Conflict Pollution Hotspots in Iraq Land Remediation for Livelihoods Restoration Document of the World Bank Disclaimer This document is a product of the work carried out by the staff of the International Bank for Reconstruction and Development/The World Bank. The findings, interpretations, and conclusions expressed in this document do not necessarily reflect the views of the Executive Directors of The World Bank or the governments they represent. Although all efforts have been made to improve the accuracy of the information that was collected and analyzed, serious data limitations existed in the challenging context of Iraq. The World Bank hence does not guarantee the accuracy of the data presented in this document. The boundaries, colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of The World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. 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Cover photo: © Freepik Attribution Please cite the work as follows: World Bank. 2023. “Conflict Pollution Hotspots in Iraq: Land Remediation for Livelihoods Restoration. © World Bank.” CONTENTS List of Acronyms .......................................................................................................................................................... i Acknowledgments ....................................................................................................................................................... ii Executive Summary ................................................................................................................................................... iii 1. Introduction .............................................................................................................................................................. 1 1.1 Background ................................................................................................................................................................. 1 1.2 Objectives .................................................................................................................................................................... 2 1.3 Data, information sources, and methodology ......................................................................................................... 2 1.4 Data limitations and constraints ................................................................................................................................ 3 1.5 Structure of the report ................................................................................................................................................ 3 2. Inventory and Assessment of Pollution Hotspots .................................................................... 8 2.1 Screening and inventory of hotspots ........................................................................................................................ 8 2.2 Initial assessment of hotspots ................................................................................................................................... 11 2.2.1 Profile of pollution hotspots ............................................................................................................................ 12 2.2.2 Environmental profile of suspected hotspots ............................................................................................... 13 2.2.3 Land-use pattern at hotspot sites .................................................................................................................. 15 2.2.4 The health, economic, agriculture, and livelihood impacts of pollution hotspots .................................... 16 2.3 Hotspots mapping and information management system ..................................................................................... 19 2.3.1 Data for mapping and information management ......................................................................................... 19 2.3.2 Mapping of hotspots ........................................................................................................................................ 20 2.3.3 WebGIS: a web-based, GIS-enabled information system ......................................................................... 21 2.4 Assessment of risks and prioritization of hotspots for remediation ..................................................................... 23 2.4.1 Risk assessment methods .............................................................................................................................. 23 2.4.2 Risk assessment .............................................................................................................................................. 23 2.4.3 Risk ratings and prioritization ......................................................................................................................... 25 2.5 Stakeholder engagement and consultations .......................................................................................................... 27 2.5.1 Summary of consultations .............................................................................................................................. 27 2.6 Conclusion .................................................................................................................................................................. 29 3. Policy and Institutional Framework for the Management of Hotspots ............... 30 3.1 Introduction ................................................................................................................................................................. 30 3.2 Review of international practices ............................................................................................................................. 31 3.2.1 The United States Superfund Program ........................................................................................................ 31 3.2.2 Contaminated Sites Action Plan of Canada ................................................................................................. 32 3.2.3 Contaminated land management in the United Kingdom .......................................................................... 34 3.2.4 Contaminated sites management in the Netherlands ................................................................................. 35 3.2.5 Land remediation management in South Africa .......................................................................................... 36 3.3 Policy and regulatory framework in Iraq .................................................................................................................. 38 3.3.1 Current legal framework .................................................................................................................................. 38 3.3.2 Gap analysis ..................................................................................................................................................... 39 3.3.3 Required policy and regulatory enhancements ........................................................................................... 41 3.4 Institutional framework ............................................................................................................................................... 42 3.4.1 Current framework ........................................................................................................................................... 42 3.4.2 Institutional mechanisms for hotspot management .................................................................................... 43 . CONTENTS (CONTINUED) 3.5 Technical, institutional, and infrastructure requirements .............................................................................................. 45 3.5.1 Technical capacity ............................................................................................................................................ 45 3.5.2 Institutional capacity ........................................................................................................................................ 46 3.5.3 Infrastructure requirements ............................................................................................................................ 47 3.6 Conclusion ................................................................................................................................................................... 47 4. Technology Options for Remediation ................................................................................................. 48 4.1 Introduction ................................................................................................................................................................. 48 4.2 Remediation approaches .......................................................................................................................................... 49 4.2.1 Risk-based approach ...................................................................................................................................... 49 4.2.2 Standards-based or multifunctional soil remediation approach ................................................................ 49 4.2.3 Possible approach for hotspots management in Iraq ................................................................................. 50 4.3 Remediation options and technologies .................................................................................................................... 50 4.3.1 Excavation and Offsite Disposal .................................................................................................................... 52 4.3.2 Phytoremediation ............................................................................................................................................. 53 4.3.3 Soil Washing ..................................................................................................................................................... 54 4.3.4 Electrokinetic Separation ................................................................................................................................ 55 4.3.5 Soil Vapor Extraction ....................................................................................................................................... 56 4.3.6 Landfarming ...................................................................................................................................................... 57 4.3.7 Natural Source Zone Depletion ..................................................................................................................... 58 4.4 Factors influencing technology selection and applications ................................................................................... 59 4.5 Criteria for remediation technology selection .......................................................................................................... 60 4.6 Conclusion ................................................................................................................................................................... 62 5. Roadmap for Contaminated Sites Management ....................................................................... 63 5.1 Need for a national program ..................................................................................................................................... 63 5.2 Objectives .................................................................................................................................................................... 64 5.3 Guiding principles ....................................................................................................................................................... 64 5.4 Characteristics of a National Program for Contaminated Sites Management .................................................... 65 5.5 Roadmap for developing a national program .......................................................................................................... 65 5.5.1 Enhancing the legal and policy framework ................................................................................................... 66 5.5.2 Enhancing institutional capacity and planning ............................................................................................. 68 5.5.3 Allocating budget and securing financing ..................................................................................................... 68 5.5.4 Stakeholder consultations .............................................................................................................................. 70 5.5.5 Preparing the NPCSM and demonstration remediation projects .............................................................. 71 5.6 Conclusion ................................................................................................................................................................... 72 Appendixes ........................................................................................................................................................................ 73 Appendix A: General profile of pollution hotspots in Iraq .................................................................................................... 73 Appendix B: Methodology for hotspots inventory and mapping using spatial tools ........................................................ 76 Appendix C: Site inspection checklist .................................................................................................................................... 81 Appendix D: Source, pathway, and receptor for pollutants across hotspots .................................................................... 84 Appendix E: Summary of preliminary assessment of Health, Economic, Agriculture and Livelihood impacts of hotspots 98 Appendix F: Risk assessment summary ............................................................................................................................... 104 Appendix G: Participants of stakeholder consultations ....................................................................................................... 118 Appendix H: GoI Project team ................................................................................................................................................ 120 References ......................................................................................................................................................................... 121 LIST OF BOXES Box 1: Overview of risk assessment approaches ......................................................................................................... 24 LIST OF FIGURES Figure 1: Multistage process to identify, screen, and map contaminated sites ............................................................ 9 Figure 2: Distribution of hotspots by pollution category ................................................................................................... 10 Figure 3: Distribution of hotspots by governorate ............................................................................................................. 10 Figure 4: Geographical overview of hotspots in Iraq ........................................................................................................ 11 Figure 5: Number of people possibly directly and indirectly affected by pollution, by assessed governorate .......... 13 Figure 6: Suspected contaminated area, by assessed governorate .............................................................................. 13 Figure 7: Suspected pollution hotspots by nature of activity ........................................................................................... 14 Figure 8: Suspected pollution hotspots by major pollutant .............................................................................................. 14 Figure 9: Number of structures around pollution hotspots ............................................................................................... 16 Figure 10: Land-use patterns around hotspots ................................................................................................................... 16 Figure 11: Typical detailed map of hotspot with land cover—the Ibn Sina Company .................................................... 