficiency of WSC but indirectly eased the demand on EneMalta Corporation since the production and the distribution of 1m3 of water by reverse osmosis requires 6.38 kWh of electricity compared to e.g. 0.854 and 0.662 kWh of electricity needed to produce and distribute water from groundwater sources. A fall in water production and distribution of 14,406,1599 m3 means a saving in electricity generation of about 91,911,294 kWh over this five year period. This savings in energy consumption has substantially reduced the volume of marine discharges that would otherwise have been necessary. References

Central Office of Statistics, Malta, 2000, Malta in Figures, 2000. Central Office of Statistics, , 2000, Number of Tourist departures from Malta & Length of Stay, Classified by Type of Accommodation Jan-Dec, 1996,1997,1998, 1999. Economic Planning Division, Ministry for Economic Services, Nov., 1999, Economic Survey, January –September, 1999. Mangion , M’Louise and Vella Leslie, Malta Tourism Authority, Valleta, 2000, The Economic Impact of Tourism in Malta. Ministry for Economic Services, Nov., 2000, The New Business Promotion Act. ST.MicroElectronics (Malta) Ltd, Kirkop Site, Malta, Dec., 1998, pp 12-13, The Environmental Statement. Water Services Corporation, Malta, 1998, Annual Report, 1997/1998


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Water Services Corporation, Malta, 1999, Annual Report, 1998/1999. Water services Corporation , Malta, 2000, Annual Report, 1999/2000


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15. AUTHORIZATION SYSTEM FOR DISCHARGES INTO THE MARINE ENVIRONMENT.

15.1 Introduction Discharges of waste waters or of any process waters into the marine environment (as well as upstream, i.e. from the industrial plants into the sewers) must be controlled by an Authorization System in the form of a Competent Authority. This is a basic requirement of the Water Framework Directive (as reviewed in Chapter 2, Section 2.4) as well as of the Protocol for the Protection of the Mediterranean Sea against Pollution from Land-Based Sources and Activities (Article 6). As already discussed in Chapter 3, the relevant EU directives concerning discharges of waters into the environment, lay down the conditions and limits for such discharges both as released into sewers and public collecting systems, as well as when released into the marine environment. The manner in which the EU directives will be covered by local legislation, has already been agreed upon and identified by the National Plan for the Implementation of the Acquis. 15.2 Two Authorization Systems An authorisation system is already in place within the Drainage Department (DD) to control discharges of industrial wastewaters into the sewers. The workings of such an authorization system for discharges into sewers have been reviewed in Chapter 3. The authorization system to control marine discharges will be set up within the Environment Protection Department, through the new regulations as stipulated in a new Legal Notice on Environmental Protection (Discharges to the Marine Environment). The present study on the impact of compliance, dealt mostly with direct marine discharges as stipulated in Chapter 1. As such this Chapter will focus on the responsibilities of the authorization system, which will be required to control discharges into the marine environment. Nonetheless, it is self-evident that the two authorization systems (i.e. that to control discharges into sewers and that to control discharges into the marine environment) will need to be integrated in a common framework and strategy.


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Regular and formalized contacts between these two Departments already exist, and these will need to be strengthened, for the purpose of achieving compliance with the EU water quality Directives. The Ministry for the Environment will be the single Competent Authority to implement the relevant EU Directives related to water quality. As such, it would be the responsibility of this Ministry to ensure that the two ‘separate’ authorization systems’ will work in full complimentarity. One likely source of difficulty in the division of responsibilities between the Drainage Department and the Environment Protection Department, as identified above will need to be pointed out at this stage. According to the present plans, the Drainage Department will act not only as the authorization system to control discharges into the sewers from industrial plants, but also to ensure that such wastewaters are sufficiently treated to a level that would be compliant with the relevant EU water Directives, prior to their discharge into the marine environment. While water treatment may be undertaken by third parties (such as the private sector), it will be the Drainage Department (or the Works Division) that will ultimately be responsible for such compliance. In the event of non-compliance for marine discharges on the part of the Drainage Department or the Works Division, such as the accidental discharge of sewage from a malfunctioning sewage pumping station, or in the event of malfunctioning of treatment plants, then the Environment Protection Department would be bound to take actions (including the setting of fines and penalties) to stop such contraventions. It may be difficult for two divisions or departments which are located within the same Ministry, to fine one another! There may be also the risk that the fines set will be below the appropriate level, (or worst still, there may be pressures to overlook such contraventions), so that the budget of the whole Ministry will not be unduly affected. Certainly, it may be argued that the costs of such contraventions on the part of the Drainage Department or the Works Division, may be passed on to the industrial plants themselves, if it may be proved that the malfunctioning of a particular treatment plant was due to their fault (e.g. due to discharging of substances which may interfere with the functioning of such treatment plants). Nonetheless, there may be administrative pressures to apply less stringent control over marine discharges arising from public sewers or from sewage treatment plants. If this happens, then there is a risk that the level of control over the private sector for direct marine discharges will also be jeopardized. In that case the whole system


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of compliance will collapse. In effect, such a marine discharge control strategy is a chain of responsibilities and of obligations for various sectors. Such a chain will be as strong as its weakest link. 15.3 Responsibilities of Authorization System Controlling Marine

Discharges The authorisation system for the control of marine discharges will need to fulfill all provisions of the relevant EU Directives as already reviewed in Chapter 3. Such marine discharges will include:

a) Permanent or Semi-permanent Point Sources; b) Illegal or Accidental Point or Discrete Sources; c) Diffuse Sources which may arise from land-based activities which

could be located either on the coastline, or well inland. The responsibilities of such an Authorization System (as well as of the Competent Authority) as they fall under the various EU water quality Directives, are summarized in Table 15.1. Since, the Water Framework Directive aims at integrating the various Directives dealing with water discharges (as well as others), then the following account will be mostly based on its provisions. 15.3.1 Classification of coastal waters For the purpose of river basin management, surface waters are categorized as:

Rivers Lakes Transition waters (Estuaries) Coastal waters Artificial surface water bodies Heavy modified surface water bodies.

In fact, for the purpose of environmental management, all the coastal areas of the Maltese Islands may be categorized as Mediterranean, coastal, euhaline (salinity 30 to 40 ppt) waters of shallow / intermediate depths (following System A of type differentiation as laid down in Annex 2 of Directive). A better degree of differentiation may be possibly achieved if System B is followed (as indicated in Annex 2 of the Directive). The relevant descriptors to take into account will include geographical location, tidal range, salinity, and a range of other optional factors such as hydrodynamics, temperature, turbidity and


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substratum composition. Further work will need to be carried out by the competent authority to determine such matters. 15.3.2 Setting up of Water Quality Objectives The water quality objectives to be set (as per Article 4 of the Water Framework Directive) would need to include:

a) The prevention of deterioration of the ecological status and of the pollution of coastal waters;

b) The restoration of good ecological and chemical status for already degraded coastal areas.

c) The achieving of compliance with the relevant standards and quality objectives in protected areas.

These water quality objectives will need to be achieved through phased implementation of measures as indicated by Article 11 of the Water Framework Directive, within 16 years after the Directive enters into force. There are various provisions for extensions or exceptions to this deadline. It is beyond the scope of the present study to discuss the implications and applicability of such allowable extensions to Malta, but it may be assumed for the sake of compliance cost estimates, that such water quality objectives will apply without the need for any extensions or exceptions. In applying such water quality objectives to Malta, the authorization or competent authority will first need to identify the characteristics of coastal waters and to collate data (and if this is missing, to generate such data) along the following lines:

a) an analysis of the relevant characteristics; b) a review of human impact; c) an economic analysis of water use.

This will need to be carried out within 5 years of the Water Framework Directive coming into force. Furthermore, the Directive includes detailed specifications and methodologies (Annex 2 and 3) about how to formulate such characterization. The competent authority will then need to establish type-specific reference (baseline) conditions for the local coastal waters, with respect to:

a) morphological b) physico-chemical and c) biological conditions.


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These conditions may be based on spatial considerations (i.e. choice of clean reference coastal stations), modeling, or expert judgment or any combination of these approaches. 15.3.3 Water Quality Elements For coastal waters, the quality elements that need to be taken into consideration for the classification of ecological status (as well as for the setting up of reference conditions) include: Phytoplankton; Macroalgae and angiosperms (i.e. Posidonia meadows); Benthic invertebrate fauna; Hydrodynamic elements which may affect the above biota; Nutrient levels; Temperature range; Oxygen balance; Water transparency; Levels of synthetic and non-synthetic pollutants. 15.3.4 Identification of Human Impact and Economic Implications In identifying human impact, the competent authority will need to:

a) Identify and assess the significance of point sources of pollution, by chemicals (as stipulated in Annex 8). Such chemicals are generally the same as those included in Dangerous Substances Directive and the Urban Waste Water Directive.

b) Identify and assess the significance of diffuse sources of

pollution;

c) Estimate land-use and sea-use patterns, such as fishfarming, marina developments, port developments, etc..

d) Estimate any other significant impact, such as those

generated from maritime traffic, bunkering etc…


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The Competent Authority will then be required to assess the level of risks from the human impacts as identified above, i.e. to assess the probability that coastal waters will fail to meet the set environmental quality objectives. In the undertaking of economic analysis of water use, the Competent Authority will need to take into account the recovery of costs (including cost of resource as well as environmental cost, such as that require to rehabilitate the environment, after impact) according to the polluter pays principle. 15.3.5 Protected Areas and Sensitive Areas A register of protected areas will need to be established within 5 years of the Directive coming into force. Such protected areas will include: coastal waters which are used as feed waters for reverse osmosis plants; bathing areas; marine conservation areas; eutrophication-sensitive areas. The designation of sensitive areas is also provided for in the Urban Waste Water Treatment Directive. A number of ecologically important sites in local coastal waters, has already been identified by the Environment Protection Department. Such sites have been selected on the bases of type of habitats found, level of threat to species present, as well as scientific value of the site. For the purpose of the EU water quality Directives, other sites need to be included, on the bases of sensitivity to nutrient-induced eutrophic conditions. Some data is available regarding the location of such sites. Such data is mostly available from short-term coastal monitoring programmes undertaken at the Marine Ecotoxicology Laboratory of the Department of Biology (University of Malta), including remote sensing, and more recently other information is available from a long-term monitoring programme of coastal waters commissioned by the Pollution Control Co-ordinating Unit of the EPD. 15.3.6 Monitoring Obligations The Competent Authority will need to set up a monitoring programme to assess the ecological and chemical status of coastal waters, so as to permit classification of such waters into a number of status classes: high, good, moderate, poor or bad. The parameters to be monitored will include all those quality elements as identified above. Annex 5 of the Water Framework Directive, stipulates the type, objectives, location of monitoring stations, frequency of monitoring ,as well as other details of such monitoring programmes. For the purpose of the present study, there is no need to


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review in great detail, all such requirements. Nonetheless, a number of worthwhile observations may be made, as follows: Emphasis is made, not only on chemical monitoring, but also and especially so, on bio-monitoring. Such bio-monitoring may include the use of bio-indicator species or group of species, such as phytoplankton and benthic invertebrates. Axiak (1995), and Axiak and Scoullos (1995) have reviewed the merits in the use of biological indicators for environmental quality. Experience gained through a number of biomonitoring projects carried out at the Department of Biology of the University of Malta, has shown that:

a) Some bio-indicator responses specific to particular pollution (e.g. imposex in response to organotins, Axiak et al, 1995) have been used in a highly cost-effective manner;

b) In other cases, biomonitoring may be much more demanding on field

and laboratory resources. The personnel in charge of such monitoring must be highly trained.

c) Biomonitoring of state of health of some benthic communities, such as

that of Posidonea meadows, is feasible and yield valid results in the case of compliance monitoring. (e.g. for the case of the Hilton Marine Monitoring Programme, currently being undertaken in Spinola).

d) Biomonitoring data is much more difficult to interpret and assess. In fact

the Directive tries to address this issue through the establishment of inter-calibration exercises.

Monitoring responsibilities are quite onerous and time-consuming. They will need to be fulfilled by specially trained staff, who will be completely dedicated for such a purpose. This fact is not always appreciated and given due consideration in the allocation of funds and resources to the Environment Protection Department. The Directive requires that the data collected from monitoring programmes will be used to generate colour coded maps for the various coastal sites, which indicate the ecological and chemical status of the various localities. Over the past three years, the Pollution Control Co-ordinating Unit has initiated a similar programme of coastal water quality monitoring, though on a much smaller scale and with a very limited number of parameters being measured. Colour-coded maps for water quality have been produced, and these have proved to be quite effective in communicating data information for the purpose of environmental management.


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15.3.7 Control of Marine Discharges Point marine discharges may be controlled through the establishment of emission limit values or the implementation of emission controls based on best available techniques. Diffuse sources may be controlled by establishing best environmental practices, codes of good practice. All such discharges are to be controlled in such a way so as to achieve the set environmental quality objectives, and following the lines of operations as identified in the preceding sections of this Chapter. After laying down emission standards into the marine environment and identifying sensitive and less sensitive coastal areas for the purpose of marine discharges, the Competent Authority may grant authorization for marine discharges for limited periods under given conditions (as determined by Commission). These authorizations are to be periodically reviewed (every 4 years). An inventory of such point (and possibly diffuse) sources of discharges needs to be kept and regularly updated. In case of coastal waters which are found to be degraded or below ‘good’ status, environmental quality standards will need to be established for pollutants concerned, followed by thorough investigation of the point or diffuse sources which may be leading to such a situation. Authorization for discharges or for the particular land-based activities constituting the diffuse source, will then be reviewed and if necessary, withheld. Furthermore, the Competent Authority must be able to take the appropriate steps to stop contraventions resulting both from point and diffuse sources. 15.4 Establishing Pollution Reduction Programmes Council Directive 76/464 requires the Competent Authority to establish a programme for pollution reduction for substances in List II to the Annex of the Directive. According to a recent EU publication (European Commission, 2000) , the implementation of this provision proved to be very difficult for Member States. The same report states that the starting up of the accession negotiations for the candidate countries showed that the Directive 76/464/EEC, and the pollution reduction programmes under Article 7 in particular, are one of the major challenges within the environmental Acquis. Nonetheless, such programmes remain the major and most powerful legal instrument for the protection of the environment against such contaminants.


