Methodology used for the purpose of the case study research Studies published within the Danube Pollution Reduction Programme held by the MoE in cooperation with Programme Coordination Unit ENDP/GEF Assistance were examined (they contain some basic data concerning the factory; it is identified as a hot spot of water pollution). Interviews were made with some officials of the MoE/State Authority for Nature Conservation (MoE/SANC), the MoE/Hidrometeorological Institute (MoE/HI), the Environmental Inspectorate of the RS, and the Municipality of Krsko. The polluter was contacted as well. The five written requests for information concerning the water pollution caused by the factory were submitted to the responsible authorities. The answers gathered were examined. Overview of the requests for information made for the purpose of the case study research and answers received from public authorities 1) REQUEST: A request for data from the annual 1999 report of the operation monitoring of wastewater discharges from the factory was submitted to the MoE/SANC on July 19, 2000. ANSWER: The answer was not received up to date (September 15, 2000). Urgent letters/phone calls: A special letter was sent to the director of the SANC asking him to ensure that data requested are to be provided to us timely. Several telephone calls were made to official responsible to deal with our request. 2) REQUEST: A request for data gathered by the 1999 state immission monitoring of the quality of surface watercourse of the river Sava for measurement stations located upstream and dawnstream of the factory's (industrial) WWTP was submitted to the MoE/HI on July 21, 2000. ANSWER: The answer was provided timely, on July 26,2000. The photocopies of row data concerning analyses of the quality of water for both measurements stations identified in our request were provided (8 pages). 3) REQUEST: A request for data related to water issues from the rehabilitation programme imposed to the polluter as well as data related to measures concerning water pollution issue imposed by the MoE's consent to the rehabilitation programme, was submitted to the MoE/SANC on July 21, 2000. ANSWER: The answer was not received up to date (September 15, 2000). Urgent letters/phone calls: A special letter was sent to the director of the SANC asking him to ensure that data requested are to be provided to us timely. Several telephone calls were made to official responsible to deal with our request. 4) REQUEST: A request for list/type of information (concerning water pollution caused by the factory) held by the Municipality of Krsko, with special regard to those receiving from the polluter, was submitted to the Municipality on July 19, 2000. ANSWER: The answer was provided timely, on August 11, 2000. We were informed that the municipality has the information related to rehabilitation programme, namely the rehabilitation programme, the MoE's consent to the rehabilitation programme, and the 1998 Ecological Report - a summary of the 1998 annual report of the execution of measures imposed by the rehabilitation programme. The annual report for the year 1999 is still not submitted by the polluter to the municipality. In the procedure of adoption of the rehabilitation programme in 1997, a public hearing/discussion was organized by the municipality. 5) REQUEST:  A request was submitted to the Municipality of Krsko on August 30, 2000, for the information concerning: water issues from the rehabilitation programme imposed to the polluter, namely analysis of estimated environmental strain of waters caused by the factory, chosen solution for reduction of such strain, justification of the solutions chosen, and the time-schedule for achievement of wastewater parameters imposed by the programme; measures related to water pollution issue imposed by the MoE's consent to the rehabilitation programme, namely the limit values for particular parameters which must be met by the quality of waste water originated by the factory and a time-schedule for the compliance with them; execution of the rehabilitation programme in its part related to water pollution issue, as contained in the 1998 annual report made by the polluter. All three stated requests was made in the manner of asking authority to provide data from these documents concerning the facts identified in the request or to provide copies of actual documents containing the facts identified in the request. ANSWER: The answer was provided immediately on August 31. We received copies of the MoE's consent issued in 2000 to the altered rehabilitation programme and the polluter's 1998 Ecological Report (a summary of the annual report on the execution of the rehabilitation programme). In both cases information was provided in the form of photocopies of actual documents in their whole extend. Concerning the polluter's annual report it should be stressed that the polluter provides to the municipality a short summary of actual annual report being obligated to submit to the environmental inspection. Concerning the third information requested - the relevant part of the rehabilitation programme, the Municipality informed us that the rehabilitation programme is available for public examination in the municipality's office; the authority can not send it because of its extend. Actually, we was asked to make arrangement with the responsible official in order to visit municipality office, examine the document and choose what data we would like to get in photocopies. Short analysis of provision of information upon our requests We received 3 answers of 5 requests we made. Answers received were provided timely. Information was provided in the form of photocopies of the actual documentation as we requested. Submission of written requests was necessary since officials, which we firstly contacted by the telephone, were not willing to provide information without a written request. Provision of information was not charged in any case. Background information concerning the factory obtained The factory VIPAP VIDEM KRSKO (previous name ICEC) is located in the city