21 Figure 12: Typical detailed map of hotspot without land cover: the chemical contaminated site in Nineveh governorate (NIN 015) ......................................................................................................................................... 22 Figure 13: Typical WebGIS view of hotspots at site level: Al Shahid Company, Al Anbar ............................................. 22 Figure 14: Process of contaminated site management in Superfund program ............................................................... 31 Figure 15: The Federal Contaminated Sites Action Plan’s 10-step process in Canada ................................................ 33 Figure 16: Contaminated sites management framework in the Netherlands .................................................................. 35 Figure 17: Contaminated sites management process in South Africa .............................................................................. 37 Figure B1: Phenological changes and break in harmonic models detected by CCDC and fit to a time-series model .. 78 Figure B2: One-page map templates with Very High Resolution images ........................................................................ 80 © Adobe Stock CONTENTS (CONTINUED) LIST OF TABLES Table 1: Summary of candidate and suspected hotspot sites ....................................................................................... 10 Table 2: Profile of suspected pollution hotspots in Iraq .................................................................................................. 12 Table 3: Environmental profile of suspected hotspots in Iraq ........................................................................................ 13 Table 4: Number of sites exceeding Dutch Intervention Values for soil contamination .............................................. 14 Table 5: Land-use profile of pollution hotspots in Iraq .................................................................................................... 15 Table 6: Health, economic, agriculture, and livelihood impacts of pollution hotspots (US$ millions) ....................... 18 Table 7: Data sets for mapping hotspot sites ................................................................................................................... 20 Table 8: Summary risk ratings and prioritization of hotspots ......................................................................................... 26 Table 9: Summary of issues discussed during stakeholder consultations ................................................................... 28 Table 10: Summary of existing legislation relevant to contaminated site management in Iraq .................................. 38 Table 11: Environmental laws of Iraq relative to contaminated site management processes ..................................... 40 Table 12: Role of stakeholder ministries in hotspots management ................................................................................. 43 Table 13: Technical capacity requirements for contaminated sites management ......................................................... 45 Table 14: Potential remediation technologies relevant to profile of hotspots in Iraq ..................................................... 51 Table 15: Indicative budget for implementing remediation program ................................................................................ 69 Table A1: General profile of pollution hotspots in Iraq ....................................................................................................... 73 Table B1: Datasets hotspot inventory .................................................................................................................................. 76 Table B2: Output of the inventory component per vector dataset .................................................................................... 77 Table C1: Preliminary contamination observations ............................................................................................................ 81 Table D1: Source, pathway, and receptor for pollutants across hotspots ....................................................................... 84 Table E1: Estimate of burden of disease due to hotspots ................................................................................................. 98 Table E2: Estimate of economic impacts (loss of industrial production) ......................................................................... 101 Table E3: Estimate of loss of agriculture yield (wheat) ...................................................................................................... 102 Table E4: Estimate of loss of livelihood (industrial jobs) ................................................................................................... 102 Table E5: Estimate of loss of livelihoods (agricultural jobs) .............................................................................................. 103 Table F1: Summary of risk assessment ............................................................................................................................... 104 LIST OF ACRONYMS ASA Advisory Services and Analytics ARAR Applicable or Relevant and Appropriate Requirements CCDC Continuous Change Detection and Classification CoED Cost of Environmental Degradation COLD Continuous Monitoring of Land Disturbance CSO Civil Society Organizations DEM Digital Elevation Model DIVs Dutch Intervention Values EO Earth Observation EPA Environment Protection Agency EPD Environmental Protection Directorate ER Electrokinetic Remediation ESA European Space Agency FCSAP Federal Contaminated Sites Action Plan, Government of Canada FRTR Federal Remediation Technologies Roundtable, USA GDP Gross Domestic Product GIS Geographical Information System © Freepik LIST OF ACRONYMS (CONTINUED) GPS Global Positioning System ha Hectares HEAL Health, Economic, Agriculture, and Livelihoods I3RF Iraq Reform, Recovery, and Reconstruction Fund IQD Iraqi Dinar LNAPL Light Non-Aqueous Phase Liquid m Meters MoE Ministry of Environment MoO Ministry of Oil MPC Marginal Propensity to Consume NPCSM National Program for Contaminated Sites Management NSZD Natural Source Zone Depletion OSM OpenStreetMap SVOC Semi Volatile Organic Compounds TPH Total Petroleum Hydrocarbons UNEP United Nations Environment Programme UK United Kingdom US United States US$ United States Dollar UTM Universal Traverse Mercator US EPA United States Environmental Protection Agency VHR Very High Resolution VOC Volatile Organic Compounds © Freepik Acknowledgments This report is an output of World Bank’s Advisory Services and Analytics (ASA) work with co-operation from Ministry of Environment, Government of Iraq on “Support to the Management of Environmental Hotspots” financed by the Iraq Reform, Recovery, and Reconstruction Fund (I3RF) and was prepared by Environment, Natural Resource and Blue Economy (ENB) Global Practice of Middle East and North Africa (MENA) Region. The preparation of the report was led by Harinath Appalarajugari Sesha (Task Team Leader, Senior Environmental Engineer) with a team comprising Suiko Yoshijima (Senior Environmental Specialist), Ahmed Hasoon Ali (Environmental Specialist), Kevin Whittington-Jones (Senior Environmental Consultant), Zhong Xiong (Senior Environmental Consultant), Fadi Doumani (Senior Consultant— Environmental Economics). The team was supported by the European Space Agency’s Earth Observation Clinic for the initial research, with critical technical inputs by members of the Hatfield Consortium (Hatfield [Canada], GeoVille GmbH [Germany], and CLS [France]) and RSK LLC, UK. The task team is grateful to His Excellency Engineer Nazar Amedi, Minister of Environment and His Excellency Dr. Jasim Abdulazeez Hammadi Alfalahy, Deputy Minister of Environment, Government of Iraq for their leadership. Mr. Yousif Muayad Yousif, Director, Directorate of Climate Change, Mrs. Sarab Wajaan Ajeel, Manager, International Relationships Department, Mr. Oday Haddawee, Assistant Manager, International Relationships Department, and the Chemicals Monitoring and Contaminated Sites Assessment Department and National Experts Team (listed in Appendix H) led by Mr. Waleed Ali Hussein, Senior Chief Engineer, Ministry of Environment, Government of Iraq and other government institutions for their excellent support and cooperation in carrying out this study. The team would also like to thank the World Bank colleagues Saroj Kumar Jha (Global Director, Water), Ramzi Afif Neman (Senior Operations Officer, MENA Strategic Co-operation Department), Naila Ahmed (Program Manager, I3RF), Waseem Falih Kadhim Al Muqdadi (Deputy Program Manager, I3RF), Zeina Azar (Operations Officer, I3RF) for their support and inputs provided, Katelijn Van den Berg (Senior Environmental Specialist, East Asia and Pacific Region), Sameer Akbar (Senior Environmental Specialist, Europe and Central Asia Region), and Tracy Hart (Global Lead, Fragile and Conflict States) served as peer reviewers. Jean-Christophe Carret (Country Director, Middle East Department), Meskerem Brhane (Regional Director, Sustainable Development, MENA Region), Lia Carol Sieghart (Practice Manager, ENB Global Practice, MENA Region), Richard Abdulnour (Country Manager, Iraq), Lemya Izzet Ayub (Operations Officer, World Bank Office, Baghdad), Salim Rouhana (Sector Leader, Sustainable Development) provided guidance in carrying out this work. Victoria Bruce-Goga (Senior Program Assistant) and Hasan Jamal Mohsin (Program Assistant) provided logistical support. The report was edited by Jennifer Stastny and designed by Brett Jefferson Stott. Executive Summary 1. Introduction Successive conflicts in Iraq were characterised by tactics to damage its oil and industrial assets that not only led to huge economic loss, but pollution of environmental resources (air, land and water) on an unprecedented scale. The Damage and Needs Assessment (DNA)1 carried out by the World Bank Group (WBG) in 2017, estimated damages to the environmental resources at IQD85 billion (US$73 million) and sectoral losses as a result of the conflict at IQD3.5 trillion (US$3 billion). Further, this assessment estimated that up to 47 percent of natural forests in the country may have been destroyed and large areas of land have been contaminated by land mines and hazardous chemicals. Unless these contaminated sites (also referred as ‘environmental hotspots’ in this document) are identified and remediated and/ or managed appropriately as part of the broader reconstruction program of Iraq, it is likely that the negative impacts (both economic and environmental) will be felt for generations to come. In addition, creating better environmental conditions and investments in human and physical capital is crucial for the economic diversification, job creation and healthy citizens for a stable and sustainable development of post-conflict Iraq. The main objective of this report is to present a broad framework and suggested prioritization for the remediation and/or management of environmental hotspots in Iraq. The recommendations have been informed by a detailed inventory and assessment of hotspots carried out by the Ministry of Environment (MoE), Government of Iraq (GoI) with capacity building support provided through the Advisory Services and Analytical (ASA) work of the World Bank. The work involved analysis of the scale and significance of contamination in the conflict affected governorates of Al Anbar, Babil, Baghdad, Diyala, Kirkuk, Nineveh and Salah Al-Din and identifying essential elements of a program for the remediation/ management of environmental hotpots in the country. © Freepik 1 World Bank, 2018. 1 Iraq Pollution Hotspots 2. Inventory and assessment of environmental hotspots The inventory and assessment work carried out by the MoE with contamination exceeds 100 times the Dutch Intervention Values technical support from the World Bank’s ASA involved: (DIVs) at 32 sites; 50 times the DIV at seven sites; and 10 times • Screening and developing an inventory of hotspots the DIV at the remaining 30 sites. The Kirkuk governorate is through spatial analysis of satellite imagery using estimated to have the largest impacted population, with about the Continuous Change Detection Classification 1.1 million people affected by pollution. (CCDC) algorithm. Site assessments further indicated that about 1,569 ha of • Field visits and initial assessments of suspected hotspot agriculture land; 3,018.38 ha of vegetation; and 8,482 structures sites including laboratory analysis of soil and water samples are impacted by contamination. Nine major industries are to understand the nature and magnitude of contamination, completely damaged and are currently not in operation. This and its impacts on local communities. indicates the level of environmental and health challenges • Risk-based classification and prioritization of posed by the hotspots in Iraq, as well as the potential sites for detailed assessments and remediation gains due to their management or remediation. • Detailed mapping of identified hotspots along with Web Geographical Information To better understand these challenges, System (WebGIS) database for the burden of diseases, economic cost future updating. of destroyed industries, opportunity cost of affected agricultural land, and loss of The inventory and assessment activities livelihoods due to destroyed industries established that Iraq’s pollution hotspots and agriculture was estimated. These indicate widespread hydrocarbon and estimates indicate that the overall chemical contamination. Of the total cost of Health, Economic, Agriculture 76 “suspected hotspots” identified, field and Livelihood (HEAL) impacts at the assessment could be carried out for 69 identified suspected hotspots in Iraq is sites in 47 locations (including 20 damaged around US$1.44 billion per year. © MoE and RSK LLC industrial units). This assessment suggests that about 1,333.03 hectares (ha) of land is likely to Further, an assessment of risks due to these have been contaminated, affecting an estimated 55,050 suspected pollution hotspots identified that the risks people directly and more than 1.70 million people indirectly. Most are very high at five sites; high at 18 sites; moderate at 24 sites; of the pollution hotspots are in the three governorates of Kirkuk moderate/low at 16 sites; and low at five sites. Stakeholder (24 sites), Nineveh (17 sites), and Salah Al-Din (13 sites). consultations carried out as part of the assessment also confirmed the significant impacts faced by local communities Environmental analysis of the soil and water (surface and around these hotspots and emphasized the urgent need for groundwater) samples at these sites indicated that the level of remediation and management of contamination. 