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The Water Framework Directive also requires the setting up of such pollution reduction programmes. 15.4.1 Need for a Single Co-Ordinating Body This programme must be comprehensive and coherent. It must therefore include all provisions for the control of diffuse and point sources of discharges, both into the sewers as well as into the marine environment. In the local situation, where different Legal Notices are to be issued, to control sewer and marine discharges separately, the relevant legislation, as well as their implementation programmes must demonstrate in a clear an understandable manner to the Commission, that they are in fact fully complimentary and form part of a single programme. For this purpose it is proposed that the Ministry for the Environment (as the Competent Authority) will set up an inter-departmental body or unit which would be responsible for the implementation of such pollution reduction programmes as well as other compliance programmes. Further details about this proposal are being presented in concluding Section of this Chapter. 15.4.2 Identification of Relevant Pollutants to be Covered Member States are required to identify, which particular substances (from List 2) will need to be included in such a programme. These substances will include: Metals (in particular, Cr, Zn, Cu, Ni, Pb, As and Ag) Aromatics (benzene, xylene, toluene) Phenols Petroleum Hydrocarbons Cyanides Ammonia and nitrites Sulphides Phosphrous compounds Biocides (including organotins) and pesticides. The present study has generated some data which could be useful for the purpose in assessing the relevant significance of the respective pollutants. However, there must be a much more extensive body of data as derived from an intensive screening monitoring programme which could be undertaken over one year at a number of fixed stations, similar to those monitored for the purpose of the present study.


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15.4.3 Quality Objectives and Compliance Monitoring Quality objectives for the identified relevant pollutants must be formulated. These could include emission limit values and preferably indicate the time frame over which the load of a particular pollutant would be reduced. This will entail the setting up of emission reduction targets. For example, the present study (Chapter 7) has identified one particular fuel/oil terminal which would find it difficult and economically not feasible, to discharge wastewaters with an upper limit of discharge of 5 mg/L. For the purpose of this pollution reduction programme, it may be possible for the Competent Authority to allow marine discharges above this emission limit, provided that the installation may demonstrate that it will improve its present treatment facilities to reduce the current levels of oil in its discharges to acceptable limits. A time limit for such a reduction will need to be provided for in the issue of authorization of such a discharge. The methodology for the establishment of environmental quality objectives will be the same as those identified for the Water Framework Directive. The establishment of environmental quality standards and emission limit values will be reviewed in Section 15.5. Furthermore, in the case of diffuse sources of discharges, such environmental quality objectives could be achieved via the control of land-based or sea-based activities through the setting of standards for products and procedures. Compliance monitoring will need to be carried out to supervise the effectiveness of the implementation of such a programme. The Water Framework Directive covers details of this type of monitoring. 15.5 Establishing Criteria of Impact of Specific Substances As already reviewed above, the Competent Authority is required to set environmental standards with the ultimate aim of protecting human health and to preserve environmental quality. The present section will present a very brief review of the background to the ecotoxicological methods applied in assessing impact of a particular pollutant (as required by the terms of reference for this study) as well as in establishing controls for its discharges through a range of standards.


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For a more extensive review of this aspect of environmental management of marine discharges, there is a whole list of well known references such as: Suter II (1993), Rombke and Moltmann (1996), Weinstein (1996), and Hens and Vojtisek (1998). The impact of a specific pollutant will ultimately be dependent on the following factors:

a) The level of its toxic effects on target species; b) Its fate in the various marine environment phases: such as: surface

microlayer, water column and sediments, including environmental persistence.

c) Its bioavailability to target species; d) The degree of its bioaccumulation and biotransformation

15.5.1 Toxic Effects Toxic effects of a particular pollutant may be exerted on various levels of biological organizations including, the cellular (histological, biochemical) , organismic (behavioural, physiological), community and ecosystem levels. The ultimate and most dramatic effect on the individual is mortality. Standard methods and endpoints of toxicity are readily available for a variety of marine organisms. These include: the lethal concentration which kills 50% of the organisms after a particular exposure time (LC50), the concentration which elicits a given biological effect on 50% of the organisms after a given exposure time (EC50) and others. These endpoints of toxicity are derived from laboratory based experiments, and their ecological significance is quite limited. Such laboratory tests may be used to derive toxicity curves, which establish the relationship between the level of exposure (i.e. concentration of pollutant) exposure time, and biological effect. From such toxicity curves one may determine the concentration of the pollutant at which no biological effects are observable (NOEC). There are various difficulties in determining the NOEC for a given pollutant. These are due to the extrapolation from acute to sublethal laboratory test; the extrapolation from one test species to other target species which have not been tested; the extrapolation from laboratory tests to real filed conditions. In the setting up of environmental quality standard, the Water Framework Directive (Annex 5) stipulate methods which include the application of safety factors (1000 to 10) to derive the predicted no observable concentration in the field from toxicity endpoints.


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15.5.2 Environmental Fate The fate of a pollutant, once it is found in the marine environment can be quite diverse depending on a number of interacting factors. The pollutant may eventually change into a harmless compound (s) or it may persist for long periods of time, or it may be transformed into a more toxic pollutant. These factors will need to be taken into account in determining emission and environmental quality standards. Very often sediments are important sinks (reservoir) for a particular pollutant. This is especially the case for petroleum hydrocarbons, so much so that local experience has shown that long-term trends in the levels of oil pollution in coastal waters may be more readily identified by using data on levels of oil in superficial coastal sediments. As such environmental quality standards are to be set also for sediments as well as for biota. 15.5.3 Bioavailability of Pollutant The degree of impact of a pollutant will evidently depend on the ease with which it may gain entry into a target organism. Although some pollutants such as weathered oil, may exert a lethal effect through its physical smothering effect, most other pollutants must gain access into the organism before they may exert an effect. Some pollutants may be more readily available to marine target species if they are adsorbed to sediment or suspended particles. These factor will need to be taken into account in determining the various standards. 15.5.4 Bioaccumulation After gaining access into an organism, pollutants are often able to accumulate in its tissues, especially if they are not easily biotransformed into water soluble intermediates, or if they are lipid soluble. Bioaccumulation must be distinguished from biomagnification. The latter is the tendency for some chemicals to accumulate to higher concentrations at higher trophic levels (food chains) through dietary accumulation. 15.5.5 Applying a combination of Environmental Standards All the above data and information will be rendered useful and applicable to environmental management, only if they may be used in the setting up of standards.


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One way to view the whole range of available environmental standards is to take into consideration the various stages of environmental issues and activities ( or the so called Environmental Chain Effect) which need to be controlled in order to protect human health and the environment. With reference to Figure 15.1 behavioural standards would indicate how people should respect the environment and behave in order to protect it. As a rule, they are enshrined in legal regulation, but are part of education and information aimed at enhancing public awareness of the environment. For example, in the case of marine discharges from the Malta Drydocks, a well- organized sensitization campaign aimed at the workers, would greatly facilitate the implementation of better dock practices, in order to reduce the generation of liquid wastes, as well as to dispose of them in a correct manner. Product Standards concern the requirements for formulation or importation or rate of use of a particular product. In our case, it may be made illegal to use-organotins as antifouling paints at the Manoel Island Yacht yard. Activity Standard stipulates the manner in which a particular activity will need to be undertaken in order to comply with the regulations. For example, the dock activities at the smaller shipyards (e.g. Cassar Ship Repair Ltd.) may be better controlled if dock practices would be authorized only under certain conditions and if specific codes of practice are adhered to. For example, the disposal of empty solvent containers into the sea, may be strictly prohibited, so as to reduce the possibility of marine contamination by the relevant organics. Emission Standard would determine which emission concentration should not be exceeded either in absolute terms or in terms of a particular frequency and/or during a specified period of time. Most of our current regulations make use only of such standards. Zoning Standards relate environmental quality to the distance of a source of emission. Their purpose is to specify the safe distance between a pollution source and a target receptor. Immission Standards specify, sometimes in terms of probability, which concentrations or exposure levels should not be exceeded in a particular area. Environmental Quality Standards specify the concentration of a harmful chemical, which should not be exceeded in an environmental compartment, such as sediments, biota and/or water. These type of standards are required by the Water Framework Directive.


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To conclude, the Authorization System will need to consider applying any combination of such standards in order to achieve the set quality objectives. 15.6 Cost Implications of Authorization System As seen from the above account, the authorisation system and Competent Authority required to implement the provisions of the various relevant EU Directives controlling marine discharges, would need to fulfill a very wide range of responsibilities and consequently would need to have a wide range of personnel with different capabilities and professional background. It is proposed that such a unit will be constituted within the Pollution Control Co-ordinating Unit of the EPD. This unit will need to have available all the relevant material and labour resources in order to undertake laboratory and field surveys as well as to carry out all other obligations as outlined above. A well-equipped laboratory will need to be set up, and manned by fully trained personnel. There will also be the need for external consultancy services to augment the expertise available to the unit in such areas as biomonitoring and benthic surveys. The capital costs which may be involved in the setting up of appropriate laboratory facilities are presented in Table 15.2. These costs do not include the premises, basic laboratory furniture and finishes. Also, field work will require a substantial amount of boat services. No additional costs will be required for such services, since these are already available to the PCCU. Table 15.3 presented the estimated annual recurrent costs for such facilities. These costs do not cover training requirements. 15.7 Need for a Single Compliance Co-Ordinating Body As already discussed in various sections of the present report, the allocation of tasks and responsibilities amongst governmental agencies and levels of government, for the implementation of the various EU water quality Directives, has already been carried out.


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The need is now felt, to ensure that the various programmes of implementation by the different entities will be fully integrated in a common environmental strategy and workplan. For this purpose it is proposed that the Ministry for the Environment (as the Competent Authority) will set up an inter-departmental body or unit which would be responsible for the implementation of pollution reduction and pollution control programmes. Such a body, will be entrusted with the coordination of the implementation of all provisions by the relevant water quality Directives. It is proposed that this body should include representatives from the Drainage Department, the Environment Protection Department, the Water Services Corporation and others. Furthermore, it should have a sufficiently high level of administrative authority to ensure that the different players will comply with its policies and decisions. It is proposed that this Compliance-Co-ordinating Body will have the following responsibilities:

a) Co-ordinate the various programmes at the Governmental level, which will be required for the implementation of the various provisions of the EU water quality Directives;

b) Ensure that there are no gaps or inconsistencies amongst such compliance programmes as being implemented by the various Departments (e.g. the Environment Protection Department and the Drainage Department);

c) Ensure that any further development of legislation to control discharges, as well as to ensure compliance, will be carried out in full consultation with the Private Sector and Industry, as well as any other partner;

d) Assist the Private Sector in identifying the requirements arising from the provisions of the EU Directives;

e) In collaboration with the Private Sector, set up a time schedule for compliance, taking into consideration any transition periods which may be granted by the European Commission to Malta;

f) Ensure, through constant supervision, that this time schedule for compliance is being met by the various partners;

g) Elicit public support for the whole compliance programme, through comprehensive information and education programmes.


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References Axiak, V., and M. Scoullos . 1995. The case for a biomonitoring Programme of Pollution in the Mediterranean. XXXIVth Congress. Commission Internationale Pour l'Exploration Scientifique de la Mer Mediterranee. Malta 1995. Axiak, V. 1995. Pollution of the Mediterranean Sea: Assessment of the Scientific and Technological Options for Monitoring, Prevention and Cure. The Reliability and Potential of Biological Indicators. STOA Project. Axiak, V., A. J. Vella, D. Micallef, P. Chircop, B. Mintoff. 1995. Imposex in Hexaplex trunculus (Gastropoda: Muricidae): First results on biomonitoring of tributyltin contamination in the Mediterranean. Marine Biology 121: 685-691. European Commission. 2000. Guidance Document on elements for pollution reduction programmes under Article 7 of Council Directive 76/464/EEC. Brussels 20 September 2000. Adonis No. 710651. Directorate-General – Environment. ENV.E.1 – Industrial Installations and Biotechnology. 14pp. Hens, L., and Vojtisek, M. 1998. The Establishment of Health and Environmental Standards In: Environmental Management in Practice. Vol. I. Instruments for environmental management. Edited by Nath, B., Hens, L., Compton, P., and Devuyst, D. Routledge Publishers. 108-123pp. Rombke , J., and Moltmann, J. 1996. Applied Ecotoxicology. Lewis Publishers. US. Suter II, G.W., 1993.. Ecological Risk Assessment. Lewis Publishers U.S. Weinstein C. E., 1996. Ecotoxicolgy: Environmental Fate and Ecosystem Impact. In Ecotoxicity and Human Health Edited by de Serres, F.J., and Bloom, A.D. Lewis Publishers. US. 63-85pp.


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16. OVERVIEW OF COMPLIANCE COSTS, COST RECOVERY AND REQUIRED TIME FRAME.

16.1 Summary of Costs The main aim of the present study is to provide an order of magnitude estimates of the capital and recurrent cost of compliance with the provisions of the relevant EU Directives controlling direct marine discharges. The main cost analyses as identified in the various chapters, is summarised in Table 16.1. In the best-case scenario, an order of magnitude estimate yielded approximately Lm 44.97 million of capital costs to be incurred due to compliance by direct marine discharges. In the worst-case scenario, these capital costs increase to Lm 65.37 million. These estimated capital costs do not include those costs which may be required to cover capital expenditure in case that the current thermal discharges from the power stations are found to exceed the upper permissible limits of temperature to be set by the Legal Notice covering marine discharges into the marine environment which is to be issued by the Environment Protection Department. This issue is fully discussed in Chapter 8. Furthermore, these estimates do not include the required cost of sludge treatment as no such information was made available. The biggest extent of uncertainty attached to these figures is that related to the fuel and oil terminals (where capital costs may be as high as Lm16.6 million). However, we believe that it should be possible to adopt sensible and cost-effective options to ensure compliance in this sector, and that the real capital cost would be closer to that quoted for the best-case scenario, rather than that quoted for the worst-case scenario. The highest capital costs per m3 of wastewaters discharged, are those produced by ship yards and ship repairs. This is as would be expected, since relatively small volumes of wastewaters are produced, containing a wide range of potentially toxic substances which need to be controlled.


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Therefore, as a first approximation of the global estimate required to cover capital costs for compliance, the data presented in the present report indicates that these would amount to between Lm 45 to Lm 65 million, with the final figure being probably closer to the lower limit. With respect the estimated annual running costs, these amount to Lm 2.24 million or Lm 2.37 million, for the best-case and the worst-case scenarios respectively (if we include the annual costs for monitoring and reporting obligations). If costs are expressed in EUROs at today’s prices (assuming rate of exchange: LM1=2.4114 EUROs, which is the average rate of exchange over 1999 and 2000), then the estimated cost of 108.445 to 157.625 million EUROs is needed to provide the necessary infrastructure and related capital equipment to comply with EU directives related to the marine discharges. If these investment costs are amortised over a fifteen-year period at a 3% real discount rate, the annual capital requirement is between 9.082 in a best scenario and 13.201 million Euros in a worst scenario. Of course the annualised costs are sensitive to the capital recovery period and the discount rate. As the discount rate increases, the annualised capital cost rises, (ceteris paribus): and as the period over which the capital is recovered increases the annualised capital costs decreases (ceteris paribus). The costs in Table 16.2 do not include the cost of training government staff to implement the institutions required to comply with the EU directives. Table 16.2 Cost Analysis in million EUROs 1 including Annualized Costs

Future Compliance

need

Capital Costs Recurring Costs

Annualised Costs 2

Total Costs

Best Scenario 108.445 5.410 9.082 122.937

Worst Scenario 157.626 5.709 13.201 176.536

Notes.