of Krsko nearby the river Sava. It is one of the biggest water polluter in Slovenia. Average nutrient emissions are 2,350 tons of N and 470 tons of P yearly. The waste water originated in the factory constantly and equably exceeds before all the following parameters: BOD 5, COD, N and P. Ecological problems cause also sanitary pollution and toxic wastes originated by production. The factory has its own industrial WWTP situated on the bank of the river Sava. Discharges from the WWTP run directly to the river. Existing WWTP has no sufficient capacity to clean properly wastewater originated, especially concerning removal of suspended solids and toxic matters (e.g. Cl). Wastewater is discharged from outfalls of particular facilities within the factory as well. These discharges are measured and reported to the MoE/SANC as well as discharges from the WWTP. Extraordinary water pollution of the factory has transboundary implications; it causes eutrophication of the river Sava in Croatia. Water from the river Sava is used for drinking water supply of Zagreb, the main and biggest city of Croatia. Rehabilitation programme of the factory The factory is under rehabilitation programme from 1997. In 1999, the polluter proposed alteration of the programme and acquired the MoE’s consent for it. The consent was issued in February 2000. New limit-values for particular parameters of the quality of wastewater were imposed and a new time-schedule was set up for the compliance with them. The term for the conclusion of the whole rehabilitation programme was prolonged for four years, that is to the year 2006, but all measures concerning reduction of water pollution should be executed by the end of June 2004. The alteration of the programme was allowed since the polluter was proposed the replacement of the old technology for cellulose production with a new one that will reduce water pollution for 50 %. Another reason was that in meantime new regulations concerning limit values for emmision of substances by waste water from facilities for production of cellulose, paper, pasteboard and cardboard were adopted. According to the MoE’s consent, the polluter is obligated to prepare annual reports on the execution of the rehabilitation programme and submit them to the Environmental Inspectorate of the RS. Once a year, the polluter should also report about the course of the execution of the rehabilitation to the public of the Municipality of Krsko. The progress report of the execution of the rehabilitation programme for the year 1999 should be submitted to the inspection up to the end of August 2000. In the beginning of September we were contacted Environmental Inspection, a responsible department of the Environmental Inspectorate of the RS, and we were informed that the polluter has already submitted the respective report, but the inspection has not yet examined the report (it is rather extensive). Emission monitoring of wastewater originated by the factory and collection of data Regulations which apply to emission monitoring of waste water originated by the factory are the Decree on Emission of Substances and Heat by Discharges of Wastewater from Sources of Pollution and the Rule Book on First Measurements and Operating Monitoring of Waste Waters and on Conditions for their Performance. On the basis of documents we succeeded to obtain in our research we have figured out that the factory has 5 outflows of wastewater. According to the 1998 Ecological Report, an average yearly quantity of waste water exceed 100.000 m3 in all 5 outflows, what means that the factory should ensure permanent monitoring measurements on all of them. The polluter should prepare annual monitoring reports and submit them every year by March 31 to the SANC, the MoE’s agency. According to the 1998 Ecological Report, the factory performs the emission monitoring of wastewater by itself. For this purpose the factory has obtained the authorisation by the MoE (No. 354-1712/97). It allows the factory for performance of such monitoring up to the end of the year 2000. Some data from the polluter’s 1998 Ecological Report concerning the quality of wastewater According to the 1998 Ecological Report, the prescribed limit values for particular parameters of wastewater were exceeded the most on the outfall of wastewater originated within the cellulose production (outfall “KI B”). The average monthly quantity of wastewater discharged by this outfall in 1998 was 732.016 m3. On this outfall, the average concentration of wastewater for parameter COD exceeded the prescribed value for 19,6 times; for parameter BOD 5 for 15,4 times; for parameter total organic C (TOC) for 24,9 times; for parameter adsorbable organic halogens (AOX) for 158,8 times; and for parameter SO3 for 321,4 times. To this point it should be stressed that limit values indicated in the report are those which are prescribed by the Decree on Emission of Substances and Heat by Discharges of Wastewater from Sources of Pollution and not limit values imposed by the rehabilitation programme. So these data gives a picture of actual pollution caused by the factory in the year 1998. Activities of local non-governmental organizations During our research, a few local non-governmental environmental organizations were contacted by telephone concerning their eventual previous or present activities related to the issue of water pollution caused by the paper factory, but no one had any experiences in gathering information on such pollution or any other related experiences. We also ask about reaction of local people to extraordinary pollution caused by the factory in the office responsible for environmental protection within the Municipality of Krsko. The answer was that the local people have been protested mainly because of air pollution, and particularly odour problems.

Contents of this page: Methodology Overview of requests Analysis of requests Background information on the factory Rehabilitation programme of the factory Wastewater emission monitoring Wastewater quality data Activities of local non-governmental organizations