3. Policy and institutional framework for the management of hotspots Building on the inventory and assessment of hotspots, an analysis institutional mandate for managing contaminated sites need to be of regulatory, institutional, and capacity-building requirements for included in the current regulatory framework. the management of environmental hotspots in Iraq was carried out. This involved reviewing both international practices in Accordingly, the analysis identified the specific need to: strengthen contaminate site management (from the United States of America policy and regulatory framework in line with the international good (USA), the United Kingdom (UK), Canada, the Netherlands, practices; establish an institutional mechanism that ensures and South Africa) and Iraq’s current regulatory and institutional coordination between various stakeholder ministries; and build the framework. This analysis indicated that Iraq has a comprehensive technical and institutional capacity of MoE. The report identified set of environmental regulations that includes certain aspects a set of options for each of the above enhancements. However, relevant to contaminated sites management, such as regulations these options need to be further evaluated based on more detailed for hazardous waste, storage and handling of chemicals, and analysis of each element, more specifically in the context of an inclusion of “Polluter Pays” principle. However, some important overall program on contaminated sites management in Iraq and requirements for the identification, assessment, remediation, and its specific interventions. Land Remediation for Livelihoods Restoration 2 © Freepik 4. Technology options for remediation In order to develop a roadmap for the remediation of pollution technologies. While no specific technology is recommended, the hotspots in Iraq, a review of technology options that may be ASA presents salient features of available technologies along relevant to the nature, type, and local context was carried out. with the advantages, disadvantages, and indicative costs of each The review focused on four critical elements of remediation: option per unit of contaminant to be removed. These elements remediation approaches (risk based versus standards based); should be closely evaluated based on a detailed assessment of available technologies; factors that influence the selection of each hotspot and stakeholder consultations in order to choose technologies; and the criteria to be followed in selecting remediation suitable technology for the targeted land use of the respective site. 5. Roadmap for contaminated sites management in Iraq Based on the analysis of pollution hotspots, their potential to legislation on contaminated sites; establishing standards for cause health and environmental impacts, and a review of the legal, remediation; establishing an institutional mechanism supported by institutional, and technological aspects related to the assessed capacity-building measures; identifying financing mechanisms for contaminated sites, the report recommends establishing a implementation; and ensuring the participation of all government National Program for Contaminated Sites Management (NPCSM). and community stakeholders in the proposed NPCSM. In the initial phase, the NPCSM is recommended for five years at a broad estimated cost of US$422 million. A project to implement the actions recommended for the development of NPCSM and demonstration remediation projects A proposed roadmap detailing specific actions for policy, has also been recommended. Implementation of this project regulatory, institutional, and demonstration remediation projects is and roadmap actions will help ensure better management of also presented. The actions recommended in the roadmap include contaminated sites in Iraq. developing a contaminated site management policy; promulgating 3 Conflict Pollution in Iraq 1 Introduction 1.1 Background Successive conflicts in Iraq were characterized by tactics to damage the country’s oil and industrial assets. This led not only to huge economic loss, but to the pollution of air, land, and water on an unprecedented scale. The Damage and Needs Assessment2 published by the World Bank in 2018 estimates environmental resources damages resulting from various conflicts at Iraqi Dinar (IQD) 85 billion (US$73 million), with sectoral losses at IQD3.5 trillion (US$3 billion). The Damages and Needs Assessment also estimated that as much as 47 percent of the country’s natural forests may have been destroyed, while 2.4 million hectares of high-use land has been rendered unusable due to landmines, and at least 10,569 ha have been lost due to pollution by hydrocarbons and other chemicals. The true extent of conflict-related land contamination, however, is yet to be confirmed. Without any intervention, the contamination of land is expected to have long-lasting impacts for the safety, health, and livelihoods of communities, with disproportionately high impacts on the most vulnerable members of society, who continue to access these contaminated sites for agriculture, animal grazing, and other domestic activities. These groups, as estimated by the Damage and Needs Assessment, include about three million internally displaced persons, women, female-headed households, and the youth. Future generations will likely suffer the economic and environmental impacts of these contaminated sites (also referred as “pollution hotspots” in this document) unless they are identified and remediated or managed appropriately as part of Iraq’s broader reconstruction program. Creating better environmental conditions and investments in human and physical capital are crucial for the economic diversification, job creation, and healthy citizens that will form the foundation of stable and sustainable development in post-conflict Iraq. © Freepik 2 World Bank, 2018. 1.2 Objectives This report presents a broad framework for the remediation and management of pollution hotspots in Iraq and identifies priorities for further action. Its recommendations are informed by an inventory and assessment of hotspots carried out by the Ministry of Environment (MoE), Government of Iraq, with capacity-building support provided through the Advisory Services and Analytical (ASA) work of the World Bank. The work analyzed the scale and significance of contamination in conflict-affected governorates and identified essential elements for a remediation and management program in targeted pollution hotspots. In addition to improving the environmental conditions and reducing associated health risks for communities, implementing such a framework would also enable the restoration of livelihoods and economic development in affected governorates. Another important objective of the World Bank’s ASA was building the capacity of the MoE and other government agencies under which this report is prepared. This was achieved by providing technical support and delivering virtual, classroom, © MoE and RSK LLC hands-on, and on-site training programs that followed a “learning by doing” approach. The training focused on identifying, mapping, assessing, and prioritizing hotspots for remediation. A customized training program on estimating the Cost of Environmental Degradation (CoED) was also provided. 1.3 Data, information sources, and methodology The main regions of Iraq impacted by conflicts were the and manage such sites will help analyze pollution hotspots in governorates of Al Anbar, Babil, Baghdad, Diyala, Kirkuk, Nineveh, other regions of Iraq. In addition to conflict pollution, radioactive and Salah Al-Din. Since the focus of this ASA report (and that of contamination is anticipated in some southern areas of the the Iraq Reform, Recovery, and Reconstruction Fund [I3RF]) is country. This aspect, however, was not analyzed by this ASA, as on conflict pollution, it focuses only on these seven governorates. it is usually assessed by the International Atomic Energy Agency. Similarly, the landmine and explosive remnant contamination in While most of the conflict-related contaminated sites are expected the country is also not analyzed, since these assessments are to be in these governorates, the broad framework proposed in coordinated at the local and international levels by the United this report and the enhanced capacity of the MoE to assess Nations Mine Action Service.4 DATA AND INFORMATION SOURCES This report relied on existing data and information available from the MoE and further updating carried out by the ministry’s Chemicals Monitoring and Contaminated Sites Assessment Department. The work carried out by the MoE, with support from this ASA, involved: • Updating the inventory and mapping of suspected contaminated sites • Field visits and initial assessments of suspected sites to understand the nature and magnitude of contamination and its impacts on local communities. • Risk-based classification and prioritization of sites for detailed assessments and remediation. 3 IAEA 2018. 4 UNMAS 2021. 5 Conflict Pollution in Iraq METHODOLOGY Agencies and international experts that specialize in the above aspects provided virtual, classroom, and on-site field training to officials from the MoE, the Ministry of Oil (MoO), their regional and local teams, and Environment Protection Directorates (EPDs). In addition to building technical capabilities, the training ensured that appropriate data was collected and managed in a consistent manner to aid future analysis. Capacity-building involved the following training programs: 1 A five-day comprehensive virtual training program for 30 environmental engineers and scientists from the MoE, MoO, and EPDs, was provided by the World Bank’s technical experts on contaminated site management, totaling 150 person-days. This training focused on the identification, assessment, remediation, management, and post-remediation monitoring of contaminated sites (June 8–15, 2021). On-the-job virtual training on identifying and taking inventory of suspected contaminated sites by analyzing satellite imagery 2 was provided for eight members of the MoE’s Geographical Information System (GIS) team between June and December 2021 (64 person days). This training was provided by experts hired by the European Space Agency (ESA) through its Earth Observation (EO) Satellites Clinic program. 3 A two-day classroom training program on the design of environmental sampling strategies and initial assessment of contaminated sites was provided for 30 environmental engineers and scientists from the MoE, the MoO, and the EPDs (60 person days) by an expert international consulting firm on contaminated site assessment (April 3–4, 2022). 4 On-site and on-the-job training (following a “learning by doing” approach) was provided for 30 environmental engineers and scientists from the MoE, the MoO and the EPDs (900 person days) by an expert international consulting firm on environmental sampling, assessment, and baseline profiling of contaminated sites (April–July 2022). 5 A two-day laboratory and hands-on training program was provided for eight environmental scientists of the MoE (16 person days) on analyzing water and soil samples for chemical contamination. This training was provided at the advanced laboratory of an expert international consulting firm (August 28–29, 2022). 6 On-the-job (virtual) and a five-day hands-on training program on detailed mapping of contaminated sites, developing an online GIS (that is, a WebGIS), and managing and updating data related to contaminated sites was provided for eight members of the MoE’s GIS team (40 person days) (October 17–21, 2022) at a specialized laboratory in France. 7 A five-day comprehensive face-to-face training program on assessing CoED (November 7-11), was provided for 20 government officials in Beirut, Lebanon (100 person days) (November 7–11, 2022). OUTPUTS The following outputs were produced through the above capacity building programs. • A comprehensive inventory with detailed maps of suspected pollution hotspots was prepared using innovative spatial analysis techniques based on the Continuous Change Detection Classification (CCDC) algorithm and grid-based characterization of sites.5 • An environmental, social, and chemical baseline profile of all the suspected contaminated sites was developed.6 • A risk-based classification of sites and prioritization for further assessments and remediation was completed.7 • An interactive WebGIS database for continuous monitoring and updating of information on contaminated sites was developed.8 5 MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022, MoE and Hatfield Consultants LLP 2022. 6 MoE and RSK Environment LLC 2022. 7 MoE and RSK Environment LLC 2022 and 2023. 8 MoE and Hatfield Consultants LLP 2022. Land Remediation for Livelihoods Restoration 6 Building on the above outputs, the World Bank team conducted a review of Iraq’s legal and institutional framework for managing contaminated sites, with an aim of identifying areas for enhancement. A review of technologies for the remediation of chemical and hydrocarbon contaminated sites was also carried out to identify the technologies that would be most suitable in the context of Iraq. This report draws on the above analyses, reviews, and consultations and presents a framework for the management or remediation of pollution hotspots in Iraq. 1.4 Data limitations and constraints Analyzing and assessing sites affected by chemical contamination such as (1) conducting site © MoE and RSK LLC requires detailed sampling and extensive field investigations. Water assessments and sampling; (2) and soil samples collected from the sites also require careful use of satellite imagery, GIS, and analysis for a wide range of contaminants such as Total Petroleum other digital tools for collection and Hydrocarbons (TPH), Volatile Organic Compounds (VOCs), Semi analysis of field-level data; (3) collection and collation of information Volatile Organic Compounds (SVOCs), and Heavy Metals. These through earlier studies; as well as (4) use of data from MoE and analyses require expertise and use of advanced equipment such consultations with various stakeholder agencies. as Gas Chromatography-Mass Spectrometry, Inductively Coupled Plasma-Mass Spectrometry, and Energy Dispersive X-Ray While these efforts did help in obtaining the most relevant data Fluorescence. Access to this level of expertise and infrastructure and information required for the development of a framework required for extensive field investigations is limited in Iraq. for the management of environmental hotspots in Iraq, further refinement and more detailed field assessments are needed before The COVID-19 pandemic and the security situation in the country designing and implementing remediation plans for individual sites. also severely hampered the MoE team’s field work. These The findings and observations in this report should therefore be challenges were addressed by providing extensive training (virtual, considered from this perspective and policies and programs shall classroom/face-to-face and on-the-job trainings as elaborated in be developed accordingly. section 1.3 above) to government officials on all relevant aspects 1.5 Structure of the report The results of the analysis along with the broad framework for current regulatory and institutional regime to address the issue of addressing the issues related to environmental hotspots in Iraq land contamination and enhancements or improvements needed is presented in five chapters. for implementing a sustainable contaminated sites management program. Based on the profile of hotspots, Chapter 4 evaluates While Chapter 1 (the current chapter) provides an overall the technological options for the remediation of hotspots, their background of the work, objectives, and approach followed in relevance in the context of Iraq, and associated cost implications. carrying out the analysis, Chapter 2 presents an inventory and Building on the analysis carried out in the earlier chapters, analysis of the profile, type, magnitude, and an initial assessment Chapter 5 presents the recommended roadmap for developing a of impacts of contamination in the hotspots across seven targeted program for the management or remediation of hotspots in Iraq. governorates of Iraq. Chapter 3 provides an analysis of the © Freepik 7 Conflict Pollution in Iraq 2 Inventory and Assessment of Pollution Hotspots This ASA builds on earlier work conducted by the MoE and the United Nations Environment Programme (UNEP) to understand and assess the environmental pollution caused by a series of conflicts in Iraq. This included the following studies and projects. Strengthening environmental governance in Iraq through environmental assessment and capacity building project (2004–05): This project was funded by the United Nations Trust for Iraq. It focused on identifying potentially contaminated sites and building the MoE’s capacity to conduct site assessment.9,10 The project identified five priority sites for remediation of more than 100 sites identified across the industrial, mining, and oil refinery sectors. A follow-up project to contain and clean hazardous material at two sites was proposed. Capacity Needs Assessment of the institutional and regulatory framework for environmental management in oil and gas sector (June 2018): With the support from the Norwegian government’s Oil for Development program, UNEP assessed the needs of the oil and gas sector for environmental management after conflicts in Iraq subsided in 2018.11 This study identified regulatory and institutional gaps and recommended establishing an inventory of environmental issues (including contaminated hotspots) related to the oil and gas sector. Mapping of oil pollution in Iraq (2018–19): UNEP, with financing from its Disaster Management Branch, conducted field visits and prepared GIS maps of the sites affected by oil pollution in Nineveh, Kirkuk, Salah Al-Din, and Diyala. The study produced a rapid inventory of 75 sites contaminated with hydrocarbons and diagnosed 23 sites as high risk. It also recommended developing plans to address the issues of oil or hazardous waste pollution and building the MoE’s capacity to assess sites and design remediation plans. 