1. LM1=2.4114 EUROs , 1999 end of period rate of exchange. This rate is taken to reflect the average rate

over the period 1999 & 2000.

2. The capital recovery factor used to determine the annualized capital cost is 0.08375 (r=3%; n=15 years)


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16.2 Scale of the Investment Needs The impact of the investment on the Maltese economy will depend to a large extent on the timing of the investment programme. Consideration of the time phasing was not a requirement of this study. However, it should be noted that the present value of the estimated total compliance costs will vary considerably according to how the capital programme is implemented over a set period of time and on how short this period is. Annualised investment needs account for 0.28 per cent of GDP for 1999 in the best scenario and 0.407 per cent of GDP in the worst scenario. (Table 16.3) Table 16.3 Annualised Capital Cost of Approximation

Water future needs Annualised Capital Costs (millions)

EUROs per capita 1

(thousands) % of GDP 2

Best scenario 9.082 23.389 0.280 Worst scenario 13.201 33.997 0.407 Notes:

1. Based on an estimated population of 388,297

2. Based on GDP at factor cost of Lm1345.5 millions for 1999 or 3244.5387 millions EUROs

At this stage, it would be worthwhile to try and compare the estimated levels of local cost of compliance to the relevant EU water directives which relate to marine discharges, with similar compliance costs which have been estimated for other countries. For this purpose, we used a report published in 1999 (Boyd and Markandya, 1999) which dealt with compliance costing for Cyprus. This report also includes figures of compliance costs in other CEECs. In undertaking such comparisons, it is to be noted that the costing estimated for CEECs and Cyprus include compliance with all EU water quality Directives, including the Groundwater Directive (80/68/EEC), the Nitrates Directive (91/676/EEC), and Bathing Water Directive (76/160/EEC), while the local estimated costs of compliance relate only to marine discharges. Nonetheless, Boyd and Markandya (1999) indicate that compliance with the urban wastewater treatment Directive (91/271/EEC) was the major cost element in their estimates.


175

This is similar to the findings of the present study. Therefore, such comparisons of compliance costing would be useful, if they are interpreted with proper caution. When expressed in 1997 prices the local annualised investments needs account for 0.31 per cent and 0.44 per cent of Malta’s GDP in a best and worst scenario respectively. This figure is considerably lower than the needs of CEECs and of the Republic of Cyprus, which stand at 1.12 per cent and 1.09% respectively. The difference in annualised costs per capita between Malta and the CEECs and the Republic of Cyprus is substantial, 23.27 EUROs for the best scenario or 33.83 EUROs for the worst scenarios in Malta compared to 486 EUROs per capita for the CEECs and 97 Euros for Cyprus. Details of the comparisons are given in Table 16.4 below. Table 16.4 Annualised Capital Cost of Approximation at 1997 prices in EUROs

Annualised Capital Cost 1

Euro per capita 2 % of GDP 3

Water future needs

Malta Malta Cyprus4 CEECs 5 Malta Cyprus CEECs

Best Scenario

8.762 23.27 97 486 0.31 1.09 1.12

Worst Scenario

12.736 33.827 0.44

Note: 1. This figure for capital at 1997 prices is obtained after allowing for a rise in the cost of capital goods of

3.52% (Economic Survey 1999). 2. Based on an estimated population of 376,500 in 1997 3. GDP at 1997 constant prices is estimated at EUROs 2862.833 given that GDP = LM1, 249m and an

exchange rate of Lm1=2.2921 EUROs then known as ECUs. 4. Boyd and Markandya, 1999 5. EDC (1997) Compliance Costing for approximation of EU Environmental legislation

As illustrated in Table 16.5, the estimated total annual compliance cost (i.e. annualised capital costs plus recurring costs) are 122.937 million EUROs for the best scenario which correspond to 316.61 EUROs per capita or 3.79% of GDP.


176

Table 16.5 Total Annual Capital & Recurring Costs of Approximation in EUROs Future water needs Total annual costs EUROs per capita 1 % of GDP 2

Best Scenario 122.937millions 316.61 3.79 Worst scenario 176.536 millions 454.64 5.44

Notes:

1. Based on an estimated population of 388,297.

2. Based on an estimated GDP at factor cost of 3244.5387 EUROs

In per capita terms, (Table 16.6) total annual compliance costs for marine discharges are about 3.5 times higher than the average per capita figure for the EU 15 and 2.5 times that of the Republic of Cyprus. As a percentage of GDP the total annual compliance cost for Malta for the best scenario are almost eight times as high as that for the EU member states and about three times as high as that for the Republic of Cyprus. Table 16.6 Total Annual (Capital and Recurring) Costs of Approximation at 1997 prices Future water

needs Total Costs

1 Euros per Capita 2 % of GDP 3

Malta Cyprus 4 EU 5 Malta Cyprus

EU

Best Scenario

118.549 314.87 124 90 4.14 1.39 0.53

Worst scenario

170.259 452.22 5.95

Notes

1.The figure for capital at 1997 prices is obtained after allowing for a rise in the cost of capital goods of 3.52%.

A deflator of 1.0465 was applied to adjust the recurring cost. Labour costs are a main component of such costs.

Wages are annually adjusted to. reflect cost of living increases as measured by the RPI.

3. Population of 1997 is estimated at 376,500.

4. GDP for 1997 at constant prices is estimated at LM1249 million or 2862.833 EUROs at an exchange rate

of Lm1=2.2921 EUROs

5. Boyd and Markandya, 1999

6. EDC (1997) Compliance Costing for Approximation of EU Environmental Legislation in the CEECs


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16.3 Potential benefits of the Investment Programme Compliance with the EU directives related to the marine environment would inevitably improve the quality of the environment in Malta for everybody. Compliance with these directives will reduce the levels of water contamination. As a result, the natural environment will be better protected. Moreover, the welfare of both the Maltese as well as of the tourists who visit Malta annually will improve, whether directly or indirectly. Compliance with these directives will best be undertaken as part of a national plan to enhance and protect the environment. Piecemeal control may not be cost effective. This overall view will have benefits in terms of increased efficiency, as well as with respect to the integration of environmental protection. The planned infrastructural investments to comply with the directives in the water quality will protect the already very scarce resources of potable water. Water for irrigation purposes may be obtained from recycled water from the sewage plants. This will result in savings of electricity and the marine discharges generated from such source. The minimisation of contamination of seawater will also have health benefits besides ensuring that Malta’s bathing waters are maintained at a high standard with the obvious benefit to the tourist industry. 16.4 Cost Recovery Compliance with EU legislation implies that additional capital and running costs have to be incurred to cover the collection, treatment and the discharge of wastewater. Theoretically, these costs have to be partly or wholly borne by the user, consumer or polluter, whether domestic, industrial or agricultural. However, who actually pays for these additional costs varies from industry to industry and is determined by The time over which the subsidy or charge is paid The sensitivity of the quantity demanded and supplied to price changes and the

market structure in which such businesses are operating and The legal framework in which firms operate. These factors are examined below.

The initial bearer of compliance costs could be determined at law, but eventually, it is the market conditions that establish who will ultimately pay the additional costs incurred. Thus, it will be administratively easier to raise a charge on effluent on the producers and this could be paid by say a fish farm, a pig breeder or an oil recycling plant. But, if the market conditions permit, it may be presumed that this


178

charge will be passed on to the consumer. This is the method adopted in the case of excise duties on cigarettes and spirits. Similarly, if the legislation indicates the buyer as the bearer of the charge, say the buyer of chemicals or pesticides, it could well be that the market conditions are such that part of this charge will be borne by the producer. The consumer will thus be transferring part of the charge on the producer. In the case of the installation of additional equipment to treat wastewater, the initial capital costs and running charges will have to be borne by the producer. But, evidently, these costs will be taken into account in the pricing policy of the firm and they will be passed on to the consumer whenever the market permits. Therefore, to be able to anticipate how these costs may be recovered, it is important to have detailed analyses of the markets in which fish farms, water producers, oil field terminals, shipyards, power production and hotels and restaurants operate. Although when compiling this report efforts were made to collate detailed financial information to work out the unit cost and the additional cost of compliance, the information made available by firms is very scanty. It is not detailed enough to evaluate the additional compliance cost per unit of good or service produced provided by each operator. Moreover, detailed information from which one can derive the values for the elasticity co-efficient of demand and supply for the various goods and services provided is not available. It was even more difficult to have figures on the profit margins of these operators. To obtain such statistical data, an economic impact assessment on the various operators will have to be carried out. In view of this, available data is used to give illustrative examples of how costs may rise as a result of compliance. 16.4.1 Additional Costs due to Compliance: Waste Oil Company Ltd. For example, for the worst-case scenario, it is suggested that the Waste Oil Company Ltd which at present has an output of 500m3 of recycled oil needs to undertake a capital expenditure of Lm300,000 and must incur a recurrent cost amounting to Lm13,500 annually. If we assume that capital is recovered at the rate of LM20,000 annually over a period of fifteen years and that the Waste Oil Company Ltd, pays an interest of 6% on its bank loan then in the first year the company will have to pay Lm20,000 ……. To pay an instalment on capital Lm18,000 ……. To cover interest payment at 6%


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LM13,500 …. … Running costs inclusive of monitoring costs Lm51,500 ……. Total compliance costs to cover the 1st year The additional cost per unit of output in this case would amount to Lm 103. The compliance costs will fall as the outstanding capital that should be paid decreases. For example, in the seventh year, the company would have paid Lm120,000 of its capital. Outstanding liabilities in the seventh year would include:- Lm20,000 ……. Annual repayment on capital Lm10,800 ……. 6% interest on Lm180,000 Lm13,500 ……. Running costs including monitoring Lm44,300 ……. Total costs to be covered during the 7th year This amounts to an additional cost of Lm88.60 per cubic metre of recycled oil annually. This figure is exclusive of additional costs e.g. increases in labour costs or monitoring costs that may have to be incurred over time. Since detailed knowledge of neither the cost of operation nor the various markets for this product is known, it is difficult, at this stage, to indicate how much of the additional costs can be borne by the producer and what fraction of compliance costs can now or in the future be shifted forward on the various consumers.

16.4.2 Additional Costs due to Compliance: MOBC Ltd. Similarly, it is assumed that The Mediterranean Offshore Bunkering Co. Ltd may need to spend LM300,000 to comply with EU water directives. This company has a fuel storage capacity of 43,000m3. If we assume a fifteen year repayment period of such a loan at 6% interest rate the additional compliance cost per cubic meter of oil stored would range from Lm1.11c6 in the first year to 94c8 in the seventh year of compliance. These additional compliance costs may be absorbed from profits. Alternatively, the firm could raise the price of its product. But if this company operates in a tough competitive international market, it may not be economically feasible to increase its price without risking losing some of its customers. Hence alternative sources of recovering costs will have to be sought.

16.4.3 Additional Costs due to Compliance: Fish and Fish Ltd


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Another example of how compliance costs may impinge on the cost of production and consequently on the price of goods sold is given for fish farming. For example, Fish and Fish Limited, which produces 300 tons of fish, is expected to incur a capital expenditure of LM10,000 and a running cost of Lm3,000 annually. If we assume that the settling tank has a lifetime of ten years, then the annual additional costs that will be incurred in the first year will be as follows:- 1St Year Capital expenditure …… Lm1,000 Interest at 6% …… 600 Running costs ………... Lm3,000 Total expenditure …… Lm4,600 or Lm15.33 additional cost per ton of fish reared annually Again, here it is very difficult to establish whether it is feasible for this fish farm to carry the additional costs or to pass on the whole or part of these additional costs on the consumer. This fish farm might be operating in a very competitive market. Competition may increase if more producers supply these fish. In this case, it will become more difficult to increase prices. This situation will deteriorate if demand for fish cultured on this farm falls over time because of a change in consumer tastes or if alternative fish compete for the same market. In such cases, it becomes imperative that such firms have access to government incentives, which are being proposed in the Business Promotion Act. Alternatively, firms may participate in foreign programs like MEDA, LIFE or SMAP and hence be in a position to recover part of their compliance costs, thus reducing the burden of compliance. In the process, they will avoid risking losing the market for their goods or services. If part of the compliance cost is recovered from these sources, the cost of compliance is shifted on the local taxpayer if local funds are forthcoming or on the European taxpayer who would be paying funds to mitigate local compliance costs.

16.4.4 Recovery of Compliance Costs: Drainage Department Other economic instruments may be used to recover compliance cost. For example, the Drainage Department is expected to spend an additional Lm38 million to treat waste waters and to comply with the relevant EU water quality directives. Total discharges are estimated at 25.8m3 annually. If the department obtains a soft loan repayable over a period of twenty years at 3% interest and it is assumed that


181

this capital expenditure is paid after twenty years the department will need the following additional finance in the first year: Capital Cost …….. Lm1.9m Interest on loan …… Lm1.14m Total Cost …… Lm3.04m or an average of Lm117,829.457 per cubic meter of waste water treated annually. In the tenth year, the Drainage Department would require Capital Cost ………. Lm1.9m Interest payment ……. Lm0.627m Total cost ……... Lm2.527m or Lm97,945.736 per cubic metre of waste water treated assuming that the volume of treated water remains at the same level. If the volume of waste water treated falls e.g. because of more compliance from the industrial sector, then the annual compliance cost per unit would rise further. In this case the Drainage Department may recover part of the costs from waste water tariffs. Tariff charges should be set to exceed the cost of treatment. Thus businessmen will be encouraged to treat and possibly re-use waste water rather than diluting it as a means of meeting the effluent standards. Effluent charges will be based on volume and pollution load or the size of the industrial installation. It will not be feasible to set a standard charge on all firms irrespective of size. Small firms may find it more difficult to recover costs. Part of the compliance cost may be recovered from enforcement penalty charges. Offenders may have to pay fines if acceptable limits are exceeded. Moreover, performance bonds may be paid prior to potential polluting activity or liability assignments or fines will be paid for pollution damages. User charges based on water consumption may be meditated for domestic waste. In such cases caution must be paid not to induce unnecessary burdens on low income earners. Perhaps, it could be suggested that no such charges are paid on a minimum volume of discharge per person. This is more important if present subsidies on water and electricity consumption are removed after the year 2002 and prices will reflect costs. 16.4.5 Cost Recovery: Conclusion


182

Recovery of compliance costs is complex. Measures taken may have wide economic, social and political implications. Different economic instruments may be used to achieve this end. However, before introducing any measures, more detailed analyses of these markets for the different goods and services provided will have to be first undertaken. Only then will it be feasible to establish which costs are to be carried by consumers in the form of higher prices, which costs will be absorbed by which businesses and which costs will be suffered by society at large in the form of taxes or charges. Unless such an economic impact assessment is carried out, policy measures may be immature, ineffective and may run the risk of creating unnecessary economic burdens which may impact negatively on businesses especially those whose demand is very price sensitive. 16.4.6 Financing of upgrading programmes As reviewed above, compliance with the EU legislation implies additional capital and operational costs which may impact negatively on the cost of production. In cases where profit margins are low or non-existent, prices may rise sharply. Such an increase in costs may jeopardise the competitiveness of these firms which may lose their market share besides reducing job opportunities in these industries. This situation may be aggravated in sectors e.g. energy and shipbuilding where the compliance costs may be high but profit margins are very narrow or non-existent at present. Price rises may also negatively affect the demand for those goods and services whose demand is very price elastic e.g. fish farming. Caution must therefore be taken to contain the impact of these compliance costs especially in the short run. One way of neutralising the effect of cost and price increases is by encouraging firms to make maximum use of programmes or incentives schemes aimed at damping the damaging effects of these compliance costs. Maltese firms, which as a result of their production of goods and services have direct or indirect (because they are connected with the main sewer) marine discharges, may benefit from local or foreign incentive schemes or programmes which are specifically available to businesses which take initiatives for the protection of the environment. A review of possible sources for the financing of upgrading programmes is being included in ANNEX 7.