2.1 Screening and inventory of hotspots International practice to identify and manage contaminated sites follows a sequential process. In the first step, “suspected sites” are identified based on current or past site use or historical incidents. After an initial site assessment and preliminary risk assessment of suspected sites, “ potentially contaminated sites” are identified. This process is referred to as “Phase 1 Assessment”. In the next step, detailed assessment (referred to as “Phase 2 Assessment”) of potentially contaminated sites involving comprehensive environmental investigations is conducted to establish the levels of contamination and risks to neighboring communities. “Contaminated sites” are identified based on this detailed assessment. Necessary steps for the preparation of management or remediation plans (referred to as Phase 3) based on the information obtained above and their implementation (Phase 4) is then initiated. The effectiveness and results of the management or remediation are subsequently monitored in Phase 5. 9 UNEP 2005. 10 UNEP 2007. 11 UNEP 2018a. 12 MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. Referring to the above process, the sites identified by the MoE so far However, security situation in Iraq and COVID 19 pandemic can be termed as “suspected sites” through Phase 1 assessment. during the years 2021 and 2022, posed challenges to MoE team These sites, however, are limited to four governorates where in conducting field visits and preparing the inventory of hotspots. the majority of the sites were reported. Building on this work, Considering this, technical support from ESA’s EO clinic was during the period June to December 2021, the MoE developed leveraged (through Hatfield Consultants LLP), who provided a comprehensive inventory of hotspots across all seven conflict- handholding support to MoE team (technical and GIS teams) in affected governorates of Iraq: Al Anbar, Babil, Baghdad, Diyala, the development of inventory of hotspots through spatial tools. Kirkuk, Nineveh, and Salah Al-Din.12 The approach as presented in the figure below involved a multistage process to identify and screen the sites with the help of multiple digital data sets involving the following steps: 1 An inventory of suspected pollution hotspot sites was prepared based on an analysis of information from the MoE; spatial data from OpenStreetMap (OSM) (industrial and/or military polygons from OSM for possible contamination); and German Aerospace Center, Global Urban Footprint, and Environmental Systems Research Institute data sets. This analysis sought to identify potential pollution to develop a hazard site inventory. Candidate sites and land-cover disturbance events were screened using the CCDC algorithm on the Landsat archive (1984 2 to present) and Sentinel-2 archive (2015 to present) to identify significant land cover disturbance events. An inventory of suspected hotspot sites was then prepared based on the grid-based assessment of sites for targeted time 3 periods using Airbus OneAtlas and Maxar SecureWatch. These sites were verified by on-the-ground knowledge of the MoE team. In addition to providing a robust inventory on suspected hotspot sites (Appendix A), this exercise demonstrated the effectiveness of spatial data analysis for screening, identifying, and mapping contaminated sites in situations where access is restricted, and time is limited. A more detailed description of spatial analysis followed for preparing the inventory of “suspected hotspot sites” is presented in Appendix B. Figure 1: Multistage process to identify, screen, and map contaminated sites OpenStreetMap MoE/World Bank industrial or military identified sites polygons • Group sites into polygons for assessment. Minimum 2x2 km bounding box for each site Hazard site inventory • % built environment (DLR GUF) • % crop, water, vegetation (Esri 10m land cover) • Attribute potential pollution, site name, etc Candidate sites list CCDC algorithm to assess change within 2x2 km bounding box Hazard site history & screening • Landsat archive 1984–present • Sentinel-2 archive 2015–present • Identify significant land cover disturbance events Candidate • Timing and magnitude of change sites list Hazard site Attribute 100x100m grid with land use, damage characterization and pollution (visual assessment) • Target time periods: 2000, 2005, 2017, 2021 • Airbus OneAtlas and Maxar SecureWatch images Candidate sites list Detailed site Detailed site mapping mapping • Airbus OneAtlas and Maxar SecureWatch images • Land cover/use • Hazards, Pathways, Receptors 9 Conflict Pollution in Iraq Based on the knowledge gained through virtual training in waste-contaminated sites. In terms of geographical distribution, 2021, the MoE’s GIS team screened 216 candidate sites and 36.84 percent (28 sites) of the sites are in Kirkuk governorate, identified 76 suspected hotspots in Iraq (Table 1). Of these sites, 22.37 percent (17 sites) in Nineveh, and 19.73 percent (15 sites) 51 (67.1 percent) are oil-contaminated, 23 (30.26 percent) in Salah Al-Din. The detailed list of suspected contaminated sites are chemical-contaminated, and two (2.63 percent) are within each governorate is presented in Appendix A. Table 1: Summary of candidate and suspected hotspot sites Candidate Hotspot Sites Suspected Hotspot Sites Governorate Chemical Oil Waste Total Chemical Oil Waste Total Al Anbar 16 1 0 17 5 1 0 6 Babil 6 2 0 8 1 0 0 1 Baghdad 17 2 2 21 8 0 0 8 Diyala 5 2 0 7 1 0 0 1 Kirkuk 14 30 21 65 1 26 1 28 Nineveh 17 63 0 80 4 12 1 17 Salah Al-Din 8 8 2 18 3 12 0 15 Total 83 108 25 216 23 51 2 76 Source: Based on inventory by MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. Figure 2: Distribution of hotspots by pollution category Figure 3: Distribution of hotspots by governorate 2 sites 1 site Babil Waste 1 site Diyala 6 sites Al Anbar 8 sites Baghdad 23 sites 28 sites Chemical Kirkuk 15 sites Salah Al Din 51 sites 17 sites Ninevah Oil Source: Analysis of inventory by MoE, Hatfield Consultants LLP, Source: Analysis of inventory by MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. CLS, and GeoVille 2022. The inventory of contaminated sites includes only the seven conflict-affected governorates of Iraq. Significant industrial activity and waste management challenges could mean that there are pollution hotspots in the other 12 governorates of Iraq as well. This limitation was addressed by the training provided to the MoE’s GIS team in October 2022, which focused on identifying, screening, and mapping suspected contaminated sites using spatial tools. An updatable WebGIS on identified hotspots has also been developed (Figure 4). Through this training and WebGIS, MoE can identify hotspots in other governorates of Iraq. Land Remediation for Livelihoods Restoration 10 Figure 4: Geographical overview of hotspots in Iraq Source: MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. 2.2 Initial assessment of hotspots Governorate-specific site-assessment teams were formed to • A detailed site-inspection checklist (Appendix C) was developed. carry out the initial assessments of suspected pollution hotspots This checklist included basic information such as the site’s name between April and August 2022.13 These teams comprised and Global Positioning System (GPS) coordinates, the source members of the relevant ministries, notably the MoE; local and history of contamination, and visible and reported impacts, agencies with knowledge of the sites; and other stakeholders. as well as an option for photographic evidence. • Administrative and security permissions were obtained from The World Bank team provided the MoE and other relevant site-owning authorities and agencies to conduct stakeholders with technical and capacity building support site visits. in carrying out the following steps of initial assessment: • Site visits were conducted to collect basic data and obtain limited environmental samples to confirm the nature and type • A two-day training program was held for the MoE, MoO, and of contamination at the sites. governorate-level EPD teams focusing on how to review available data and information; identify and finalize site-level • Environmental samples were analyzed in a laboratory to additional information to be collected; and design sampling establish the level of contamination. strategies and site-specific sampling plans. This training also • An overall environmental profile of each site was prepared. covered health and safety measures to be taken up in carrying out site assessments, among other topics. 13 MoE and RSK Environment LLC 2022. 11 Conflict Pollution in Iraq 2.2.1 PROFILE OF POLLUTION HOTSPOTS Following the above process, site assessments were conducted at 69 suspected sites in 47 locations. Seven sites could not be assessed due to lack of security or access permissions from relevant site authorities. The assessment found that about 1,333.03 ha of land might have been contaminated (980.55 ha directly and 352.48 ha indirectly), impacting about 1.75 million people, or about 8.55 percent of the total governorate population (Table 2). In addition to environment and health impacts, the contamination is also expected to have affected the livelihoods of these people owing to reduction or loss in productivity of agriculture lands and job opportunities due to destroyed industrial facilities and other economic assets. This aspect is discussed in more detail in Section 2.2.4. Table 2: Profile of suspected pollution hotspots in Iraq Suspected Contaminated Affected Population Affected Total Area, (ha) (approximate) Governorate Governorate locations hotspots* population** Direct Indirect Direct Indirect Al Anbar 5 5 501.66 25.12 4,260 89,000 1,771,656 Babil 1 1 6.20 12.56 1,080 10,000 2,065,042 Baghdad 6 6 27.64 56.52 10,930 78,500 8,126,755 Diyala 1 1 0.30 3.14 1,200 10,000 1,637,226 Kirkuk 13 24 33.45 94.20 2,660 1,100,900 1,597,876 Nineveh 8 17 275.20 82.44 25,570 181,500 3,729,998 Salah Al-Din 13 15 136.10 78.50 9.350 231,677 1,595,235 Total 47 69 980.55 352.48 55,050 1,701,577 20,523,788 Grand Total 1303.03 1,756,627 (8.55% of governorates population) * Seven sites could not be assessed due to access issues: three in Kirkuk, two in Baghdad, and one each in Al Anbar and Nineveh. ** Central Statistics Organization (Government of Iraq) 2018.14 Source: Based on inventory by MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. Across the seven governorates, Kirkuk had the largest number of hotspots (24 out of the total 69 hotspots), affecting over 1.1 million people (Figure 5). Al Anbar had the largest area of contaminated land, totaling about 501.66 hectares over five hotspots in five locations (Figure 6). The Nineveh governorate led in the number of people directly affected by the contamination (55,050 people), followed by Baghdad (19,930 people). © Freepik 14 Central Statistics Organization. (Government of Iraq). 2018. “Populations Projections 2015–18”. Land Remediation for Livelihoods Restoration 12 Figure 5: Number of people possibly directly and indirectly Figure 6: Suspected contaminated area, by assessed governorate affected by pollution, by assessed governorate 1,200,000 600 Number of possibly affected people Total contaminated area (ha) 1,000,000 500 400 800,000 300 600,000 200 400,000 100 200,000 0 r bil la uk h in 0 d ba va da ya -D Ba rk An ne Al Di gh Ki r bil la uk h in d Ni ba Al lah va Ba da ya -D Ba rk An ne Al Di Sa gh Ki Governorate Ni Al lah Ba Sa Governorate 2.2.2 ENVIRONMENTAL PROFILE OF SUSPECTED HOTSPOTS To prepare the environmental profile of hotspot sites, the basic characteristics of each site with regard to the nature of industrial and/or production activities, area of the site, environmental features, land use, and socio-economic profile, were analyzed. This analysis, as summarized in Table 3, indicates that 43 of the total 69 sites assessed (62.31 percent) are oil refinery and gas isolation facilities and 10 sites (14.49 percent) are fertilizer/chemical industrial sites. These suspected hotspots are distributed in 47 locations, 27 of which are oil/Hydrocarbon, and 20 industrial hotspots. A site-specific sampling strategy was developed to understand the type of pollutants and the level of contamination by collecting three or four soil, surface water, and groundwater samples from each site. These samples were analyzed for the following potential contaminants: Volatile Organic Compounds (VOCs), Semi Volatile Organic Compounds (SVOCs), Heavy Metals, © MoE and RSK LLC Total Petroleum Hydrocarbons (TPHs), and other basic environmental parameters.15 Table 3: Environmental profile of suspected hotspots in Iraq Hotspot nature/type Major pollutants Governorate Fertiliser/ Engineering Hydro- Heavy Chemicals & Oil/gas Others Metals chemical & electrical carbons Metals Asbestos Al Anbar 1 3 0 1 1 0 2 2 Babil 0 1 0 0 0 1 0 0 Baghdad 1 3 2 0 1 4 0 1 Diyala 0 0 1 0 1 0 0 0 Kirkuk 22 1 0 1 19 1 0 4 Nineveh 12 1 1 3 11 3 3 0 Salah Al-Din 7 1 2 5 13 2 0 0 Total 43 10 6 10 46 11 5 7 Source: Based on site assessment by MoE and RSK Environment LLC 2022. 15 Standard parameters to understand pollution at the sites identified. 13 Conflict Pollution in Iraq Figure 7: Suspected pollution hotspots by nature of activity Figure 8: Suspected pollution hotspots by major pollutant 6 sites 5 sites Engineering & Electrical Chemicals & Asbestos 7 sites 10 sites Metals Fertiliser/Chemical 11 sites Heavy Metals 10 sites Others 43 sites 46 sites Oil/Gas Hydrocarbon Source: Based on site assessment by MoE and RSK Source: Based on site assessment by MoE and RSK Environment LLC 2022. Environment LLC 2022. The results of the laboratory analysis of water samples were compared with the MoE’s guidance values and found to be within standards. Soil contamination levels were determined by comparing soil sample results with the Dutch Intervention Values (DIVs).16 The soil analyses found that, out of 69 sites, 46 were polluted by Hydrocarbons and TPHs, 11 were contaminated by Heavy Metals, five sites were contaminated by chemicals and Asbestos, and seven sites were contaminated by Metals. All contaminated sites exceeded the DIVs of their pollutants tenfold, with 32 of the sites exceeding 100 times the DIVs for some pollutants (Table 4). Table 4: Number of sites exceeding Dutch Intervention Values for soil contamination Hydrocarbons and Total Petroleum Heavy Metals Chemical & Asbestos Metals Hydrocarbons Governorate 10xDIV 50xDIV 100xDIV 10xDIV 100xDIV 10xDIV 50xDIV 10xDIV Al Anbar 0 0 1 0 0 2 0 2 Babil 0 0 0 1 0 0 0 0 Baghdad 1 0 0 3 1 0 0 1 Diyala 0 0 1 0 0 0 0 0 Kirkuk 4 0 15 1 0 0 0 4 Nineveh 4 3 4 4 0 0 3 0 Salah Al-Din 3 1 9 1 1 0 0 0 Total 12 4 30 9 2 2 3 7 Grand Total 46 11 5 7 Source: Based on MoE and Hatfield Consultants LLP 2022. 16 Dutch Ministry of Housing, Spatial Planning, and the Environment 2000. Land Remediation for Livelihoods Restoration 14 Hydrocarbon and TPH contamination exceeded 100 times the DIV in 30 (65 percent) of the total 46 Hydrocarbon and TPH contaminated sites. The level of Heavy Metal contamination exceeded 10 times the DIV in nine (82 percent) of the total 11 sites and the chemical contamination exceeded 50 times the DIV in three of the five sites. Metal contamination in all seven contaminated sites exceeded 10 times the DIV. The contamination of sites with hazardous substances poses significant and direct environmental and health risks to more than 55,050 people who either work at these sites or live close by. In addition, the contamination poses significant risks to more than 1.75 million people within the sites’ influence area. © MoE and RSK LLC 2.2.3 LAND-USE PATTERN AT HOTSPOT SITES High levels of contamination could cause agricultural and economic losses. Land-use patterns around the hotspots were analyzed as part of the initial site assessment exercise. This revealed that cropland constitutes about 1,569 ha (27.68 percent) and vegetation about 3,018.38 ha (53 percent) of the total area. Roughly 94 percent (1,476.55 ha) of the cropland and about 82.02 percent (2,475.72 ha) of land with vegetation is in Kirkuk, Nineveh, and Salah Al-Din. The remediation of hotspots in these governorates could therefore also contribute to the enhancement of agricultural productivity and growth of vegetation in surrounding areas. Table 5: Land-use profile of pollution hotspots in Iraq Number of Land-use pattern around hotspots (ha) structures Governorate around hotspots Cropland Built up Vegetation Shrubs Water Total Al Anbar 672 5.73 110.83 295.28 1.38 0.27 413.49 Babil 193 8.15 23.92 14.08 0.01 0.00 46.17 Baghdad 1,394 77.77 178.79 226.39 2.54 0.00 485.49 Diyala 38 0.81 4.70 6.91 0.00 0.00 12.42 Kirkuk 1,990 567.81 114.45 682.83 74.25 0.00 1,439.34 Nineveh 1,813 681.13 151.88 465.02 1.02 0.00 1,299.05 Salah Al-Din 2,382 227.60 274.27 1,327.87 130.41 11.28 1,971.42 Total 8,482 1,569.00 858.84 3,018.38 209.61 11.55 5,667.39 Source: Based on mapping of hotspots by MoE and Hatfield Consultants LLP 2022. Across all hotspots, 8,482 structures were found to be damaged or destroyed. Of the 20 industrial hotspots identified, nine were destroyed and abandoned. Remediation of these hotspots could help rehabilitate and operationalize industrial units and contribute to the local economy and jobs. 15 Conflict Pollution in Iraq Figure 9: Number of structures Figure 10: Land-use patterns 2,500 209.61 ha 11.55 ha Shrubbery/barren Water/wetland land 2,000 858.84 ha Built up 1,500 3,018.38 ha Vegetation 1,569.01 ha 1,000 Cropland 500 Source: Hotspots mapping by MoE and Hatfield Consultants LLP 2022. 