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16.5 Required Time Frame for Compliance As regards the required time frame for compliance, it was estimated that this will vary from 1 to 4 years, according to the particular sector being considered (Table 16.1). In each case, the time frame for compliance has been estimated in terms of the number of years required for implementation of the relevant compliance programme, which may be required, assuming that the necessary administrative decisions have been already taken and that the necessary financial and other resources would have been made already available. Therefore, no allowance is being made for undue delays in compliance-related policy and decision making by the respective authorities or companies, as well as for any difficulties, which may arise to allocate the necessary funds and other resources. It is not within the competence of the present author or his collaborators to be able to make such assessments. In case of discharges from public sewers into the marine environment, the Drainage Department has indicated that the Malta North and Malta South sewage treatment infrastructure is expected to be set up and fully operational in compliance with EU Directives, by 2005. Figure 16.1 presents graphically, the required time frame per sector. It includes provisions for the time required for the setting up of a Compliance Co-ordination Unit (Chapter 15), which would implement the various required modifications, and for a period in which to identify and procure the required financial and other resources for implementation. As indicated in this figure, assuming that Malta will aim at EU accession at the beginning of 2003, then the longest time frame required will be for the compliance by the public sewerage system, (i.e. by 2005) as indicated above. Under these circumstances, it would be wise to ask for a transition period of 3 to 4 years and preferably 4 years, for Malta to comply with the provisions of the relevant directives. This transition period will not be specified for any one single sector, but will apply for all sectors. This would make up for any delays in efforts to procure the necessary financial and other resources as well as in decision-taking for the implementation of the compliance programme. We are of the opinion, that such a transition period of 4 years is quite reasonable since:

a) It will not induce any distortion of competition within the EU;


184

b) It should not have heavy consequences on the EU budget;

c) It is reasonably limited in time and scope.

References Boyd, R., and Markandya, A. 1999 Approximation of Environmental Legislation. The role of compliance costing for the approximation of EU environmental legislation in Cyprus. Final Report. Metroeceonomica Ltd.


185

Figure 7.1 Location of oil spills around Malta and in the Sicilian Straits for 1999.

Spills were identified from ERS SAR images. (Information provided by JRC)

Figure 7.2 Location of Bunkering Sites (Circles) and of Fuel Installations

Investigated (Squares)

Power Generation Turbines and Boilers

Cooling sea water

Chlorine and Clamtrol

Marine Discharges

S

Discharges during

4

Blow-down water

Boiler Washings

Water with much suspended solids

Fuel dewatering Settling tanks Oil Interceptor

Rain run off

3

2

1

Fuel Tanks

igure 8.1

Evaporators

ea water

Demineralization Plant

Brine

regeneration

6

Sulphuric acid and Sodium Hydroxide

5

Scale control Chemicals

Layout of more relevant Operations within Marsa Power Station showing generation of different wastewater streams

F

Power G neration Turbine and Boilers

Cooling sea water

Chlorine

Marine Discharges

Evaporators Sea water

Demineralization Plant

4

Sulphuric acid and Sodium Hydroxide

Other chemicals

Blowdown water

Boiler Washings

Water with much suspended solids

Settling Tanks/ pH Control

Fuel dewatering Settling tanks Oil Interceptor

3

2

1

Rain run off

Fuel Tanks

Scale control Chemicals

re 8.2 Layout of more relevant Operations within Delimara P

es

Brine

Discharges during regeneration 5

6

ower Station showing generation of different wastewater streams

Figu

Figure 8.3 Thermal Discharges emitted from Marsa Power Station as seen from satellite images (Landsat 5, November 1998). Image was generated using algorithms specifically prepared for this locality. Surface temperatures are colour coded as seen in the smaller box (red warmer waters, blue colder waters).

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Figure 10.1 Type and number of factories present in Hal Far Industrial Estate

Figure 10.2: Discharge of wastewaters from the Comino Pig Farm (IN2) producing a

visible turbid plume. The extent of this plume is indicated by white arrow.

Figure 13.1 Major runoffs from agriculture, showing graphically relative estimated amounts of pesticides, and nutrients (data from Castaglia, 1996) and location of principal watercourses and engineered works undertaken in them.

Figure 14.1 Trends in the importation of different classes of compounds

0

100000

200000

300000

400000

500000

600000

700000

800000

900000

1995 1996 1997 1998 1999

kg

Nitrogen containing

Phosphorus containing

fluorides

cyanides

organics

metals

Figure 15.1 Environmental Standards in relation to the environmental

chain effect. Environmental Chain Effect Applicable Standards Perceived Human Needs Behavioural Standards

Industrial Activity Product Standards / Activity Standards Discharges of wastewaters Emission Standards Immission Standards and Zoning Standards

Effect on Environmental Quality Environmental Quality Standards

Figure 16.1 Required Time Frame for Compliance with EU Directives covering Marine Discharges

2002 2003 2004 2005 2006 Setting up of Compliance Co-ordination Unit

Identification of Resource Fish Farmin

Fuel and Oil Terminal Electricity and Water Productio

Industry+ Shipyard Hotels + Recreatio

Sewage Di

Malta Accession

Required Transition Period

Key

Planning/Study/Evaluation/Decision

Construction

Commissioning and start-up

scharges

2001 s g s n s n

Table 4.1 List of chemicals analysed for and Laboratories

Chemical Monitored For Analytical Laboratory

Monobutyltin 1

Dibutyltin 1

Tributyltin 1

Total Organo tins 1

Petroleum Hydrocarbons 1

Cyanides 1

Fluorides 1

Hexachlorocyclohexane (Lindane) 2

DDT (dichlorodiphenyl trichloroethane) 2

Pentachlorophenol PCP 2

Aldrin 2

Dieldrin 2

Endrin 2

Isodrin 2

Hexachlorobenzene HCB 2

Hexachlorobutadiene HCBD 2

Chloroform 2

1,2 dichloroethane EDC 2

Trichloroethylene TRI 2

Perchloroethylene PER 2

Trichlorobenzene TCB 2

Carbon tetrachloride 2

Parathion 2

Malathion 2

Cypermethrin 2

Dichlorovos 2

Mercury and its compounds 3

Cadmium and its compounds 3

zinc 3

copper 3

nickel 3

chromium 3

lead 3

selenium 3

arsenic 3

boron 3

Inorganic phosphorus compounds 4

Nitrates 4

Nitrites 4

Phosphates 4

Total Phosphorus 4

NotesLaboratory 1 = Department of Chemistry (Prof. A. Vella)Laboratory 2 = Progetto Natura srl (Italy) (Dot. P. Pucci)Laboratory 3 = Department of Chemistry (Dr. G. Peplow)Laboratory 4 = Department of Biology (Prof. V. Axiak)

Table 4.2 Results of analysis of samples collected from various sites for the purpose of the present study

Mono-butyltin

Di-butyltin Tri-butyltinTotal Otgano-tin

Petroleum Hydrocarbons

PHC Description Cyanides Fluorides ChloroformTrichloro-ethylene

Perchloro-ethylene

Zinc Copper Nickel Chromium Lead Selenium Arsenic Boron Nitrates Nitrites PhosphatesTotal Phosphorus

Maximum Permissible Limit Values A 500ug/L 5 mg/L 0.5-2mg/L 2mg/L 12 ug/L 10 ug/L 10 ug/L 1 mg Zn/L 0.5 mgCu/L 0.5 mg Ni/L 0.5 mg Cr/L 0.2 mg Pb/L 0.05 mg As/L 2 mg /L B 1 to 2 mg/LUnits of measurement ngSn/L ngSn/L ngSn/L ngSn/L mg/L ug/L mg/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L mg/L ug N/L ug N/L ug P/L mg/L

Analytical limit of detection 12 ng Sn/L 12 ng Sn/L 12 ng Sn/L12 ng Sn/L 0.2 mg/L 1 ug CN/L0.05 mg F/L 0.1 ug/L 0.1 ug/L 0.1 ug/L 0.02 0.1 0.1 1 ug N/L 1 ug N/L 0.01 ugP/L 0.1 mg P/LSample Code Location Sample Code

DO1-060700 Malta Drydocks dockwaters 1571 4892 8261 14724 1.7 degraded stuff 0.6 0.1 511 230 58 0.29 0.17 0 0.5 0 56.03 0.30 0.21 1.95 DO1-060700

DO1-070700 Malta Drydocks dockwaters 619 1134 1451 3204 0.3 degraded stuff 0.5 570 45 63 0.27 2.63 0 1 0 30.28 0.10 0.66 1.81 DO1-070700

DO2-060700 MD Tank Cleaning Facility (Separator Outflow) 0.4 high amount of diesel-type 0.5 0.1 47 2.2 122 0.9 0.12 0 0.8 0 64.51 1.21 2.91 12.22 DO2-060700

DO2-070700 MD Tank Cleaning Facility (Separator Outflow) 2.6 high amount of diesel-type as well as lub-like 0.6 0.2 30 2.2 111 0.44 0.23 0 0.4 0.8 2.49 0.04 2.85 16.71 DO2-070700

DO3-030700 Marsa Menqa (surface waters) 431 954 788 2174 0.3 degraded 0.6 0.1 83 5.7 18 0.19 0.08 0 0.5 2.6 24.21 0.09 0.00 0.15 DO3-030700

DO3-050700 Marsa Menqa (surface waters) 221 78 318 617 0.7 sig diesel-like and lube-like 1.2 0.1 0.1 59 4.5 21 0.39 0.12 0 1.9 0.3 21.33 0.18 0.51 11.63 DO3-050700

DO4-030700 Marsa Quay 1 (surface waters) 576 0 957 1533 0.2 0.6 0.1 0.1 74 1.5 35 0.08 0.44 0 1 1.4 56.89 0.35 0.00 DO4-030700

DO4-050700 Marsa Quay 1 (surface waters) 0 0 0 0 0.2 0.7 0.1 0.1 30 3.2 1.1 0.11 0.28 0 0 0.2 120.68 0.32 1.01 2.66 DO4-050700

DO5-100700 Manoel Island Yachtyard (Slipway) 0 630 470 1100 0.4 0.6 0.1 110 18 88 0.11 0.24 0 2.1 0.4 3.45 0.05 0.08 0.20 DO5-100700

RO1-040700 RO Plant 1 Ghar Lapsi (undiluted effluent) 0.4 0.2 42 1.1 23 0.19 0.12 5.85 2.9 6 29.74 0.03 0.26 1.71 RO1-040700

RO2-040700 RO Plant 2 Cirkewwa (undiluted effluent) 0.7 0.1 57 1.2 11.1 0.42 0.18 1.85 1.7 4.7 15.23 0.03 0.00 -0.06 RO2-040700

RO3-040700 RO Plant 3 Penbroke (undiluted effluent) 0.8 0.3 47 0.3 5.4 0.13 0.28 1.11 2.1 2.1 7.74 0.06 0.01 0.00 RO3-040700

EN1a-030700 Marsa PS Tubine Water (cooling) 684 521 315 1519 0.30 degraded with lube-oil type 0.6 0.1 70 3.2 92 0.6 0.55 0 1.4 2.2 3.74 0.04 0.00 0.11 EN1a-030700

EN1a-050700 Marsa PS Tubine Water (cooling) 0 0 0 0 0.2 degraded with lube-oil type 0.6 0.1 72 6.8 57 0.07 0.15 0 1.2 0.7 4.84 0.06 0.07 0.38 EN1a-050700

EN1b-030700 Marsa Power Station Boiler water 792 681 0 1473 0.2 degraded with lube-oil type 0.6 0.1 0 17.3 3.1 0.02 0.4 0 0 0.2 1.07 0.01 8.61 20.25 EN1b-030700

EN1b-050700 Marsa Power Station Boiler water 0.00 0.00 0.00 EN1b-050700

EN2-030700 Delimara Power Station (Single Pit-Effluent) 733 395 0 1128 0.3 degraded with lube-oil type 0.5 0.1 0 2.7 91 0.15 0.53 0 0 2.3 17.21 0.01 0.04 0.06 EN2-030700

EN2-050700 Delimara Power Station (Single Pit-Effluent) 0 0 0 0 0.3 degraded with lube-oil type 0.6 0.1 61 9.2 50 0.05 0.27 0 0.7 0.6 1.85 0.06 0.00 5.37 EN2-050700

EN3-030700 St. Lucian (Enemalta Slop Tank- effluent) 740 980 412 2132 0.8 degraded 0 0.36 0.6 0.1 0 2.2 6.7 0.03 2.01 0 0 0.6 7.37 0.13 0.81 2.78 EN3-030700

FF1-030700 Fort Saint Lucian (discharge effluent) 489 0 0 489 0.4 degraded 0 0.88 0.6 0.1 13 1.5 125 0.1 0.94 0 0.6 3.7 46.92 0.20 0.34 20.96 FF1-030700

FF4-070700 Mistra Fish Farm 0 0 0 0 1.62 0.04 0.00 0.12 FF4-070700

FF7-070700 Mellieha P2M Fish farm 0 0 0 0 2.84 0.03 0.03 0.01 FF7-070700

FF8-060700 Comino Fishfarm (surface waters near cages) 0 0 0 0 2.66 0.04 0.00 0.09 FF8-060700

MA1-100700 Pieta Marina (surface waters) 0 0 0 0 0.8 degraded 36 2.1 76 0.11 0.18 0 1 0 23.96 0.06 0.00 MA1-100700

MA2-100700 Ta Xbiex Marina (surface waters) 0 0 0 0 1.3 degraded 25 1.1 87 0.12 0.36 0.24 0.8 0.3 20.74 0.06 0.00 MA2-100700