0 r il d la uk h in ba b va da ya -D Ba rk An ne gh Di Al Ki Ni Ba Al ahl Sa Source: Hotspots mapping by MoE and Hatfield Consultants LLP 2022. 2.2.4 THE HEALTH, ECONOMIC, AGRICULTURE, AND LIVELIHOOD IMPACTS OF POLLUTION HOTSPOTS Three main valuation techniques are generally used to assess the health, economic, agriculture, and livelihoods (HEAL) impacts of pollution: • Change in production • Change in health © MoE and RSK LLC • Change in behavior. Building on the analysis of land-use pattern, a preliminary assessment was done to determine the magnitude and significance of the HEAL impacts. This involved estimating the following. • The burden of disease on directly and indirectly affected populations by considering changes in health (“dose-response function”). • The changes in economic productivity from loss of economic activity due to destroyed industries and agricultural land that was abandoned due to site and cropland contamination (“opportunity cost”). • The loss of livelihoods (jobs) due to decreased sectorial productivity and its effects on local economies. The assessment was limited in its accuracy due to lack of site- specific information and the analysis (for example, of the effects of contamination on ecosystem services including water bodies, vegetation, and so on) needed to calculate the real cost of environmental degradation. Land Remediation for Livelihoods Restoration 16 HEALTH IMPACTS: THE BURDEN OF DISEASE The hotspot sites in the seven governorates will cause an estimated value factor of US$5,048 per disability adjusted life year lost was three instances of mortality and 14 instances of morbidity every used. Based on these assumptions and the estimated number of year. These estimates are based on the Institute for Health Metrics people directly and indirectly affected (Figure 5), the burden of and Evaluation’s dose-response functions for Iraq17 and the direct disease is estimated to be approximately US$1.33 million per year and indirect effects of chemical- and oil-contaminated hotspots (at 2021 prices), with oil hotspot sites costing US$1.28 million and on populations in all seven governorates was assessed. Waste chemical contaminated sites costing US$50 000 (Table 6). These was not considered as no specific dose-response functions estimates are conservative because they are calculated without were available for this aspect. Clusters of diseases such as any site-specific and/or governorate-specific information on health cardio-pulmonary, cancer, metabolic, immune-endocrine, skin, and disease. Furthermore, as most of the hotspot sites have been psychological, and birth disorders were identified18 as relative active since 2003 or 2004, the cumulative burden of diseases over risks to derive specific dose response function. the past 20 years is likely to be much higher. A comprehensive health impact assessment on the prevalence of hotspot-related To estimate the monetary value of these risks, a mortality value diseases is hence needed to provide more exact information on factor (value of a statistical life) of US$416,971 and a morbidity the burden of disease. ECONOMIC IMPACTS: LOSS OF INDUSTRIAL PRODUCTION About 20 of the 69 hotspots assessed are industrial hotspots Al Anbar was used to calculate the cost of lost industrial production located in 20 industrial units, most of which were completely from four industrial hotspot sites. destroyed or are operating at low capacity. These hotspots included large fertilizer, chemical and engineering industries that made At 2021 prices, the cost of lost industrial production from important contribution to Iraq’s economy. (Other hotspots sites these four industries is estimated as follows: such as oil refineries and gas isolation stations that were damaged but are currently operating were not considered in this analysis.) • General Phosphate Company in Al Anbar: US$1.15 billion per year The loss of production from the destruction of these 20 • Two pharmaceutical industry hotspot sites: US$23.15 million industry sites is expected to have affected the local and per year national economy. However, no information on the production • One vegetable oil industry hotspot site: US$2.25 million capacity or annual turnover of these industries is available. per year. Available information including the average annual turnover of pharmaceutical industries (US$11.60 million per year), The total cost of lost industrial production for the four hotspot the average annual production capacity of vegetable oil sites (for which information on production capacity or turnover industries (1,200 tons per year), and the actual capacity of was available) is estimated to be US$1.17 billion. The cost could the General Phosphate Company (150,000 tons/year) in be much higher if a similar assessment is carried out for 16 other destroyed industrial hotspots. AGRICULTURE IMPACTS: LOSS OF AGRICULTURE YIELD Wheat was considered as a proxy for assessing the loss of A study by the World Food Programme in 2021 estimated Iraq’s crop yield on affected land for the following reasons: wheat yield to range between 3.3 and 20 tons per hectare per year.19 The same study found that the price of wheat ranged • It is the predominant crop in the northern, central, and between US$346.90 and US$462.50 per ton. Based on these southern governorates assumptions, the total cost of lost agriculture production for the • It requires one season for harvesting 1,569 hectares of agriculture land affected by contamination is estimated to be US$8.16 million per year, which is likely a • About 25 percent of the land is rainfed and 75 percent is irrigated conservative estimate as this estimate does not consider the in Iraq. supply chain disruption since 2022 or the cumulative loss of agriculture production since the hotspots were first polluted. 17 https://www.healthdata.org. 18 At chemical contamination sites, sulfuric acid was considered for lower-bound risk (relative risk for mortality of 0.0025 and relative risk for morbidity of 0.031 per 100,000 population) and carcinogens such as polycyclic aromatic hydrocarbons and lead were considered for upper-bound risks (relative risk for mortality of 0.42 and relative risk for morbidity of 1.31 per 100,000 population). For oil, polycyclic aromatic hydrocarbons were considered as a lower-bound risk (relative risk for mortality of 0.03 and relative risk for morbidity of 0.0073 per 100,000 population) and Lead as an upper-bound risk (relative risk for mortality of 8.63 and relative risk for morbidity of 49.19 per 100,000 population). 19 WFP 2021. LIVELIHOODS: LOSS OF AGRICULTURE AND INDUSTRIAL JOBS Information on employee numbers at each industrial hotspot site shows that about 31,201 jobs were lost due to the abandonment of these industries. And, based on values from the 2021 Iraq Labor Force Survey, an estimated 1,250 jobs may have been lost due to the pollution of agricultural land in the seven governorates.20 The net effect of lost jobs on local gross domestic product (GDP) is estimated at US$191.10 million per year for industrial jobs and US$7.66 million per year for agricultural jobs at 2021 prices. SUMMARY OF HEAL IMPACTS Pollution hotspots in the seven conflict-affected governorates have had a cumulative HEAL impacts of about US$1.45 billion per year. With a large fertilizer industrial hotspot (General Phosphate Company) and associated loss of industrial production, Al Anbar governorate, at US$1.17 billion per year is affected the most, followed by Baghdad, Salah Al-Din, and Kirkuk. If the high economic cost (US$1.15 billion) of General Phosphate Company is excluded (which is an outlier), the cost of HEAL impacts can be estimated at US$295.98 million per year. © Freepik Table 6: Health, economic, agriculture, and livelihood impacts of pollution hotspots (US$ millions) Impact cost (US$ million) Health Economic Agriculture Livelihood Governorate Grand total Chemical Oil Total Total Total Industry Agriculture Al Anbar 0.01 0.04 0.05 1,150.50 0.03 19.97 0.03 1,170.57 Babil 0.00 0.00 0.00 CNA* 0.04 0.49 0.04 0.57 Baghdad 0.02 0.02 0.04 CNA* 0.40 79.19 0.38 80.02 Diyala 0.00 0.00 0.00 CNA* 0.00 1.22 0.00 1.24 Kirkuk 0.00 0.24 0.24 CNA* 2.95 0.19 2.77 68.49 Nineveh 0.01 0.74 0.75 23.15 3.54 25.72 3.32 56.49 Salah Al-Din 0.01 0.24 0.25 2.25 1.18 64.31 1.11 69.10 Total 0.05 1.28 1.33 1,175.90 8.16 191.10 7.66 1,446.48 * Could not be assessed Source: Estimations by the ASA team. These estimates are indicative and intended to provide a broad understanding of the significance of HEAL impacts due to pollution hotspots. Section 5 of this report outlines a need for a more comprehensive and detailed site-specific assessment as part of the recommended roadmap for appropriate mitigation and management actions. 20 ILO 2022. Land Remediation for Livelihoods Restoration 18 2.3 Hotspots mapping and information management system Reviewing the data collected during initial site assessment, • Designing strategies for data organization, storage, and mapping hotspots based on this information, and developing management information systems are all critical steps for designing and • Developing maps for each hotspot developing management programs for contaminated sites. To assist the MoE on these aspects, the World Bank provided • Developing a WebGIS to collate the information and maps technical and capacity-building support focusing on the produced by MoE on hotspots in a system that can be managed following activities:21 and updated. • Assessing the nature, type, and form of environments In addition, the ASA supported the MoE in identifying software and hardware requirements for the maintenance, management • Collecting social and digital information during site assessment and updating of data, and provided customized training on • Reviewing data virtually for quality assurance and adapting data basic principles, tools, and techniques of mapping and updating requirements based on site assessments hotspots for eight MoE GIS team. 2.3.1 DATA FOR MAPPING AND INFORMATION MANAGEMENT Field data A standardized field data checklist (Appendix C) was developed Digital data to ensure consistency in data capture and to minimize note High-resolution maps and satellite images are essential for site taking errors during field assessment work. The field data assessment and sampling work. These resources provide not only checklist included basic details, such as location, nature, and accurate digital coordinates, but also geospatial datasets such type of pollution, as well as other complex information, like GPS as roads, streams, and other critical features related to the sites. coordinates of the sites, locations of soil and water sampling, The MoE team used Universal Traverse Mercator (UTM)—the sensitive environmental features, and affected structures. Digital standardized digital data format—and a standard GPS device for coordinates of photos, sketch maps, and other features were also digital data collection. Online resources such as Google Maps, collected by the assessment teams. Google Earth Pro, and OSM were also used. The World Bank ASA team helped to optimize the MoE’s data storage methodology by supporting in the design of a file folder structure and naming convention, standard operating procedures for storage and management of field and other ancillary data, and so on, so that the data can be updated as more is collected and more information becomes available. Secondary data Detailed maps of hotspots and the best available site-specific information helps with developing a Conceptual Site Model and carrying out Human Health Risk Assessments, which are important steps towards developing appropriate management and mitigation measures for hotspots. To support this process, datasets such as Microsoft Building Footprints on Bing Maps (for assessing affected populations); the Copernicus Digital Elevation Model (DEM) and OSM (for understanding site drainage and transport of contaminants); and the ESA’s WorldCover 10m 2020 (to identify farming adjacent to sites) were identified (Table 7). These data sets were accessed © Freepik through Maxar and Skywatch, incorporated into Very High Resolution (VHR) images, and used to develop base maps and 21 MoE and Hatfield Consultants LLP 2022. Conceptual Site Models of the sites. 19 Conflict Pollution in Iraq Table 7: Data sets for mapping hotspot sites Data set Source and description Population density Microsoft Building Footprints • Detects buildings using deep neutral networks and RessNet34 with RefineNet algorithm applied to Bing Maps. • Provides an estimate of the size of population potentially found within a defined distance from the pollution sources, thereby providing an indirect means of assessing potential receptors. Site drainage and water supply Copernicus Digital Elevation Model • A model that presents the surface of the earth which, together with ArcMap tool, can be used to estimate water-flow accumulation and identify the presence of drainage channels. Stream network from OpenStreetMap • Complements above drainage analysis by providing data on major streams and river channels. Agriculture and vegetation ESA WorldCover 10m 2020 • Global land cover product based on Sentinel-1 and -2 data. • Used to quickly assess critical land use such as cropland, built-up areas, and their potential exposure due to the pollution hotspot. Source: Compiled by the ASA team. 2.3.2 MAPPING OF HOTSPOTS Using the data sets summarized in Table 7, the MoE and technical In addition to the base maps, the following key statistics support consultant developed detailed base maps for each (elaborated in Section 2.2.3 and summarized in Table 5) contaminated site/hotspot comprising common map template relating to each site were also generated from the maps design; a VHR image; an image map generation (in A3 PDF through GIS analysis: format); an overlay of existing vector data on maps (for example, OSM such as roads, building footprints); and integration of • Buildings per site as an indicator of human settlement/activity historical imagery from a period before the damage or conflict at the site and potential receptors (derived from the building impacts (based on availability of images). footprint data). Receptors are those entities—people, an ecological system, property, or a water body—that could be In addition, the following outputs were produced. adversely affected by contamination. • An overview map at the country and governorate level showing • Area of cropland per site as an indicator of human farming all hotspots (Figure 4) activity and potential exposure pathways (derived from ESA WorldCover 10m 2020 data). • A “Sites Map Book” presenting all hotspots with land cover/land use, developed through analyzing ESA WorldCover 10m 2020 • Built up area per site as an indicator of human settlement/ data and integrating building footprints and site drainage derived activity at the site and potential receptors (derived from ESA from Copernicus DEM (for example, Figure 11) WorldCover 10m 2020 data). • A “Sites Map Book” presenting all hotspots developed through • Areas of vegetations, shrubs, and water bodies at each site satellite imagery analysis with building footprint and drainage as an indicator of other land use features (derived from ESA layers (for example, Figure 12). WorldCover 10m 2020 data). Land Remediation for Livelihoods Restoration 20 These statistics provide important information on risks associated with contamination at hotspots and were used in estimating HEAL impacts and carrying out risk assessment of hotspots sites. However, these statistics are only indicative, as they are generated through visual interpretation of satellite imagery (using ESA WorldCover 10m 2020 data). Such automated land-use classifications in arid/semi- arid environments such as Iraq are always challenging. 