MA3-100700 Msida Marina (surface waters) 0 0 0 0 0.2 degraded 49 0.1 71 0.26 0.19 0.27 1.1 0 9.41 0.02 0.04 0.26 MA3-100700

MA4-060700 Mgarr Gozo Marina (surface waters) 0 0 0 0 0.6 degraded 40 9.2 101 0.33 0.2 0.3 1.5 0 0.97 0.05 0.01 -0.06 MA4-060700

OL1-100700 Grand Harbour MOBC Depot (surface waters) 0.8 degraded with sig lube oil type 6.45 0.04 0.00 0.41 OL1-100700

OL3-070700 Bunkering Site Anchor Bay (surfae waters) 0.5 degraded with sig lube oil type 1.68 0.04 0.01 -0.02 OL3-070700

OL4-070700 BS Melliehaunkering Site (surface waters) 0.5 degraded with sig lube oil type 1.24 0.03 0.03 0.11 OL4-070700

SG1-030700 Xghajra Sewage Outfall effluent 0 0 450 450 0.5 sig amount of diesel-like 0 0.28 1.4 0.1 0 12.5 2.7 0.1 0.12 0 0 0.4 37.93 0.03 10.68 20.73 SG1-030700

SG1-040700 Xghajra Sewage Outfall effluent 0 724 749 1473 0.3 moderate amount of diesel-like material 0 0.34 1 0.2 0 19.3 46 0.13 0.5 0 0 0.3 22.41 0.12 11.08 37.73 SG1-040700

SG1-050700 Xghajra Sewage Outfall effluent 0 490 567 1057 1.4 sig. Amount of diesel-like material 0 0.34 1.3 0 3.3 50 0.17 0.2 0 0.8 0.4 16.52 0.01 11.15 46.24 SG1-050700

SG2-030700 Cumnija Sewage Outfall effluent 0 485 406 891 0.8 sig higher boiling lube-oil type 16 0.28 2.3 0.1 0 15.1 7.3 0.07 0.02 0 0 0.3 2.84 0.02 20.83 30.65 SG2-030700

SG2-040700 Cumnija Sewage Outfall effluent 0.7 degraded stuff 0.34 0.8 0.1 0 3.9 0.7 1.44 0.31 0.46 0 2.6 22.94 0.03 20.04 22.62 SG2-040700

SG2-050700 Cumnija Sewage Outfall effluent 0 0 769 769 1.2 degraded stuff 0 0.28 0.9 0.2 0 2.6 2.8 0.15 0.14 0 0 0.5 2.76 0.04 17.14 21.67 SG2-050700

SG3-050700 Ras il Hobz Sewage Outfall effluent 0 0 0 1 0.3 degraded stuff 0 0.58 0.4 0.1 0 6.6 0 0.12 0.11 0.24 0.4 0 5.69 0.01 11.08 41.51 SG3-050700

SG3-060700 Ras il Hobz Sewage Outfall effluent 0 625 316 941 0.9 lube-oil type material 6 0.66 0.3 0.2 0 2.1 0 0.57 0.48 0.22 0 0 11.21 0.03 17.41 23.09 SG3-060700

SG3-070700 Ras il Hobz Sewage Outfall effluent 0 555 422 977 0.2 degraded stuff 3 0.72 0.6 0.1 0 14.9 3.3 0.05 0.17 0 0 0 3.89 0.04 9.49 22.14 SG3-070700

SG4-050700 Comino Pig Farm Effluent 0.2 degraded stuff 10 0.58 2.6 292 150 2.1 0.87 0.1 1.13 1.8 0 15.44 0.14 28.48 103.73 SG4-050700

SG5-030700 Marsa Pumping Station undiluted wastewaters 0 0 394 394 0.3 6 0.28 2.1 0.5 0 1.4 2.1 0.03 0.72 0 0 0.3 1.68 0.08 7.76 33.48 SG5-030700

SG6-030700 Hal Far Industrial Unused Treatment Plant (from reservoir) 0 0 0 0 0.3 0 0.48 0.7 0.1 0 2.3 8.9 0.11 0.2 0 0 0.5 1.30 0.10 5.45 17.89 SG6-030700

Notes: Date of collection appears in sample code number

A = Maximum Permissible Limits in the forthcoming LN of EPD

B = Upper permissible limit for Boron as indicated in LN8/93

0 = below detection limit for analytical protocol

Table 6.1 Fishfarming Production Units (from Schembri et al. 1999)

Production Unit Location Location of shore base facilities

Total cage surface area

(sq. m)

Annual production

capacity (m. tons)

MALTA MARICULTURE LTD.

South Comino Channel

Marfa peninsula

50,000

500

P2M COMPANY LTD.

Mistra Bay (nursery) St.Paul’s Islands Mellieha Bay

Mistra Bay Redoubt

80,000

1000

MALTA FISHFARMING LTD.

Marsaxlokk Bay (nursery) Munxar Reef l/o St. Thomas Bay.

*Marsaxlokk

N/A

700

FISH & FISH COMPANY LTD.

Il-Hofra z-Zghira, l/o Delimara

*Delimara

N/A

400

Land-Based Unit

Location

Type of production

Annual

production

NATIONAL AQUACULTURE CENTER

Fort San Lucjan, Marsaxlokk

Sea bream hatchery

1.0 million fry

SEALAND LTD.

Pwales Valley, Xemxija

Sea bream hatchery

1.5 million fry

AQUACULTURE DEVELOPMENTS LTD.

Salt Pans, Salina Bay

On growing of sea bream

50 tons

Table 6.2 Summary of Findings for the Fish Farming Sector

Reference Number

Site Location

Estimated Annual

Volumes of Discharges

(m3)

Capital Costs for Compliance

Running Costs (annual) Time

Frame (years)

Best Case Scenario (BCS) Worst Case Scenario (WCS) BCS WCS Monitoring FF1 National

Aquaculture Centre

239,616 Lm 25,000 to connect toilet wastes to sewers

Lm 100,000 for further treatment

Lm 2,500 Lm 10,000

Lm 2000 1

FF2 Mistra P2MFishfarm

390 Lm 20,000 for biological treatment to remove nutrients etc..

Lm 20,000 Lm 2,000 Lm 2,000 Lm 2000 2

FF3 Malta MaricultureLtd.

1,080 Lm 10,000 for settling tank Lm 20,000 for additional treatment

Lm 2,000 Lm 2,000 Lm 2000 1

FF4 Fish and Fish Ltd. 300 Lm 10,000 for settling tank Lm 10,000 Lm 1,000 Lm 1,000 Lm 2000 1

Total for whole Sector: Lm 65,000 Lm150,000 Lm7500 Lm15000 Lm8000

Table 7.1 Summary of Findings for Fuel Terminals Sector

Reference Number

Site Location Estimated Annual

Volume of Discharges (m3)

Capital Costs for Compliance Running Costs (annual) Time

Frame (years)

Best Case Scenario Worst Case Scenario BCS WCS Monitor

ing

OT1 MD Tanker Cleaning

Facility 225,000

Upgrading of present TP to comply with 15 ppm limit:

Lm2.5 million

Relocation of whole plant: Lm 15 million

Lm 20,000 Lm 50,000 Lm

5,000 1 to 4 years

OT2 Oiltanking (Malta) Ltd. 100 none Lm

2000 --

OT3 MOBC Ltd. 360Lm45,000 for further

treatment in case of planned expansion, plus oil sensor.

Lm300,000 if present WTP is

insufficient Lm 1200 Lm 7,500

Lm 2500

1

OT4 Waste Oils Co. Ltd. 100 none Lm300,000 to control

heavy metals none Lm 7,500

Lm 6,000

1

OT5 Enemalta Petroleum

Division 16,500 Lm800,000 Lm 1 million Lm 20,000 Lm 25,000

Lm 5,000

2

Total for whole Sector Lm 3.345m Lm16.6 m Lm 41,200 Lm90,000 Lm20,500

Table 8.2 Results of Monitoring of surface waters or of marine discharges from Marsa and Delimara Power Station

MBT DBT TBTtotal Organotins PHC

PHC Description Chloroform

Perchloroethylene PER zinc copper nickel chromium lead arsenic boron Nitrates Nitrites Phosphates

LIMITING VALUE (From EPD LN) 500ug/l 12 ug/l 10 ug/l 1 ppm 0.5 ppm 0.5 ppm 0.5 ppm 0.2 ppm 0.05 ppm 2 ppm?Units ngSn/l ngSn/l ngSn/l ngSn/l mg/l ug/l ug/l ppb ppb ppb ppb ppb ppb ppm

Location of Sampling Stations

Marsa Menqa (3rd July 2000)431.4 954.4 788.3 2174 0.3

degraded 0.6 0.1 83 5.7 18 0.19 0.08 0.5 2.6 24.21 0.09 0.00

Marsa Menqa (5th July 2000)221.2 77.9 317.6 617 0.7

sig diesel-like and lube-like 1.2 0.1 59 4.5 21 0.39 0.12 1.9 0.3 21.33 0.18 0.51

Marsa (in front of Vernon Foods) 3rd July 2000576.1 0.0 957.4 1533 0.2 0.6 0.1 74 1.5 35 0.08 0.44 1 1.4 56.89 0.35 0.00

Marsa (in front of Vernon Foods) 5th July 2000 0.0 0.0 0.0 0 0.2 0.7 0.1 30 3.2 1.1 0.11 0.28 0 0.2 120.68 0.32 1.01

Marsa PS Tubine Water (cooling) 3rd July 2000684.0 520.6 314.6 1519 0.30

degraded with lube-oil type 0.6 0.1 70 3.2 92 0.6 0.55 1.4 2.2 3.74 0.04 0.00

Marsa PS Tubine Water (cooling) 5th July 20000.0 0.0 0.0 0 0.2


Marsa Power Station Boiler water 3rd July 2000792.0 681.0 0.0 1473 0.2

degraded with lube-oil type 0.6 0.1 0 17.3 3.1 0.02 0.4 0 0.2 1.07 0.01 8.61

Delimara Power Station (Single Pit) 3rd July 2000732.8 394.9 0.0 1128 0.3

degraded with lube-oil type 0.5 0.1 0 2.7 91 0.15 0.53 0 2.3 17.21 0.01 0.04

Delimara Power Station (Single Pit) 5th July 20000.0 0.0 0.0 0 0.3


Table 8.3 Thermal Discharges from Power Stations. Monitoring of surface water temperatures (Degrees Celsius)

Marsa Power Station

Date ambient near intake 15 m from outlet Rise above ambient Rise above intake Aug-97 27 28.4 32 5 3.6 Feb-98 16.2 19.4 22.6 6.4 3.2 Jun-98 24.3 26.8 30.2 5.9 3.4 Nov-98 23.8 26.8 27.4 3.6 0.6 Apr-00 15.2 16.4 18.3 3.1 1.9

Delimara Power Station

Date ambient 30m from outlet Jun-97 22 22.5 Mar-00 15.6 16.7 Jul-99 25.2 26.8

May-98 19.2 21.1 Mar-98 16.3 20.3

Ambient temperatures are those recorded on the same day, at the same hour, but very far away from the Power Station. Data produced by V.Axiak as part of a research programme funded through the 4th Italo- Maltese Financial Protocol entitled: MONITORING OF ENVIRONMENTAL QUALITY

OF MALTESE COASTAL WATERS USING REMOTE SENSING

Table 8.4 Summary of Compliance Costs for the Energy and Water Production Sectors

Reference Number

Site Location

Estimated Annual Volume of Discharges (m3)

Capital Costs for Compliance Running Costs (Annual)Time Frame (years)

Best Case Scenario Worst Case Scenario BCS WCS Monitoring

PP1 Marsa Power Station 250,640,000Lm350,000 for oil separation and for settling tank and neutralizing pit

same as for BCS plus an unknown sum for thermal control Lm7500 Lm7500 plus Lm 6,000 1

PP2

Delimara Power Station 250,670,000

Lm300,000 for oil separation to ensure 5ppm limit.

Lm300,000 for oil separation plus an unknown sum for thermal control Lm7500 plus Lm 6,000 1

RO1 Lapsi RO Plant 8,736,000possibly further study… Lm 20,000 4000 NA

RO2 Pembroke RO Plant 12,012,000RO3 Cirkewwa RO Plant 5,678,400

Total for both sectors Lm 650,000 Lm 670,000 plus Lm7500 Lm15,000 plus Lm16,000

Table 8.6 Results of Monitoring of marine discharges from three RO plants

(One sample collected from each RO plant on the 4th July 2000)

Chemical Maximum Permissible LIMITING VALUE A Units limit of detection c Ghar Lapsi RO Cirkewwa RO Penbroke RO

Chloroform 12 ug/l ug/l 0.4 0.7 0.8 Perchloroethylene PER 10 ug/l ug/l 0.2 0.1 0.3 Mercury and its compounds 50 ug Hg/l ug/l 0.2 0 0 0 Cadmium and its compounds 50 ug Cd/l ug/l 0.02 0 0 0 zinc 1 mg Zn/l ug/l 5 42 57 47 copper 0.5 mg Cu/l ug/l 1.1 1.2 0.3 nickel 0.5 mg Ni/l ug/l 23 11.1 5.4 chromium 0.5 mg Cr/l ug/l 0.19 0.42 0.13 lead 0.2 mg Pb/l ug/l 0.12 0.18 0.28 selenium ug/l 0.02 5.85 1.85 1.11 arsenic 0.05 mg As/l ug/l 0.1 2.9 1.7 2.1

boron 2 mg/l B mg/l 0.1 6 4.7 2.1Dissolved Nitrates ug/l 29.74 15.23 7.74 Dissolved Nitrites ug/l 0.030 0.030 0.056 Dissolved Phosphates ug/l 0.26 0 0.01

Total Phosphorus 1 to 2 mg/l mg/l 1.71 0 0

Notes: A = Maximum Permissible Limiting Value as would be set by the forthcoming LN of EPD to control marine discharges B = Maximum Permissible Limit Value for Boron is presently included only in LN 8/93 controlling discharges into sewers. C = Limit of Detection for the respective analytical method used. A value of 0 indicates that the concentration found is below detection.

Table 9.1 Summary of findings regarding marine discharges originating from Malta Drydocks

Sector within Malta Drydocks

Machine Shop

Electrical Shop and Electronic Dept.

Galvanising Plant

Acethylene Plant

Docks Motor Plant Repair Shop

Foundry Pipe-workers Shop

Boile-rmakers Shop

Boiler Shop

Non-Destructive Testing Dept.

Dept. of Airconditioning and refrig.