2.3.3 WEBGIS: A WEB-BASED, GIS-ENABLED INFORMATION SYSTEM Information management systems are key for any contaminated To improve the user experience, the WebGIS included the sites management program. They help in designing appropriate following navigational features: remediation actions and facilitate continuous data monitoring • An option to zoom into a site for a clearer view and updating when additional information becomes available. Considering this, a WebGIS was developed for pollution hotspots • An option to zoom into a governorate to provide an overview of in Iraq that uses the information collected during site assessment hotspots in the governorate exercise and further analyses. • The ability to turn desired information layers on or off. These layers include, for example, basic information, water sampling WebGIS includes basic information of hotspots such as site locations, and soil sampling locations identification number, site name, name of the governorate it • A pop-up box that displays attributes logged into the system is located, boundary, location, and coordinates of sampling (for example, facility status and the maximum exceedance value locations (both soil and water), sample ID, and risk rating of the of water and soil samples analyzed) (Figure 13). site presented as a triangle symbol. The application includes a feature to update relevant data. Figure 11: Typical detailed map of hotspot with land cover—Ibn Sina Company Source: MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. 21 Conflict Pollution in Iraq Figure 12: Typical detailed map of hotspot without land cover—the chemical contaminated site in Nineveh governorate (NIN 015) Source: MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. Figure 13: Typical WebGIS view of hotspots at site level—Al Shahid Company, Al Anbar Source: MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. Land Remediation for Livelihoods Restoration 22 2.4 Assessment of risks and prioritization of hotspots for remediation 2.4.1 RISK ASSESSMENT METHODS Risk assessments determine the health and environmental The methods assessed all broadly follow the Source-Pathway- risks posed by pollution hotspots to help prioritize sites for Receptor concept in assessing the risks.22 However, the United further detailed site investigations and develop management or States Department of Defense and the United Kingdom Land remediation plans. Considering the level of data available and Contamination Risk Management systems classify the sites MoE’s capacity limitations, this method needs to be simple yet in terms of high, medium, and low categories, whereas the robust, and based on the contaminants and their concentrations United States Environmental Protection Agency (US EPA) and at each site. the Canadian system assign scores to sites for prioritization. Alternatively, the Netherlands uses country-specific DIV standards A quick review of international risk assessment practices was to calculate expected concentrations and exposure. carried out to choose an appropriate risk assessment method for Iraq (Box 1). The five methods reviewed systematically classify After carefully considering all the above international approaches contaminated sites according to their current or potential adverse and the data/information available for the hotspots in Iraq, the MoE impacts on human health and the environment. The methods are not chose the United Kingdom Land Contamination Risk Management designed to provide a quantitative risk assessment, but to screen method due to its flexibility in categorizing sites rather than scoring and prioritize sites for further actions that could involve detailed and ranking them. This method is qualitative and does not require investigation, characterization, risk assessment, or remediation. any calculations or comparisons with standards, which is important since Iraq does not have standards for soil contamination or pollution. © Freepik 22 “Source-Pathway-Receptor” is a concept that is followed in assessing pollution risks in which (1) the source of pollution is identified, (2) a pathway for the movement of pollution exists, and (3) the environment/ecological element/ life that may be affected (receptor) by the pollution is established. A risk is considered present only if there is a link between all three elements. 23 Conflict Pollution in Iraq BOX 1: OVERVIEW OF RISK ASSESSMENT APPROACHES United Kingdom Land Contamination Risk Management System • A qualitative model that uses an outline Conceptual Site Model for the risk assessment. • Defines risk as a combination of the likelihood of an event and the consequence of its occurrence. • Categorizes likelihood as highly likely, likely, low likelihood, or unlikely. • Categorizes consequence of an event as severe, medium, mild, or minor. • Categorizes risks as very high, high, moderate, low, or very low. United States Department of Defense relative risk site evaluation • Uses site information to evaluate exposure endpoints of groundwater, surface water, sediments, and surface soils. • Rates relative risks as high, medium, or low by evaluating three risk factors: containment hazard, migration pathway, and receptor factor. • The highest relative risk determines the overall relative risk. United States Environmental Protection Agency Hazard Ranking System • Assesses relative importance of sites for inclusion into National Priorities list. • Evaluates four pathways of pollution: ground water migration, surface water migration, soil exposure and subsurface intrusion, and air migration. • Calculates scores for risk-related factors based on site conditions. • Groups risk-related factors into three categories: likelihood of pollutants released into the environment, characteristics of pollution, and people/sensitive environments affected by pollutants. • Normalizes category values to 100. Sites with an overall score of 28.5 and above are included in the National Priorities list. Canada National Classification System for Contaminated Sites • Used to establish a rational and consistent basis for a comparative assessment of sites. • Uses an additive numerical method to assign scores to sites. • Considers site characteristics such as contaminant characteristics, migration potential and exposure, and site hazards. These are scored between zero and 100 based on severity. • Site characteristic scores are categorized into five classes: › Class 1: > 70 (highest priority) › Class 2: 50–69.9 › Class 3: 37–49.9 › Class N: <37 (lowest priority) › Class INS: Insufficient information. The Netherlands’ remediation urgency method • A framework used to define remediation urgency for sites affected by serious soil contamination. • If site contamination exceeds the Dutch Intervention Values, the expected exposure is assessed against human-toxicological intervention values and ecological risks. • Contaminant concentrations in soils are used to calculate expected concentrations in contact media (and thus exposure). • Sites are prioritized accordingly for remediation. 2.4.2 RISK ASSESSMENT The risk assessment was conducted in accordance with the • Pathway: A route or means by which a receptor is (or could be) technical approach presented in the United Kingdom Land exposed to or affected by a contaminant. Contamination Risk Management method for Tier 1 preliminary • Contaminant source: A hazard that poses a risk to receptor risk assessment. where a pathway is present. The assessment involved desk-based analysis of risks based The relationships between sources, pathways, and receptors on the data available from the initial site assessment carried out collectively combine to create a Conceptual Site Model. A risk can by MoE team to meet the objectives of a preliminary (Phase 1 only be considered present where a contaminant source, pathway Assessment) investigation of contaminated sites. As noted earlier, and receptor are all in place, referred to as a “pollutant linkage”. the objective of this assessment was to provide an understanding of the risks associated with the hotspots and prioritize sites for the In line with the above definitions and the British Standard detailed assessment (Phase 2 Assessment) and the preparation 10175:2011+A2:2017 on Investigation of Potentially Contaminated of remediation plans. Sites Code of Practice, contaminant sources (hazards), receptors that may be impacted, and plausible linking pathways were Key terms used in the risk assessment included: identified for each of the suspected hotspots. Where all three • Vicinity: The area within a 250-meter (m) radius of the site.23 elements were present, a contaminant linkage was assumed, and a qualitative risk estimation was made. The risk classification was • Receptor: Physical, environmental, ecological, or human based on a combination of hazard consequence and probability beings that could be adversely affected by contamination. using the risk matrix from Rudland et al (2001).24 2.4.3 RISK RATINGS AND PRIORITIZATION The risk assessment identified five hotspots as “very high risk” Abdulla Station [KIR 26], and Baiji Refinery [SAL 9 C]), while only and 18 hotspots as “high risk”. Furthermore, 24 sites were rated one site (Al Fatha [SAL 15 H]) is abandoned. Similarly, all “high as “moderate” risk, 16 sites as “moderate/low” risk, and five sites risk” sites except Baghdad Lead Extraction Facility (BAG 08) are as “low” risk (Table 8). A more detailed risk assessment of each operational. The workers at these operational sites are likely to be/ site is presented in Appendix F. have been exposed to harmful contaminants. An urgent interim response may hence be needed for all operational sites to mitigate Four of the five “very high risk” sites are currently in operation exposure risk until full remediation and management actions (Alkask Refinery [NIN 10], Al-Furat Company [BAB01], Mulla are initiated. © Freepik 23 Certain sources and/or sensitive features farther than 250 meters have also been considered. The purpose is to identify and assess the potential risks and liabilities associated with ground contamination both on and in the vicinity of the sites. 24 Rudland DJ, Lancefield RM, and Mayell PN. 2001. Contaminated Land Risk Assessment: A Guide to Good Practice: C552. London: CIRIA. Table 8: Summary risk ratings and prioritization of hotspots Risk rating Remarks Very high (5 sites) Al-Furat Company (BAB 01), Mulla Abdulla Station (KIR 26), There is a high probability that severe harm could occur or Alkask Refinery (NIN 10), Baiji Refinery (SAL 9 C), Al Fatha that severe harm is currently happening. If realized, this risk (SAL 15 H). could result in substantial liability. Urgent investigation and remediation are needed. High (18 sites) Baghdad Lead Extraction Facility (BAG 08), Bai Hassan North Harm is likely to occur and realization of the risk is likely to Degassing Station (KIR 7, 8, 9, 10, 12, 13), Sarolo Station (KIR present a substantial liability. Urgent investigation is required. 02), Baba Gurgur Station (KIR 14), Bai Hassan South Oilfield (KIR 15, 17, 23), Qutan Gas Isolation Station- Babakkar Oilfield Remedial works may be necessary in the short term and are (KIR 28), Gas & Oil Separation Plant in Jabal Bur (KIR 30), likely over the long term. Al-Qayyarah (NIN 3, 4), General Company for Communication Equipment and Power (SAL 014 C), Al Sahl Valley (SAL 16 H). Moderate (24 sites) Haditha Oil Refinery (ANB 4), Ibn Sina Company (BAG 1), Diyala Harm could occur, but it would likely be relatively moderate. Electrical Industries Company (DIY 01), Sarolo Station (KIR 01, Investigations are normally required to clarify the risk and 04, 05), Sarolo Station (KIR 03), Dawood Station for Oil Refining determine the liability. (KIR 06), Serbach Station (KIR 16), Haljira Gas Isolation Station (KIR 18, 20), Al-Qayyarah (NIN 1), Al-Qayyarah (NIN 5, 17), Ein Some remedial works may be required in the longer term. Zalah Station (NIN 8, 9), Chemical Contaminated Sites (NIN 15), Ajil Oil Field (SAL 001 H, 011 H, 012), Alass Oil Field (SAL 2 H), Northern Fertilizers Company (SAL 003 H), AL Mansour Factories for Vegetable Oils (SAL 004 H), Al Seenia Oil Refinery (SAL 007 H). Moderate/low (16 sites) Pesticides Factory Al-Falluja City (ANB 05), Al Shahid Comp. Harm could occur at these sites, but it would likely be (ANB 06), Bader Company (BAG 02), That Alsawary Comp. moderate to mild. (BAG 03), Ibn Al Waleed (BAG 04), Al Harith Factory (BAG 06), Baba Gurgur Stn (KIR 19), Hawija Pesticides (KIR 25), Investigations may be conducted to clarify the risks and Khabaz Gas Station (KIR 31), Al-Qayyarah (NIN 18), Chemical determine the liability. Contaminated Sites (NIN 11), Nineveh Pharmaceutical Industrial Company (NIN 14), Al Kindy General Company (NIN 16), Baiji Power Plant (SAL 5 H), Salah Al-Din (SAL 006 H), Salah Al-Din (SAL 010 IC). Low (5 sites) State Company for Phosphate in Al-Qaaim (ANB 01), Alamer Harm could occur but it would, at worst, likely be mild. Factory (ANB 03), Showraw Station & Kat Factory (KIR 24), Alhukamaa Pharmaceutical Company (NIN_12), K2 Station (SAL 013). Source: Based on site assessment by MoE and RSK Environment LLC 2022. Land Remediation for Livelihoods Restoration 26 2.5 Stakeholder engagement and consultations Stakeholder input is crucial for determining the nature and significance of HEAL impacts that pollution hotspots have on local communities and to identify objectives for the management or remediation of contaminated sites. The MoE therefore ensured continuous stakeholder engagement after the initial screening of hotspots. This involved interacting with local people to identify suspected hotspots and conducting on-site assessments and verification regarding the extent of pollution and its impacts on people and the surrounding affected areas.25 After compiling an inventory of suspected hotspots and completing the initial site and risk assessments, the MoE organized formal stakeholder consultations both at the governorate level and at the national level in Baghdad. The objective of these consultations was to seek input from stakeholders on the appropriateness of hotspot sites, the area of impact identified, and the people affected, and to share the results of the site and risk assessments. To ensure adequate and active participation, stakeholders were comprehensively mapped by identifying all relevant public, private, civil society, community-based organizations, and other grassroot organizations operating in the seven conflict-affected governorates. A governorate-level summary of information on suspected hotspots, identified levels of contamination, anticipated impacts around sites, and key discussion points for consultations was prepared. Separate consultations were organized for government entities and for Civil Society Organizations (CSOs) to address the interests of each stakeholder group. The location © RSK LLC of these consultations considered the total number of hotspots in each governorate, their geographical linkages, and security and access issues. The chosen locations Government stakeholder consultations were Kirkuk (covering the governorates of Kirkuk, Nineveh, and Salah Al-Din) and in Kirkuk. Baghdad (covering the governorates of Baghdad, Babil, Diyala, and Al Anbar). 2.5.1 SUMMARY OF CONSULTATIONS In total, four consultations were held on March 12 and 19, 2023: one each in Kirkuk and Baghdad, one for government stakeholders, and one for CSOs. A total of 64 people (42 government officials and 22 CSO representatives) participated in these consultations. The consultations were designed to facilitate active participation and deliberation from all stakeholders. Overall, the participants agreed with the MoE’s inventory and assessment work. The discussions further strengthened the case for the remediation of hotspots and highlighted the concerns of health, environment, agricultural productivity, water contamination, and impacts on animals around certain hotspots sites. The participants also made specific suggestions relating to the risk ratings assigned to the sites and suggested additional hotspots to be included in the inventory. © RSK LLC The CSOs indicated that, while local communities were conceptually aware of the risks from contaminated sites, they were often not fully aware of specific health and CSO consultations in Kirkuk. safety issues. They also lacked an official platform to express their concerns and find resolutions. It was therefore suggested that the MoE establish a stakeholder platform for pollution hotspots for continuous dialogue between government agencies and CSOs. CSOs volunteered to assist in communication and awareness programs on behalf of the government. 25 MoE and RSK Environment LLC 2023. 