Oxygen Plant

Yacht Yard

Estimated volume of marine

discharges in m 3 per year 500 125 10 1200 4000 1 none 150 with MS 1000 4.2 none none 15

Annual consumption of chemicals

Eurosol Base Oil 600 l a a a a a a a a a a a a aIsopropanol Disinfectant a aElectrical Solvent Non-Flam. 850 a aAlkleen Powder 1000 kg aPerchloroethylene (Air cooler cleaner)

1000 l a

Descalant Accelerator (contains HF) a

Descalant HD (HCl) 1000 l 200 l a a

Tankleen HCF1000 l 1000 l 10000 l

Hydrochloric Acid a 100 l a a a a a a a a a a a aLotoxane Solvent Degreaser aAcetone aVarnish Sterling 003-1011 250Ultimeg Insulation Paint and Thinner

300 l

Oil Shell Diala B 360 lOil Agip ITE 360 4000 l

Degreaser 156 D 5000 l 4000 l aNote : a = use of chemical in respective section confirmed but not quantified.

Potential Contaminants (Relevant to EU Directive) likely to be present in discharged waste waters

BOD5 possibly a aCOD a aTotal Suspended Solids a a a a a a a a aSettleable Solids a a a a a a a a aTotal N including ammonia aNitrates aNitrites aTotal phosphorus possiblyPhosphates possiblyPersistent mineral oils and hydro-carbons a a a traces a a a a traces

Non-persistent mineral oils a a a traces a a a a traces

Fluorides a a traces possibly

CyanidesPersistent synthetic substances which interfere with water use : mainly litter

possibly apossibl

y

Organotin compounds: Butyltins and Triphenyltin

possibly a a

Hexachlorocyclohexane (Lindane)ParathionMalathionCypermethrinDichlorovosDDT (dichlorodiphenyl trichloroethane)Pentachlorophenol PCPAldrin DieldrinEndrinIsodrinHexachlorobenzene HCBHexachlorobutadiene HCBD possibly possibly

Chloroform a1,2 dichloroethane EDC a a aTrichloroethylene TRI a a traces traces aPerchloroethylene PER a a traces a traces aTrichlorobenzene TCBCarbon tetrachloride possibly infrequent tracesMercury and its compoundsCadmium and its compounds

zinc a a a a a a acopper a a a a a anickel achromium alead a a a aseleniumarsenic

antimony a a amolybdenium possiblytitanium

tin a a a a a abarium possiblyberylium

boron auraniumvanadiumcobalt possiblythaliumtellurium

silver apH a a a a a a aThermal Discharges

Note: a = likely presence of chemical or heat

Table 9.2 Results of Monitoring of marine discharges from Malta Drydocks, Marsa and Manoel Island Yachtyard

Chemical

Maximum Permissible LIMITING

VALUE A

Unitslimit of

detection c

MD dockwaters (6th July 2000)

MD dockwaters (7th July 2000)

MD Tanker Cleaning Facility (6th July 2000)

MD Tanker Cleaning Facility (7th July 2000)

Marsa, near Cassar and Bezzina Shipyards (3rd July 2000)

Marsa, near Cassar and Bezzina Shipyards (5th July 2000)

Manoel Island Yachtyard (slipway waters, 10 July 2000)

Marsa Menqa 3rd July 2000)

Marsa Menqa (5th July 2000)

Mono butyl tin ngSn/l 1571 619 576 0 0 431 221Di butyl tin ngSn/l 4892 1134 0 0 630 954 78Tri butyl tin ngSn/l 8261 1451 957 0 470 788 318Total Organotins 500ug/l ngSn/l 14724 3204 1533 0 1100 2174 617Petroleum Hydrocarbons mg/l 1.7 0.3 0.4 2.6 0.2 0.2 0.4 0.3 0.7

PHC Descriptiondegraded

stuffdegraded

stuff

high amount of diesel-type

high amount of diesel-type as well as

lub-like

degradedsig diesel-like and lube-like

Chloroform 12 ug/l ug/l 0.6 0.5 0.5 0.6 0.6 0.7 0.6 0.6 1.2Trichloroethylene TRI 10 ug/l 0.1 0.1 0.1Perchloroethylene PER 10 ug/l 0.1 0.1 0.2 0.1 0.1 0.1 0.1 0.1Mercury and its compounds 50 ppb ug/l 0.2 0 0 0 0 0 0 0 0 0Cadmium and its compounds 50 ppb ug/l 0.02 0 0 0 0 0 0 0 0 0zinc 1 mg Zn/l ug/l 5 511 570 47 30 74 30 110 83 59copper 0.5 mg Cu/l ug/l 230 45 2.2 2.2 1.5 3.2 18 5.7 4.5nickel 0.5 mg Ni/l ug/l 58 63 122 111 35 1.1 88 18 21chromium 0.5 mg Cr/l ug/l 0.29 0.27 0.9 0.44 0.08 0.11 0.11 0.19 0.39lead 0.2 mg Pb/l ug/l 0.17 2.63 0.12 0.23 0.44 0.28 0.24 0.08 0.12selenium ug/l 0.02 0 0 0 0 0 0 0 0 0arsenic 0.05 ppm ug/l 0.1 0.5 1 0.8 0.4 1 0 2.1 0.5 1.9

boron 2 mg/l B

mg/l 0.1 0 0 0 0.8 1.4 0.2 0.4 2.6 0.3Nitrates 56.03 30.28 64.51 2.49 56.89 120.68 3.45 24.21 21.33Nitrites 0.30 0.10 1.21 0.04 0.35 0.32 0.05 0.09 0.18Phosphates 0.21 0.66 2.91 2.85 0.00 1.01 0.08 0.00 0.51

Notes: A = Maximum Permissible Limiting Value as would be set by the forthcoming LN of EPD to control marine dischargesB = Maximum Permissible Limit Value for Boron is presently included only in LN 8/93 controlling discharges into sewers.C = Limit of Detection for the respective analytical method used. A value of 0 indicates that the concentration found is below detection.

Table 9.3 Summary of Compliance Costs for the Ship Yards and Ship Repair Industry

Reference Number

Site Location

Estimated Annual Volume of Discharges (m3)

Capital Costs for Compliance Running Costs (Annual)Time Frame

(years)


SY1a Malta Drydocks 7,000common treatment plant:

Lm1.5 to Lm2 millioncommon treatment plant:

Lm 4 million common TP: Lm11,000 common TP: Lm20,000 Lm8,000 2

land disposal for grit: Lm17,000land disposal for grit:

Lm17,000land disposal for grit:

Lm82,000land disposal for grit:

Lm82,000 1collection of dockwaters:

Lm10,000collection of dockwaters:

Lm10,000de-emulsification of

dockwaters: Lm2500de-emulsification of

dockwaters: Lm2500 1

SY1bMD Manoel Island

Yacht Yard 15common treatment plant,

included abovecommon treatment plant,

included abovecommon treatment plant,

included abovecommon treatment

plant, included above Lm1,000 1

new washing sump: Lm5000substituion of slipways

Lm3 million Lm 500 Lm5000 2

Malta Drydocks total: Lm2.03 million Lm7.03 million Lm96,000 Lm109,500 Lm9,000

SY2Cassar Ship Repair Ltd.

500 (estimated)

collection and treatment of wastewaters by third party: Lm 10,000

treatment plant on site Lm350,000

Improved housekeeping (cost may not be estimated)

TP running costs: Lm9000 Lm4,000 2

SY3 Bezzina Shipyard500 (estimated)

collection and treatment of wastewaters by third party: Lm 10,000

treatment plant on site Lm350,000

Improved housekeeping (cost may not be estimated)

TP running costs: Lm9000 Lm4,000 2

Total for whole Sector Lm2.05 million Lm7.73 million Lm0.1 (Approx) Lm 0.128 million Lm17,000

Table 10.1 Summary of Compliance Costs for Other Industries

Reference Number

Site Location

Estimated Annual

Volume of Discharges

(m3)

Capital Costs for Compliance Running Costs (annual)Time

Frame (years)


IN1 Hal Far Industrial Estate

No data available

If present wastewaters are led to the public sewers, then cost has already been incorporated in DD compliance costs Treatment Plant: Lm 500,000 Lm12,500

2 (for WCS)

IN2 Comino Pig Farm (KIM Ltd)1000 to 3000 Lm 0.5 million for new TP Lm 1.0 million for new TP Lm12,000 Lm 25,000 Lm2,000 2

IN3 Vernon Foods Ltd. (Marsa) 2,700

Possibly none if thermal discharges are within limits still to be determined Lm20,000 for cooling plant Lm 2,000 Lm 200

1 (for WCS)

Total Lm 0.5 million Lm 1.52 million Lm12,000 Lm39,500 Lm2,200

Table 11.1 Summary of findings for Hotel and Recreation Sector

Registration Number

Site LocationFT staff

PT Staff

Estimated Annual Turnover

Effluent TypePresent Rate of Discharges

Discharge Estimate

m3/yearCompliance Problems Compliance Costs

HR1 Corinthia San George Hotel 300 50 Lm 6 million Chillers, and pool water60l/min for chillers

40m3/week for pools

56,000 most likely none

HR2 Coastline Hotel 140 60 RO plant and pool 7m3/h 34,000 most likely none

HR3 Comino Hotel 80 20 Sewage, and RO plant180m3/d for sewage and

120m3/d for RO

55,000 requires new WTP claims: Lm60,000 possibly more

HR4 The Preluna Hotel and Towers 173 42 Pool 40,000 most likely none

HR5 Corinthia Jerma Palace Hotel 150 50 Lm 2.5 million Pool and RO plant8m3/h for brine and

3m3/day for pools27,000 most likely none

HR6 Crowne Plaza Malta 165 25 Lm 2.5 million Chiller 1.1m3/min 140,000 most likely none

HR7 The Westin Dragonara Resort 350 115 Lm 7 million

10.5m3/h for RO

brin; 180m3/h for chiller waters;

10m3/day for pools


HR8 Hilton Malta: Hotel and MarinaRO brine, cooling waters and pool water

no data available 500,000 most likely none

HR9 Fortina Hotel 145 46 RO plant and pools 18,000 most likely none

HR10 Radisson SAS BayPoint Resort 180 50 RO plant , chillers and pool

10.8m3/h for RO

plant; 32.4m3/h for

chillers,6m3/week for pools


HR11 Mediterraneo (Marine Land Ltd.) 6 3 Tanks and aquaria washings no data available unknown most likely none

Table12.1 Synopsis of results on chemical composition of sewageWied Ghammieq Ras il-Hobz Cumnija

Chemical Units mean max min sd n mean max min sd n mean max min sd n

MBT ngSn/l 0 0 0 0 3 0 0 0 0 2 0 0 0 0 3DBT ngSn/l 405 724 0 370 3 243 485 0 343 2 393 625 0 342 3TBT ngSn/l 589 749 450 151 3 587 769 406 257 2 246 422 0 220 3Total Organo-tins ngSn/l

993 1473 450 515 3 830 891 769 86 2 640 977 1 554 3

PHC mg/l 0.733 1.400 0.300 0.586 3 0.900 1.200 0.700 0.265 3 0.467 0.900 0.200 0.379 3Cyanides ug/l 0.00 0.00 0.00 0.00 3 8.00 16.00 0.00 11.31 2 3.00 6.00 0.00 3.00 3Fluorides mg/l 0.32 0.34 0.28 0.03 3 0.30 0.34 0.28 0.03 3 0.65 0.72 0.58 0.07 3Chloroform ug/l 1.23 1.40 1.00 0.21 3 1.33 2.30 0.80 0.84 3 0.43 0.60 0.30 0.15 3Perchloro-ethylene ug/l

0.15 0.20 0.10 0.07 2 0.13 0.20 0.10 0.06 3 0.13 0.20 0.10 0.06 3

copper ug/l 11.70 19.30 3.30 8.03 3 7.20 15.10 2.60 6.87 3 7.87 14.90 2.10 6.49 3nickel ug/l 32.90 50.00 2.70 26.23 3 3.60 7.30 0.70 3.37 3 1.10 3.30 0.00 1.91 3chromium ug/l 0.13 0.17 0.10 0.04 3 0.55 1.44 0.07 0.77 3 0.25 0.57 0.05 0.28 3lead ug/l 0.27 0.50 0.12 0.20 3 0.16 0.31 0.02 0.15 3 0.25 0.48 0.11 0.20 3selenium ug/l 0.00 0.00 0.00 0.00 3 0.15 0.46 0.00 0.27 3 0.15 0.24 0.00 0.13 3arsenic ug/l 0.27 0.80 0.00 0.46 3 0.00 0.00 0.00 0.00 3 0.13 0.40 0.00 0.23 3boron mg/l 0.37 0.40 0.30 0.06 3 1.13 2.60 0.30 1.27 3 0.00 0.00 0.00 0.00 3

Nitrates ug/l 25.6 37.9 16.5 11.1 3 9.5 22.9 2.8 11.6 3 6.9 11.2 3.9 3.8 3Nitrites ug/l 0.1 0.1 0.0 0.1 3 0.0 0.0 0.0 0.0 3 0.0 0.0 0.0 0.0 3

Total Phosphorus

mg/l 34.9 46.2 20.7 13.0 3 25.0 30.6 21.7 4.9 3 28.9 41.5 22.1 10.9 3

pH 7.7 8.5 7.4 0.3 14 7.7 8.0 7.0 0.3 14 7.0 7.2 6.8 0.1 16DO mg/l 1.9 8.9 0.1 2.9 13 3.5 5.9 0.3 1.5 13 1.7 5.2 0.1 2.1 15

PO4-- mg/l 25 42 10 8 14 34 46 10 9 15 47 78 22 13 16NH3 mg/l 36 54 10 16 14 60 138 31 28 15 73 136 36 29 16Cl- mg/l 2319 3460 312 687 14 1121 2850 638 640 15 1818 4353 723 815 16

COD mg/l 390 859 141 180 14 433 727 267 110 15 726 968 462 152 16BOD5 mg/l 323 1634 5 429 13 267 487 24 129 14 409 783 5 218 15

Notes 0 = below detection limita = Data from the present studyb = Data from LIFE Project

Table 14.2 Importation Trends of Relevant Compounds over the past 5 years (Source: Department of Statistics: Eurotrace-Statistics-Malta)

DESCRIPTION Quantities Imported (kg)

1995 1996 1997 1998 1999Nitrogen compounds POTASSIUM NITRATES 77,515 61,586 67,330 43,446 82,800

NITRITES 7 6,752 11,080 323 1,588OTHER NITRATES EXCL THOSE OF HS2834210000 TO HS2834295000 10,093 11,053 3,207 8 875

Phosphorus compounds PHOSPHATES OF MONO OR DISODIUM 323,287 383,075 212,761 2,138 5,329TRISODIUM PHOSPHATES 4,977 9 17,207 25 3,254POTASSIUM PHOSPHATES 242,035 40,022 56 20,152 42CALCIUM HYDROGENORTHOPHOSPHATE WITH A FLOURINE CONTENT 31,270 16,875 20,036 117 109CALCIUM HYDROGENORTHOPHOSPHATE WITH A FLOURINE CONTENT 80,000 384,800 460,100 501,000 421,000OTHER CALCIUM PHOSPHATES WITH A FLOURINE CONTENT <0.005% BY WEIGHT 6,800 1,035 2,000 644 1,008

Fluoride compounds HYDROGEN FLUORIDE (HYDROFLUORIC ACID) 662 68 96 413 285FLUORIDES OF AMMONIUM OR OF SODIUM 10 42 43 17 300FLUORIDES NES 70 1,008 1,272 5 0FLUOROSILICATES OF SODIUM OR OF POTASSIUM 0 17,500 0 0 0OTHER CALCIUM PHOSPHATES WITH A FLOURINE CONTENT =>0.005% BUT <0.2% BY WEIGH 9,570 36,140 1,000 28,600 34,100

Cyanide compounds CYANIDES AND CYANIDE OXIDES OF SODIUM 0 0 0 2 0OTHER CYANIDES AND CYANIDEOXIDES (EXCL OF SODIUM) 625 940 1,120 825 774

Organics HEXACHLOROBENZENE AND DDT (111-TRICHLORO-22-BIS [p-CHLOROPHENYL] ETHAN 0 2 0 - 0CHLOROFORM (TRICHLOROMETHANE) 6,210 589 507 1,017 1,22712-DI CHLOROETHANE (ETHYLENE DICHOLORIDE) 0 0 19 8 17TRICHLOROETHYLENE 10,402 13,479 11,588 18,319 6,764TETRACHLOROETHYLENE (PERCHLOROETHYLENE) 66,702 98,392 53,117 50,100 70,434HALOGENATED DERIVATIVES OFAROMATIC HYDROCARBONS NESIN HS29036100-6910 0 108 850 1,041 225CARBON TETRACHLORIDE 12 25 1 15 0

Metal compounds MERCURY OXIDES 0 0 0 0 1PIGMENTS & PREPARATIONS BASED ON CADMIUM COMPOUNDS 0 289 0 0 0ZINC OXIDE; ZINC PEROXIDE 23,563 29,116 32,325 38,257 27,390COPPER OXIDES AND HYDROXIDES 3,444 3,050 6,550 6,226 3,016NITRATES OF COPPER AND OF MERCURY 15 12 - 9 0CHROMIUM TRIOXIDE 300 50 28 205 102PIGMENTS & PREPARATIONS BASED ON CHROMIUM COMPOUNDS 9,400 14,115 3,925 7,180 5,697LEAD MONOXIDE (LITHARGE MASSICOT) 0 20 - 1 2RED LEAD AND ORANGE LEAD 2,000 0 2,001 0 2,000LEAD OXIDES NES 0 0 0 - 301LEAD NITRATES 2 9 9 2 505SELENIUM - 0 0 0 0ANTIMONY OXIDES 5 0 0 0 0PIGMENTS & PREPS BASED ON TITANIUM DIOXIDE TITANIUMDIOXIDE CONTENT =>80% 0 295,526 404,934 387,933 402,683TIN OXIDES 0 - 0 0 0OXIDE HYDRXIDE AND PEROXIDE OF BARIUM 0 11,057 0 1 -NITRATES OF BARIUM BERYLLIUM CADMIUM COBALT AND NICKEL 1,000 1,004 1,001 1,000 1,600BERYLLIUM OXIDE AND HYDROXIDE 0 0 0 0 25VANADIUM OXIDES AND HYDROXIDES 0 - 1 0 0

Table 15.1Responsibilities and Activities of the Authorisation System dealing with Marine Discharges as arising under provisions of different Directives (WFD: Water Framework Directive; DSD: Dangerous Substances Directive, UWD: Urban Wastewater treatment Directive)

WFD DSD UWD Planning and Implementation • Identify river basins (including coastal waters) X • Identify competent authority for the implementation of the rules of Directive X Prepare river basin plans, programmes of measures X • Identify agglomerations X • Identify sensitive and less sensitive areas and of protected areas X X • Identify the industries to which directives apply X • Set water quality objectives X X • Set fixed emission limits X X • Specify urban waste water treatment requirements and sewerage designs X Technical Standards • Develop a methodology for deciding water quality objectives (86/280/EEC). X • Develop a methodology for deciding emission limit values X • Establish procedures for the issue of authorizations X X Regulation • Establish an inspectorate that is authorized to inspect installations, take samples, and take enforcement actions X (96/61/EEC, 91/271/EEC). • Establish laboratories and associated organizations capable of sampling and analyzing waters and effluents according to prescribed methods with the application of quality control regimes to ensure harmonization X X X with directives (79/869/EEC). • Institute the prior authorisation regimes for industry and for wastewater treatment plants (96/61/EEC, X 91/271/EEC). • Set up monitoring programmes to determine compliance with directives (80/78/EEC, 76/464/EEC, priority X X substances). Monitoring programmes to include coastal waters, (especially sensitive areas) as well as effluents. • Establish databases and information systems to allow reports to be made to the Commission and to the general public (91/692/EEC, 90/313/EEC). Report to public re state of urban waste water disposal and sewage sludge. X X • Enforce measures for emission controls of priority substances. X X Reporting

• Prepare reports on e.g. implementation, designations, authorizations, derogations etc. (91/692/EEC as X X X amended by Decision 94/741/EEC).

Table 15.2 Estimated Capital Expenditure for Laboratory anf Field Facilities

Lm subtotals LmComputer Facilitiescomputer hardware: Drives,Scanner,printers,notebook 7,000computer software: for presentation/data analysis/etc 3,500 10,500

Field equipmentDigital Thermometers 300Mobile phone - X2 260Field GPS X2 400Spectrofluorimeter (in situ) 7,000Transmissometer (in situ) 4,000Marine Deck Unit s 6,000Video camera 480Underwater camera 8,000Digital camera system 610DO meters + Anemometer 1,200Environmental multimeter (other parameters) 1,200Portable Multiparametric System for Water Quality Survey 4,500Salinity meters 2,000Flow meters 2,500Van Dorn sampler and Secchi 650Plankton nets and accessories 5,000Diving Equipment 10,000Other 25,000 79,100

Basic laboratory equipmentpH Meter 2,500 thermoreactor/BOD/Meter/Mag. Stirrer 1,900Balances 2,600basic glasssware 20,000Bench top centrifuge 4,000Oven 2,000Furnace 2,500Filtration equipment plus pump 2,000other basic laboratory equipment 31,000 68,500

Major EquipmentGC Mass Spectrometer 20,000AAS 20,000UV-Vis Spectrometer 5,000Trace analyser (Polarograph) 6,000Other 50,000 101,000

Basic Laboratory FacilitiesIncluding airconditioners, hoods, etc… 40,000 40,000

Grand Total Lm299,100

not included: cost of premises, boat services, furniture and other basics

Table 15.3 Estimated Recurrent Expenditure for Laborato

Personnel Lm subtotal (Lm)Head of Section 7,6652 Environmental officers 11,6061 Senior Inspector 6,6402 Environment Inspectors 10,210Principal Scientific Officer 7,6653 Scientific Officers 17,409Data Bank Manager 7,665 68,860

Transport and TravelTravel overseas 3,000Local Transport 2,000 5,000

ConsumablesConsumables reagents 3,500Consumables others 3,000 6,500

ServicingServicing general equipment 2,000Servicing specialized equipment 5,000 7,000

Otherdocumentation 1,000on line subscriptions 2,500Sundries 5,000 8,500

Consultancy Services 20,000 14,000

Grand Total Recurrent Expenditure Lm 109,860

Table 16.1 Summary of Compliance Costs

Capital costs Lm Running costs Lm/year

Sectorbest-case scenario

worst-case scenario

best-case scenario

worst-case scenario monitoring

Fishfarming 65,000 150,000 7,500 15,000 8,000Fuel and Oil Terminals 3,345,000 16,600,000 41,200 90,000 20,500Electricity and Water Production 650,000 670,000 A 7,500 15,000 A 16,000Ship Yards 2,052,000 7,727,000 98,000 127,500 17,000Other Industries 500,000 1,520,000 12,000 39,500 2,200Hotels and Recreation B

60,000 200,000 1,500 5,000 2,000

Sewage Collection and Treatment 38,000,000 38,000,000 1,900,000 1,900,000Authorization System (control of direct marine discharges) 300,000 500,000 110,000 110,000

Grand Total (Lm) 44,972,000 65,367,000 2,177,700 2,302,000 65,700

Grand Total (EUROs) 108,445,481 157,625,984 5,251,306 5,551,043 158,429

NotesA = Costings for worst-case scenario do not include control of thermal discharges

B = Estimate based on Comino Hotel. Other hotels do not required additional costs due to compliance, except for monitoring.

Time Frame (years)

1 to 2 years1 to 4 years

1 year1 to 2 years

2 years2 years

up to 20051 year

ANNEX 1 to Study: Assessing the Impact of Compliance with CD 76/464/EEC and other related Water Quality Directives with


List of Organizations with which consultations were held for the purpose of this study. Abela, A.; Director, Drainage Department, Ministry for the Environment. Abela, Marco; Malta Development Corporation. Bugeja, David; Malta Maritime Authority. Cachia, Stefan; Sewerage Master Plan Implementation Unit, Works Division, Minsitry for the Environment. Camilleri, Sylvana; Discharge Permit unit, Drainage Department, Ministry for the Environment. Cassar Vince; Director General, Works Division, Ministry for the Environment. IPSE. Lanfranco, Ruben; Maritime Squadron, Armed Forces of Malta. Micallef, Godwin; Vice- President, Malta Federation of Industries. Mifsud Paul; Permanent Secretary, Ministry for the Environment. Mifsud, Tarcisio; Enemalta Corporation. Pace John; Enemalta Corporation. Sammut, Anthony; Water Services Corporation. Vella, Louis; Environment Protection Department, Ministry for the Environment.

Compliance Impact of CD 76/464 EEC and other Water Quality Directives: ANNEX 1.

ANNEX 2 to Study: Assessing the Impact of Compliance with CD 76/464/EEC and other related Water Quality Directives with


Monitoring Programme for the purpose of the Present Study: Analytical Protocols and Results of Analysis of Waters and Waste Waters. Department of Chemistry: Prof. Alfred Vella Dr. George Peplow Progetto Natura (Italy) Dr. Paulo Pucci

Compliance Impact of CD 76/464 EEC and other Water Quality Directives: ANNEX 2.

ANNEX 3 to Study: Assessing the Impact of Compliance with CD 76/464/EEC and other related Water Quality

Directives with Reference to Marine Discharges In Malta

QUSTIONNAIRE USED FOR SURVEY OF INDUSTRIAL MARINE DISCHARGES

Name of Official Status Interviewed Date(s) of Interview Interviewed by 1. Profile of Trade Premises 1.1 Name of Company 1.2 Registered Address

1.3 Tel No. 1.4 Fax No. 1.5 email No. of Employees 1.6 FT 1.7 PT 1.8 Turnover in 1999 1.9 Brief Description Of Industrial Activity

Survey of Industrial Marine Discharges ANNEX 3

1

2. Liquid Wastes/Effluents Discharged directly into the Marine Environment

2.1 Origin(s) of Liquid Wastes/Effluents i.e. indicate stage(s) of plant operation giving rise to liquid waste(s)

Is toilet waste Included ? 2.2 Volume 2.3Frequency M3/h or per day e.g. h / day

2.4 Method of Discharge Into Marine Env. (i.e. dimensions of drain pipe; whether discharged on shore or through submarine pipe, etc…) 2.5 Exact Location of Discharge Point(s) (if possible provide site map)

2.6 On-line Monitoring? (e.g. for flow rates and quality? Which parameters are monitored? If none available, is this Being envisaged? When?

2.7 Manual Monitoring? Frequency? Parameters? No. of Personnel?PT/FT?


2

3. Chemical Characteristics of Effluents In each case indicate presence ( ). If available ,give concentrations (including units). If treatment is available, indicate levels prior and after treatment.

1 BOD 2 COD 3 Total Suspended Solids 4 Settleable Solids 5 Total Nitrogen 6 Nitrates 7 Nitrites 8 Total Phosphorus 9 Phosphates 10 Petroleum Hydrocarbons 11 Fluorides 12 Cyanides

13 Persistent synthetic substances which interfere with water use : mainly litter

14 Organotins 15 Hexachlorocyclohexane (Lindane)

16

Organophosphorus pesticides (malathion; parathion, Cypermethrin,Dichlorovos, etc...) SPECIFY

17 DDT (dichlorodiphenyl trichloroethane) 18 Pentachlorophenol PCP 19 Aldrin Dieldrin Endrin Isodrin 20 Hexachlorobenzene HCB 21 Hexachlorobutadiene HCBD 22 Chloroform 23 1,2 dichloroethane EDC 24 Trichloroethylene TRI 25 Perchloroethylene PER 26 Trichlorobenzene TCB 27 Carbon tetrachloride 28 Mercury and its compounds 29 Cadmium and its compounds 30 Zinc 31 Copper 32 Nickel 33 Chromium 34 Lead 35 Selenium 36 Arsenic 37 Antimony 38 Molybdenum 39 Titanium 40 Tin 41 Barium


3

42 Beryllium 43 Boron 44 Uranium 45 Vanadium 46 Cobalt 47 Thalium 48 Tellurium 49 Silver 50 Radioactive substances (Specify) 51 Micro-organisms (coliforms) 52 PH 53 Temperature

4. Treatment of Such Liquid Wastes 4.1 YES 4.2 NO If such effluents are treated prior to marine discharge: 4.3 When such treatment plant installed (year) 4.4 Describe type Of Treatment (include operating efficiency any mechanical problems.etc..) No. of personnel involved in running plant 4.5 FT 4.6 PT 4.7 Production Of sludges (include data on quantities, characteristics and method of disposal)


4

5. Envisaged Modifications / Upgrading Are there any modifications, expansions, or upgrading of the production being envisaged? If so, in what way would data entered in sections above, be modified? 5.1 Brief Description of Modification(s) In production Envisaged changes in wastewater discharges into the marine environment in: 5.2 Volume and Method of discharge 5.3 Characteristics 5.4 Monitoring 5.5 Treatment 5.6 Sludge Disposal 6. Legislation 6.1 LN8/93 Sewer Discharge Control Degree of awareness, compliance. Any present difficulties of compliance?

6.2 The EPD is planning to issue a LN to control discharges into the marine environment. This LN will provide for discharge permits, set limits of discharges, set reporting obligations, etc. (See checklist and probable limits.. Annex 1) Any comments? Any envisaged problems?