27 Conflict Pollution in Iraq Table 9: Summary of issues discussed during stakeholder consultations Government stakeholders CSO stakeholders Impacts and issues faced • Direct impacts on agriculture and animal husbandry activities • Impacts experienced on plants, birds, and animals due to due to contamination hotspots in Baghdad governorate. hotspots in the Baghdad governorate. • Health impacts (including cancer cases) reported in • Health impacts on children, women, and the elderly in Baghdad governorate. hotspot areas in Baghdad governorate. • Expansion plans of some of the industries with hotspots • Health problems like congenital malformations in fetuses need to consider the existing environmental and and other chronic diseases are also experienced. expansion-related issues. • Education and awareness programs on the health and environmental impacts of contamination at hotspots are needed. • Stakeholder platforms need to be established for better coordination and engagement on hotspots. Risk rating of hotspot sites • Risk rating for Al Sahl Valley in Salah Al Din (SAL1) be Risk rating for Ibn Sina Factory in Baghdad (BAG 1) to be changed from “high” to “very high”. changed from “moderate” to “high”. • Risk rating for Bai Hasan North Degassing Station in Kirkuk (KIR 7–10 and 12/13) to be changed from “high” to “very high”. • Risk rating for Al Qayyarah in Nineveh (NIN 3, 4) to be changed from “high” to “very high”. • Risk rating for Ibn Sina Factory in Baghdad (BAG 1) be changed from “moderate” to “high”. Additional hotspots • Al Dawani landfill and Hadith hospital in Al Anbar. • Al Rafid irrigation canal, Abo Garib, Baghdad. • Al Nasir, Al Somod and missile factory in Tarmiya and Abo • Al Harish, Al Somod factory, Tarmiya, Baghdad. Garib sites in Baghdad. • Hotspots, Hadith Rawa, All Fallouja, Al Anbar. • Khazna Bar, Yai ji, Southern Bai Hasan, Al Dibis and Kat Oil • Ajeel and Alaas oil fields and Asphalt factory, Al Alam in Company in Kirkuk. Salah Al Din. • Medicine Factory, Nineveh. • Mekanian Area, Erbil Road, Kirkuk. Source: Based on stakeholder consultations by MoE and RSK Environment LLC 2023. Land Remediation for Livelihoods Restoration 28 2.6 Conclusion An overall review of pollution hotspots in Iraq indicated widespread hydrocarbon and chemical contamination in the country. Of the 76 “suspected hotspots” identified, the MoE conducted field assessment of 69 sites in 47 locations. The assessments suggested that about 1,333.03 ha of land is likely to have been contaminated, directly affecting an estimated 55,050 people and indirectly affecting more than 1.7 million people. Most of the pollution hotspots were found to be in the three governorates of Kirkuk, Nineveh, and Salah Al-Din. Environmental analyses of the soil and water at these sites indicated that contamination levels exceeded 100 times the DIV in 32 sites, 50 times the DIV in seven sites, and 10 times the DIV in the remaining 30 sites. In terms of the affected population, Kirkuk has an estimated 1.1 million affected people, which is the highest count of all seven governorates. Nine major industries were destroyed and are currently not in operation. This indicates the level of environmental and health challenges posed by these hotspots and the potential gains due to their management or remediation. The site assessment further indicated that over 1,569 ha of agriculture land, 3,018.38 ha of vegetation, and 8,482 structures are impacted by damage and contamination at pollution hotspots. To better understand the HEAL impacts of pollution hotspots, the burden of diseases, the economic cost of destroyed industries, the opportunity cost of affected agriculture land, and the loss of livelihoods due to destroyed industrial and agricultural land were analyzed. The total cost of HEAL impacts at the suspected hotspots was estimated at about US$1.44 billion per year. Furthermore, a risk assessment identified five sites as “very high risk”, 18 sites as “high risk”, 24 sites as “moderate risk”, 16 sites as “moderate/low risk”, and five sites as “low risk”. Stakeholder consultations carried out as part of the assessment confirmed the ramifications of these risks for local communities around pollution hotspots and emphasized the urgent need for remediation and management programs. The remainder of this report explores technological options for hotspot remediation and discusses a proposed roadmap for the development of a pollution hotspot management program for Iraq.   © Freepik 26 https://www.epa.gov/superfund/superfund-history. 29 Conflict Pollution in Iraq 3 Policy and Institutional Framework for the Management of Hotspots 3.1 Introduction Sound management of contaminated sites/hotspots primarily relies on three pillars: policy and institutional framework; planning and development of management and remediation plans; and program design and financing. There is a wealth of experience in United States, Europe, Canada, Australia, China, and many other countries on contaminated sites management. This section briefly reviews some of these international examples as well as the current policy and institutional framework in Iraq on contaminated sites management. Subsequent sections of this report discuss the remaining two pillars in the context of managing environmental hotspots in Iraq. © Freepik 3.2 Review of international practices 3.2.1 THE UNITED STATES SUPERFUND PROGRAM Legal framework Contaminated sites management in the United States (US) is The law includes clear provisions to respond to the situations governed by the Comprehensive Environmental Response, of contaminated sites (both orphan and non-orphan sites), to Compensation, and Liability Act of 1980, generally referred to fix liabilities for cleanup actions, and to access private lands for as the Superfund Program, and its amendment, the Superfund investigations and cleanup. Both acts are also complemented Amendments and Reauthorization Act of 1986. Both acts by other federal laws of the USA, including the Resource authorize the US EPA to respond to actual or threatened releases Conservation and Recovery Act, Clean Water Act, and Toxic of hazardous substances. Substances Control Act.26 Figure 14: Process of contaminated site management in Superfund program Site assessment/ National inspection Priorities List Remedial Remedial design & Selection of investigation & remedial action remedial action feasibility study Construction Post-construction Deletion Site reuse/ completion operation and from National redevelopment maintenance Priorities List Source: Compiled by the ASA team. Process The Superfund program (Figure 14) involves carrying out series of actions comprising an initial assessment of reported sites to evaluate the need for action, followed by inclusion of sites in the National Priorities List (NPL). Detailed investigations and feasibility studies are then done to determine the nature and extent of contamination at the site and the costs of various remediation options, which are submitted for approval by the National Remedy Review Board. Upon approval, a remediation action is designed and implemented (referred to as “construction”), after which the long-term response actions and operation and maintenance of the site is carried out. When the remediation objectives are achieved, the site is removed from the National Priorities List and site reuse/redevelopment activities (if any) may commence. Soil screening guidance The EPA’s Soil Screening Guidance presents a framework for developing risk-based soil screening levels to help with the evaluation of contaminated sites and to facilitate decisions on cleanup actions through the Superfund program. These soil screening levels are not cleanup standards, but are guiding factors for identifying and defining areas, contaminants, and conditions at a particular site that do or do not require action. At sites where contaminant concentrations exceed soil screening levels, further action or investigations may be required, but cleanup is not necessarily warranted. 26 https://www.epa.gov/superfund/superfund-history. 31 Conflict Pollution in Iraq Institutional framework The US EPA is the lead agency for the implementation of the Superfund program, which it manages through the Office of Superfund Remediation and Technology Innovation. This office is supported by six other offices within EPA, two regional offices, three federal agencies, and six state agencies. Financing mechanisms The central theme for financing the Superfund program is the “Polluter Pays” Principle. Following this principle, the program assigns liability for cleanup-related costs to the landowners, disposal operators, transporters, or generators of hazardous waste associated with contaminated sites. This principle is supported by strong legal and administrative power and aids in the program’s success to recover up to three times the damages from the “polluters” for cleanup actions. Otherwise, the federal government provides the US EPA with funding to clean sites where no responsible parties are found. 3.2.2 CONTAMINATED SITES ACTION PLAN OF CANADA Legal framework Canada’s Federal Contaminated Sites Action Plan (FCSAP) is the Canadian Environment Protection Act, the Fisheries Act, based on the principles of prevention, remediation-reclamation, and the Canadian Environmental Assessment Act. These acts the “polluter pays”, and fairness. It includes provisions that are supported by the Soil Protection and Contaminated Sites make landowners liable for the rehabilitation and remediation Rehabilitation Policy. In 2007, Canada also adopted the Canadian of contaminated sites, authorize access to sites to perform Soil Quality Guidelines for the Protection of Environmental and necessary investigations, and require landowners to perform Human Health. These guidelines prescribe specific standards for site characterization studies before changing the land use of any the presence of various chemical substances in soil for agriculture, site. It is governed by several policies and legislation, including residential, commercial, and industrial uses. Process The FCSAP’s approach to contaminated sites management Step five consists of detailed testing to delineate the boundaries follows risk-based criteria involving a 10-step process of contaminants, define site conditions in detail, and provide (Figure 15). These steps involve identifying potentially the information necessary for risk assessment and to develop contaminated sites based on past or current activities (step remediation plans, after which sites may be reclassified one); reviewing historical information related to the site (step (step six). Detailed remediation and risk management strategies two); and initial testing to understand the characteristics of are then prepared (step seven), followed by their implementation contamination and conditions at the sites (step three). Depending (step eight). Confirmatory sampling and final reporting are on the outcome of these tests, the sites are classified as per the carried out (step nine) subsequently and long-term monitoring is National Classification System for Contaminated Sites (step conducted as required (step 10). four). Site classification involves scoring sites based on analyses of the contaminations’ characteristics, exposure pathways, and receptors. Depending on the scores, the sites are classified as: • Class 1: Action required. • Class 2: Action likely required. • Class 3: Action may be required. • Class N: Action not likely required. • Class I: Insufficient information. © Freepik Land Remediation for Livelihoods Restoration 32 Figure 15: The Federal Contaminated Sites Action Plan’s 10-step process in Canada STEP 1 STEP 2 Identify suspect site Historical review STEP 3 STEP 4 Initial testing program Classify site STEP 5 STEP 6 Detailed testing program Reclassify site STEP 7 Develop remediation/risk management strategy STEP 8 Implement remediation/risk management strategy STEP 9 STEP 10 Confirmatory sampling Long-term monitoring and final report NOTE: The steps shown above illustrate the complete process involved in dealing with contaminated sites. There will be instances where some of the steps may not be required. Source: Compiled by the ASA team. Institutional framework The FCSAP is implemented by Environment and Climate Change Canada, the state department responsible for coordinating environmental policies and programs, with participation from relevant federal departments, agencies, and Crown Corporations (state-owned entities that are also referred as Custodians in this context). Initially, only sites contaminated prior to April 1, 1998, were eligible for funding under the program. Phase IV of the program (2020–2024) introduced eligibility for certain sites after 1998. As of July 2022, 23,954 sites have been listed under the program, and 17,602 have been closed. About 20,700 jobs (person-years of employment) were reportedly created or maintained through FCSAP. Financing mechanisms FCSAP was established in 2005 as a 15-year program with US$4.54 billion funding from the Government of Canada. The program was renewed for another 15 years (2020–34) in 2019, with US$1.16 billion allocated for the period 2020–24.27 27 https://www.canada.ca/en/environment-climate-change/services/federal-contaminated-sites.html. © Freepik 33 Conflict Pollution in Iraq 3.2.3 CONTAMINATED LAND MANAGEMENT IN THE UNITED KINGDOM Legal framework Contaminated land management in the United Kingdom (UK) The other important features of this statutory regime are: is governed by Part 2A of the Environment Protection Act of 1990 and statutory guidance issued by the Department for • Local authorities are responsible for managing contaminated Environment, Food, and Rural Areas. The guidance explains land. how local authorities should implement the legal regime for • Risk-based identification of sites and management or contaminated land management, especially with regard to remediation using the source-pathway-receptor concept and identifying contaminated land, setting the goals for remediation, soil guidance values are employed. liability arrangements, and recovering costs. However, the • The “suitable to use” principle for remediation is adopted. statutory requirements of Part 2A of Environment Protection Act • The requirement to include land remediation as an obligatory and guidance are only applicable when no appropriate solutions consideration under remits such as land development or are available under the planning regimes for land development redevelopment, environmental permitting, and so on. or regimes for water, wastewater, environmental permitting, and Environment Damage Regulations.28 • Financial and legislative incentives for remediation and redevelopment are provided. The Part 2A regime emphasizes risk management and introduces • Liability is placed on the original polluter, current landowner, risk-based definitions of contaminated land. Only those sites or occupier. that are causing (or are likely to cause) unacceptable risks are considered for an appropriate response or remediation. The Part 2A regime requires proactive land management to address risks. By contrast, the planning regime is reactive in its risk management, only requiring assurance that the development or redevelopment of a site is safe. Process The process of contaminated site management as set out by the statutory guidance described above primarily involves the following sequential steps, with the outcomes of each step deciding whether the next is required or not: Regular inspection by local authorities to identify potentially contaminated land. These inspections must use a strategic 1 approach relevant to the local circumstances. Detailed inspection of identified sites aims to collect sufficient information and conduct qualitative risk assessment to 2 identify whether the site is contaminated. 3 Detailed risk assessment using a Conceptual Site Model of sites is carried out. Based on the risk assessment, a determination of contaminated land may be indicated. 4 Determination of contaminated land is conducted as per the four possible grounds defined by the Part 2A regime.29 5 Initiation of remediation by the enforcing authority, including the issuing of a remediation notice to the owner. 6 Liability assignment and cost recovery once the remediation techniques and costs are identified. https://www.canada.ca/en/environment-climate-change/services/federal-contaminated-sites.html 27 CL:AIRE 28 2010. . 