5

7. Present Costs of Production

Lm Foreign Currency

7.1Permit(s) for Discharge

7.2Capital Costs

Machinery 7.2.1 Construction 7.2.2

Land 7.2.3 Interest payment 7.2.4

total 7.2.5

7.3 Lifespan

Capital 7.3.1 Construction 7.3.2

Land 7.3.3 total 7.3.4

7.4 Running Cost

Raw materials 7.4.1 electriciity 7.4.2

Water 7.4.3 Other 7.4.4 total 7.4.5

7.5 Labour Costs

7.5

7.6 Monitoring Costs

7.6

7.7 Administrative Costs

Management 7.7.1 Marketing 7.7.2

other 7.7.3

total

7.7.4


6

8. Cost Incurred For Dealing with Present Discharge into Marine Environment

Lm Foreign Currency

8.1 Permit (s)

9.1

8.2Capital Costs



Total 9.2.5

8.3 Lifespan

Capital 9.3.1 Construction 9..3.2

Land 9.3.4 Total 9.3.5

8.4 Running Cost

Raw materials 9.4.1 Electricity 9.4.2

Water 9.4.3 Other 9.4.4 Total 9.4.5

8.5 Labour Costs

9.5


9.6



Other 8.7.3

Total

8.7.4


7

9. Envisaged costs which may be incurred to comply with future legislation (including EU Directives) covering direct marine discharges.

Lm Foreign Currency

9.1 Permit (s)

9.1

9.2Capital Costs



total 9.2.5

9.3 Lifespan

Capital 9.3.1 Construction 9..3.2

Land 9.3.4 total 9.3.5

9.4 Running Cost

Raw materials 9.4.1 electriciity 9.4.2

Water 9.4.3 Other 9.4.4 total 9.4.5

9.5 Labour Costs

9.5


9.6



other 9.7.3

total

9.7.4


8

ANNEX 4 to Study: Assessing the Impact of Compliance with CD 76/464/EEC and other related Water Quality Directives with Reference to Marine Discharges In Malta

List of Industries and Personnel Interviewed

Sector Name of company Contact person

Fishfarming Fish and Fish Ltd. Mr Emmanuel Azzopardi

Malta Mariculture Ltd. Ms. Diane Spiteri

National Aquaculture centre Dr. A. Grupetta

Pisciculture Marine De Malte Ltd Dr. Jes Brinch-Iversen

Fuel Terminals Enemalta Gas Division Mr. A. Vassallo

Enemalta Petroleum Division Ing Philip Borg

Malta Drydocks Tanker Cleaning Facility Dr Vince Scerri

Maritime Squadron (Armed Forces of Malta) Captain Ruben Lanfranco

Mediterranean Offshore Bunkering Co Ltd Mr. F. W. Sammut

Oiltanking Mr Alex Fenech and Captain Klaus Trinks

San Lucjan Oil Co, Director

Waste Oils Co. Ltd. Mr. Carmel Falzon and Ing. Oliver Debono

Fresh Water Production Malta Desalination Services Ing Robert Schembri

Electricity Generation Enemalta Enegy Production Ing. John Pace and others

Shipyards Bezzina Shipyard Mr. V. Bezzina

Cassar Group of Companies Mr. A. Cassar

Malta Drydocks Various Shop Managers

Compliance Impact of CD 76/464 EEC and other Water Quality Directives: ANNEX 4 1

ANNEX 4 (Continued) to Study: Assessing the Impact of Compliance with CD 76/464/EEC and other related Water Quality Directives with Reference to Marine Discharges In Malta

List of Industries and Personnel Interviewed

Sector Name of company Contact person

Other Industrial Activities Comino Pig Farm (KIM Ltd) Mr. Edwin Bartolo

Emanuel Delicata Winery The Director

Malta Freeport The Director

Marinas and Ports, Malta Maritime Authority Captain David Bugeja

Marsovin Winery The Director

Rinella Film Facilities Mr. Mark Caruana

Vernon Foods Ltd Mr Martin Borg

Hotels and Recreation Canifor Hotel The Director

Coastline Hotel Ing. Charles Tonna

Comino Hotel The DIrector

Corinthia Jerma Palace Hotel Ing. Victor Sciavone

Corinthia San Gorg Hotel Ing. Godfrey Pace

Crowne Plaza Malta Ing. M. Morgan

Fortina Hotel Mr. Joe Demicoli

Gillieru Harbour Hotel Mr. Cremona

Hilton Malta: Hotel and Marina Ing. Andrew Forte

Island International Hotel The Director

Marine Land Ltd (Mediterraneo) Mr. Alfred Grech

Mellieha Bay Hotel Mr. F. Tabone

New Dolmen Hotel The Director

Paradise Bay Hotel The Director

Radisson SAS BayPoint Resort Ing. Valerio Spiteri

Splash and Fun Mr. Farrugia Michael

The Carlton Hotel The Director

The Plaza Regency Hotel The Director

The Preluna Hotel and Towers Alfred Perini

The Westin Dragonara Resort Ing. Bernard Grech

Compliance Impact of CD 76/464 EEC and other Water Quality Directives: ANNEX 4 2

ANNEX 6 to Study: Assessing the Impact of Compliance with CD 76/464/EEC and other related water quality Directives with reference to marine discharges

Capital Cost Estimates of Relocating the MD Tanker Cleaning Facility from its present location in Grand Harbour (See Chapter7) 3000 ton tanks 6 in number 150 tons @ Lm2OOO plates + internals and finishes (Lm75,000)- Lm 2,250,000 200 ton tanks 2 in number 20 tons @ Lm2OOO plates + internals and finishes (Lm5O,000)- Lm 180,000 600 ton tanks, 2 in number 35 tons @ Lrn2000 plates + internals and finishes (Lm60,000)- Lm 260,000 Foundation works for tanks - Lm 150,000 Oily water separators, 2 in number Lm 750,000 Hose handling rig - Lm 500,000 Dredging works - Lrn500,000 Jetty & fendering (to take 300,000 tonnes ships) - Lm 3,000,000 Valves - Lm 250,000 Transfer pumps, 3 in number - Lm 180,000 Pre-mix fire fighting system - Lm 450,000 Pipelines - Lm 1,500,000 Transfer of boilers and machinery - Lm 500,000 Infrastructure - Lrn 400,000 Bunding and tank enclosure - Lm 250,000 Offices, storerooms ~ workshops - Lm 150,000 Security fencing and security systems - Lm 250,000 Total: Lm 11.52 million

Compliance Impact of CD 76/464 EEC and other Water Quality Directives: ANNEX 6

ANNEX 7 to Study: Assessing the Impact of Compliance with CD 76/464/EEC and other related water quality Directives with reference to marine discharges

Financing Upgrading Programme Local Incentives Schemes The Business Promotion Act (BPA) which will be substituting the Investment development Act (IDA) of 1988 provides for promotional measures directed amongst other, at encouraging investment for the protection of the environment. Under this Act a ‘qualifying company’ may benefit from incentives mentioned in the Act. A qualifying company is defined as a company which carries on or intends to carry on in Malta a trade or business consisting solely of any one or more of the activities referred to in para (a to k ) of sub-section 1 of Section 3 of this Act. Business activities include

• Large scale aquaculture • Agriculture, stock farming and large scale horticulture • Activities set out in section II of the Malta Freeport Act and carried

out mainly in a Freeport as defined by the Act. • The repair, improvement or maintenance of turbines • Waste treatment

According to this Act waste treatment is defined as the physical, thermal, chemical or biological processes including sorting that change the characteristics of the waste in order to reduce its volume or hazardous nature, facilitate its handling and enhance recovery. Incentives offered under this scheme include:

1. Operational aid 2. Value added incentive schemes 3. Investment aid 4. Other incentives

Operational Aid New firms in target sectors qualify for operational aid in the form of reduced rate of tax on corporate profits as follows. 5% over the first 7 years, 10% over the next six years and 15% over the following 5 years and thereafter target sectors would qualify for a reduced rate of tax on corporate profits as follows: 10% over the first

Compliance Impact of CD 76/464 EEC and other Water Quality Directives: Annex 7

six years, 15% over the following five years and thereafter the full tax rate as applicable at the point in time. Value Added incentives These may be used by non-targeted sectors. These sectors would be eligible for tax rebates on their incremental profits calculated on the basis of their success in increasing their value added. Investment Aid All firms whether targeted or not qualify for an investment tax credit subject to a maximum permitted aid intensities equivalent to 50% of the investment made in the case of large firms and 65% in case of SME’s. Other Incentives The BPA contemplates a series of other incentives related to R&D expenditure, environmental protection, Training and job creation. It provides for additional incentives for SME’s and provisions to give micro enterprises greater protection from late payments by much larger debtors. This may facilitate the discounting of such debt by the commercial banks and thus improve the cash flow of small enterprises. Other incentives include the availability of factory premises at preferential rates, soft loans, interest subsidies and loan guarantees as alternatives to soft loans. This law also caters for grants when structural funds become available once Malta enters the European Community. Foreign Aid Malta may participate in any EU programme open to 3rd countries whether candidate countries or EEA countries if we pay our entry fees. This may not be likely if government gives priority to institution building and training of officials. Moreover, it seems difficult for Malta to tap ISPA.. i.e. funds dedicated to transport and environment in CEEC. In such cases, funding needs to be matched, the EU co-funds 75% while the Maltese government will fund 25%. There may also be private and parastatal input though this varies from country to country. Moreover, Malta has opted not to tap EIB loans.


It is more likely that Maltese businesses may tap MEDA, SMAP and LIFE programmes. Success in participating in these programmes depends on the quality of the projects submitted by Malta and in the case of regional projects , on the quality of the partners. MEDA Indicative proogrammes These programmes were established by regulation EC No 1488/96. It represents the EC main financial instrument for the implementation of the Euro-Mediterranean partnership. The proogramme has the main purpose of encouraging and supporting the reform of the economic and social structures of the Mediterranean partners, notably in preparation for the free trade with EC. The programme is to build on the experience gained through the operation of bilateral financial protocols to provide for regional co-operation. Guideline 15 states that assistance under this programme will be given in particular in the following fields:

• Harmonization of legislation and standards and the strengthening of institutions in the field of the environment.

• Co-operation in the energy, water regarding policy, interconnection

and interoperability of infrastructure and networks, improvement of quality and the cost of service provision, industrial co-operation including in industrial zones and research and technological development.

Guideline 16 which aims at strengthening of the socio-economic balance of partner countries stresses that particular attention should be accorded to preserving the environmental equilibrium in the partner countries through supporting the capacity building in the field of environmental assessment, management, legislation and enforcement. Interest rate subsidies may be granted on loans of the European investment Bank to offset the cost of improving the environment for environmental projects. Guideline 220 under guidelines for the regional Indicative Programme again mentions the need for appropriate measures to be taken in the fields of energy, the environment, water and fishing SMAP Programme


Maltese businesses may also tap the SMAP programme or Short and Medium term priority Environmental Action Programme. These programmes are very relevant. The main areas for action which promote both preventive and remedial or rehabilitation programmes include

• Integrated management of water, soil and coastal areas • Management of waste • Prevention and combating of air pollution and pollution of the sea.

The objectives of the SMAP programs are:

• To help change the current trend of environmental degradation in the region which continues despite major efforts by all partners at National and |Regional levels.

• To contribute to sustainable development of the region to the protection of the Mediterranean environment and to the improvement of health and living conditions of the population.

• To contribute to the further integration of environmental concerns in all other pollicies

• To ensure that, with the building-up of a Free Trade area, steps are taken from the start to highlight trade and environmental issues and that the respective policies are mutually supportive paying due respect to the environmental commitments.

Selection of the priority fields of action for SMAP are based on criteria including:

• Issues related to the upgrading to the national needs for the protection and rational sustainable management of the environment

• Having an impact on human health and the quality of life SMAP states that urgent action should be undertaken with regards to

1. the evaluation and monitoring of water quality. Assessment of potential (available or new) resources especially in critical areas i.e. highly populated or with big seasonal increase of population often due to tourism.

2. The establishment and implementation of programmes for waste water treatment systems in the Mediteranean encouraging the transfer of appropriate technology and know-how to this regard.

3. Identification and use of measures and techniques for a. improved collection and re-use of municipal and industrial waste

water, sludge and storm water run-off including the setting up of infrastructure for the treatment of urban sewage.


b. Prevention of salination and the treatment of brackish water.

4. Re-organisation of the management of water resources leading where appropriate, to the establishment of financially autonomous enterprises and other similar bodies with fully transparent management and cost recovery mechanisms

LIFE Programme This programme was established by Regulation EC No 1655/200 of the European Parliament. It is a financial instrument for the Environment (LIFE) that supports EC environmental policy and legislation consisting of 3 thematic components namely LIFE- Environment, LIFE-Nature and LIFE-Third Countries. LIFE co-finances environmental actions that contribute to the implementation, upgrading and the development of Community environment policy and of environment legislation in particular as regards the integration of the environment with other pollicies and to the sustainable development in the Community. Areas eligible for funding. Action must be in line with EC environmental policy and with its general properties as defined in ‘Towards sustainability, The European Economic programme of policy and Action in relation to the environment and sustainable development’. LIFE third countries also supports regional priority issues of major international importance such as:

• Technical assistance projects which further the objective set out above

• Accompanying measures required for evaluating, monitoring and promoting the action undertaken during the implementation of LIFE financial instrument for the exchange of experience between projects and for the dissemination of information on thee experience gained and on the results obtained with such actions.

• Correspond to the principles established in the context of the Mediterranean Action Plan (MAP) and the Barcelona Convention for the protection of the Marine Environment and the Coastal Region of the Mediterranean

• Are in line with the prioritizes agreed upon within the Short and Medium Term Environment Priority Action programme (SMAP) Euro-Mediterranean Partnership.


Projects should meet the following LIFE regulation criteria:

• Be of interest to the community, notably through the contribution through implementing regional and international guidelines, orientation and agreement.

• To contribute to an approach promoting sustainable development at national, international and regional level

• To provide solutions to major environmental problems in the region and the relevant sectors

• To promote co-operation. • To ensure that technical proposals are practicable in terms of

technical feasibility, timetable, budget management and value for money.

• To be carried out by technically and financially sound participants. The Commission considers important the provisions of solutions which have an environmental preventive character or relating to activities which can have irreversible impacts on the environment and the environmental relevance of the projects on the basis of national, regional and international priorities. Research projects, commercial projects the organisation of conferences or seminars, environmental studies and actions of structural nature (construction of infrastructure, purchase of equipment, purchase of land) are not eligible for EC LIFE funding. Eligibility • The European Community will finance projects whose total costs are above

100,000 Euro and less than 600,000 Euro equivalent to about Lm40,000 to Lm240,000.

• Financial support received by third countries is limited to a maximum of 70% of eligible costs

• Programmes are open to national administration. However, persons or companies or organisations of whatever legal status may apply provided that the reside or are established in one of the eligible countries. Government and non-government organisations and technical assistance programme bodies may also apply.


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