28 29 CL:AIRE 2010. are: significant harm is being caused to human or relevant non-human receptor; there is a These grounds 29 These grounds significant are: possibility harm being significant harm of significant is being caused caused to a humanor tohuman orrelevant non-humanreceptor; relevantnon-human there is a significant receptor;significant possibility of significant harm being caused pollutionto of human or waters acontrolled relevant isnon-human receptor; being caused; significant or there pollution is a significant of controlled possibility waters is of significant being caused; pollution or there is of controlled a significant possibility of significant pollution waters caused. waters being caused. of controlled being Land Remediation for Livelihoods Restoration 34 Institutional framework Multiple agencies are responsible for managing contaminated land in the UK. While the Department for Environment, Food, and Rural Affairs and the Ministry of Housing, Communities, and Local Government are responsible for leading policy and statutory guidance, the Environment Agency is responsible for managing contamination at special sites, permitting remediation processes, and handling enforcement. As per the Part 2A regime, local authorities are responsible for contaminated site designation and planning controls, while HM Revenue & Customs Department is responsible for taxes on landfilled material. Financing mechanisms Under the Part 2A regime, all costs relating to identifying and managing contaminated land are the responsibility of local authorities and no funding is provided by the central government. The cost of remediation is assigned to the landowner or responsible party wherever liability for contamination is established. However, central funding is provided to special sites that are managed by the Environment Agency. In the case of sites under the planning regime, costs of remediation and management are assigned to the respective landowner or responsible persons or agencies. The central government does provide some tax relief on the cost of remediating brownfield sites. 3.2.4 CONTAMINATED SITES MANAGEMENT IN THE NETHERLANDS Legal framework The Netherlands, one of the first countries to focus on the environment and allowing for the reuse of contaminated soil contaminated land management, approved its Interim Soil for limited purposes. These acts and standards provide the basis Remediation Act and Soil Quality Standards in 1983, followed by for contaminated site management in the country. In addition, the Soil Protection Act in 1987. The Soil Protection Act establishes the National Environmental Policy of 2001 and Environment accountability of parties and their liability for soil contamination. Management Act of 2004 provide an overarching legal framework In 1994, the Soil and Groundwater Quality Standards and for Contaminated Sites Management in the Netherlands. In 2006, approaches for identifying the need for soil remediation were the Spatial Planning Act was amended to introduce liability of issued. After subsequent evaluations, the Soil Quality Decree of site remediation for land developers as per the land use plan of 2008 was issued, which balances protecting human health and the area. Process Contaminated land management in the Netherlands is primarily driven by the Soil Quality Standards, which introduced the concept of A-, B-, and C-values. Concentrations below the A-value means that there is no soil contamination, and no remediation is needed. B-value soil may be seriously polluted and requires further investigation. C-value soil requires remediation. In subsequent revisions of the Soil Quality Standards, the concept of a “target value” and an “intervention value” was introduced. While soil meeting the target value is not contaminated, soil that meets the “intervention value” requires remediation (Figure 16). The issuance of the Soil Quality Decree in 2008, subsequent updates to the framework for the assessment of historically contaminated sites, and revisions of soil quality standards have introduced standards for the use of soil for specific functions. © Freepik Figure 16: Contaminated sites management framework in the Netherlands No further Sustainable soil Determination of action management urgency of remediation Total soil concentration 0 Background Value/Target Value*1 Intervention Value (Slightly) Seriously Clean contaminated contaminated Source: Swartjes et al. 2012. 35 Conflict Pollution in Iraq Institutional framework As in the UK, the responsibility for remediating contaminated sites in the Netherlands rests with local provinces and authorities, whereas the central government and ministries of environment and housing are responsible for developing policy and regulatory framework. The Ministry of Economic Affairs and Climate Policy plays an overarching role in policy formulation and financial aspects. Financing mechanisms Contaminated site management in the Netherlands is financed by a combination of payment from polluters, interested parties, government funds, and annual budget allocations. The “Polluter Pays” Principle is primarily applied for the remediation of sites. Interested parties (land developers) and other stakeholders may also finance the cost of remediation. If the responsible party or polluter is insolvent, the sites are remediated with government funding in the form of an advance, which must be recovered in due course. The costs of cleanup for orphan sites are borne by the government. 3.2.5 LAND REMEDIATION MANAGEMENT IN SOUTH AFRICA Legal framework South Africa recently enhanced its management of contaminated (including determining the land’s contamination status) and land and implemented several regulatory and institutional actions. provide the legal basis for soil screening values, which is needed While the Environment Conservation Act (Act 73 of 1989) included to protect human and ecological health while considering some provisions for the regulation of contaminated land, it required existing or proposed land uses. These regulations also specify a specific provisions related to soil contamination and standards to participatory and consultative approach with key stakeholders— effectively address this critical issue. The subsequent National including various government entities and communities—for the Environment Management Act (Act 107 of 1998) and the Waste management of contaminated sites and stipulate penal provisions Act (Act 59 of 2008) addressed pollution and waste management for non-compliance (such as significant fines or prison terms). Part in the country. However, Part 8 of the Waste Act on contaminated 8 of the Waste Act of 2008 is applicable even in cases where the land only came into effect in 2014, after the “National Norms contamination occurred before the act commenced, or in cases and Standards for the Remediation of Contaminated Land where contamination arose (or is likely to arise) at a different time and Soil Quality” were promulgated. These standards provide from the attributing event or activity. a unified national approach to managing contaminated sites Process As a first step, an “investigation area” is notified by the Minister of Forestry, Fisheries and the Environment or a relevant Member of Executive Council (MEC) of the province where high-risk activities have taken or are taking place. It is also obligatory for the landowner or person whose activity is suspected to have caused significant land contamination to notify the minister of any significant land contamination. After this notification, two rounds of consultations shall be carried out with Cabinet members and MECs, followed by notification in the Government Gazette. In the next step, after consulting with other relevant ministers, the minister or relevant MEC notifies the owner of the land to obtain an independent expert assessment of the site that provides details of contamination, its impacts, exposure pathways, exceedance of applicable standards, and measures to remediate or manage risks. Based on the recommendations of the independent assessment report, the minister then issues a remediation or monitoring and management order, as appropriate. This order also establishes liability for implementing remediation or monitoring actions, which may be allocated to the landowner or any other responsible party. The Department of Forestry, Fisheries and the Environment maintains a Contaminated Land Register with comprehensive information on investigation areas; the status of remediation; and land use restrictions, if any. © Freepik Land Remediation for Livelihoods Restoration 36 Figure 17: Contaminated sites management process in South Africa Notification of investigation areas Advise owner to undertake site assessment Site assessment report Not contaminated Contaminated Decision Issue remediation or monitoring Mark site closed and management order Implementation by the owner/ Land Contamination Register responsible party Source: Compiled by the ASA team. Institutional framework The Directorate of Land Remediation is a branch of the Chemicals and Waste Management division of the national Department of Forestry, Fisheries, and the Environment. This directorate is responsible for overseeing the implementation of the Waste Act of 2008 at the national and provincial level, including the investigating possibly contaminated sites, overseeing the management of contaminated sites, and maintaining a national Contaminated Land Register.30 The Environmental Management Inspectorate is responsible for enforcement. Other relevant ministries and Members of the Executive Council where the site is located are also important stakeholders in the cycle of land remediation management, from site notification and assessment to remediation and monitoring. Financing mechanisms The “Polluter Pays” principles is fully embedded in the National Environment Management Act of 1998 and the Waste Act of 2008. As a consequence, the recipient of a remediation order (the landowner or any other responsible party) is responsible for the cost of remediation or management of a contaminated site. At the time of writing, the South African Waste Information System reported that a total of 503 contaminated sites had been notified since Part 8 of the Waste Act came into force in 2014. Of this, 288 sites were given remediation orders and 215 were issued monitoring and management orders. In response, a total of 116 sites had completed actions – remediation in 49 sites and monitoring and management of 67 sites.31 30 Government Notice 331. 2014. Waste Act of 2008: National Norms and Standards for the Remediation of Contaminated Land and Soil Quality. 31 https://sawic.environment.gov.za/documents. 37 Conflict Pollution in Iraq 3.3 Policy and regulatory framework in Iraq This section identifies gaps in current policy and regulatory framework and suggests related improvements for managing of contaminated sites in Iraq based on international practices and the nature and type of contaminated sites in the country. 3.3.1 CURRENT LEGAL FRAMEWORK Although Iraq has no specific law relating to contaminated sites In terms of individual laws, Article 17, Section IV of the Protection management, the constitution and some environmental legislations and Improvement of the Environment Law 27 of 2009 refers to the do include aspects relevant to hazardous waste and pollution protection of land and requires the prevention of any activity that management (Table 10). These aspects include the “right to live” directly or indirectly results in the degradation or pollution of soil. guaranteed through Article 33 of the Constitution, which states Reference to the establishment of an environmental protection that “every individual has the right to live in safe environmental fund can also be found in Article 26, Chapter VI of the law. Further, conditions” and commits that the “state shall undertake protection Section VII explicitly refers to pollution resulting from exploration and preservation of the environment and biodiversity”. Building on and extraction of oil and gas, while Chapter VIII introduces the these provisions, the National Environmental Protection Strategy concept of the “Polluter Pays” principle. (2013–17) includes specific actions for hazardous chemicals management, oil pollution, and solid waste. Though the period Despite their relevance to contaminated sites management, these of this national strategy has lapsed, the actions it highlights are provisions require further strengthening, especially to address still relevant for Iraq. historical or legacy pollution resulting from conflicts or other sources. Moreover, a better understanding of the current status of the environment protection fund and its operational modalities is required. Table 10: Summary of existing legislation relevant to contaminated site management in Iraq Legislation Key Features The Constitution Guarantees “right to live” and commits to protect and preserve the environment and biodiversity (Article 33). Requires formulation of environmental policy in cooperation with regions and governorates (Article 114). National Environment Protection Strategy (2013–17) Analyzes Iraq’s environment status and identifies strategies for nine critical areas of environment. Includes specific strategies for hazardous chemicals, oil pollution, and solid waste. Protection and Improvement of the Environment Law 27 Overarching law to protect the environment and natural resources. of 2009 Includes provisions related to solid waste and hazardous chemicals. Section IV relates to the protection of land and Article 17 aims to prevent activities resulting in soil degradation or pollution. System No. 25 of 1967 on Water Quality Conservation, Prescribes standards for water quality and wastewater discharges. Law of Rivers and Public Water Areas Requires permits for discharge of wastewater into public waters areas. Preservation of Water Resources Regulation No. 2 of Prescribes regulations for water use, conservation, and so on. 2001 Requires discharge license from environment authority. Safe Storage and Handling of Chemicals Law 89 of 1981 Details requirements for safe handling and storage of chemicals. and Instructions No. 4 of 1989 Relevant for management of hazardous chemicals in hotspots. Safety Instructions for Use of Asbestos No. 1 of 2002 Requires protecting the environment, workers, and surrounding air and Decision to Ban Use of Asbestos No. 41 of 2016 from the use of asbestos. Cabinet resolution 41 of 2016 seeks to ban the use of asbestos. Regulation No.3 of 2015 Prescribes regulations for the management of hazardous waste Requires approvals for waste treatment and the rehabilitation of contaminated sites. Worker Employer Labor Law 151 of 1970 and Regulation Prescribes requirements for occupational health and safety that 3 of 1985 would be relevant for contaminated sites management. Source: Analysis by ASA team. Land Remediation for Livelihoods Restoration 38 The Water Quality Conservation, Law of Rivers and Public Various provisions of these laws are relevant for assessing Water Areas (System No. 25 of 1967) and the Preservation of the impacts of contaminated sites and designing appropriate Water Resources Regulation 2, 2001, deal with water quality, management or remediation strategies. the discharge of wastewater, open dumping of wastes into water bodies, utilization and conservation of water resources, In addition, Iraq is signatory to several international conventions and permits for the discharge of wastewater. Both these laws and agreements on the environment and sustainability. apply to assessment of water pollution due to contaminated sites, when establishing remediation objectives, and when designing Agreements relevant to hazardous substances and remediation plans. contaminated sites include: Iraq also has laws that relate to the storing and handling of • The Basel Convention on the Control of Transboundary chemicals (Safe Storage and Handling of Chemicals Law 89 of Movement of Hazardous Wastes and their Disposal, 1992 1981 and Instructions No. 4 of 1989), the use of asbestos (Safety (ratified by Iraq on May 2, 2011) Instructions for Use of Asbestos No. 1 of 2002 and Decision to • The Stockholm Convention on Persistent Organic Pollutants, Ban Use of Asbestos No. 41 of 2016), and the management of 2004 (ratified by Iraq on March 8, 2016) hazardous waste (Worker Employer Labor Regulation No. 3 of • The Rotterdam Convention on the Prior Informed Consent 2015). These laws will help in assessing contamination at pollution Procedure for Certain Hazardous Chemicals and Pesticides hotspots and choosing remediation technologies for individual in International Trade, 2004 (ratified by Iraq on April 18, 2017) sites. • The Montreal Protocol on Substances that Deplete the Ozone Other important laws in the country are: Layer and the Vienna Convention for the Protection of the Ozone Layer, 1989 (ratified by Iraq on June 25, 2008, except • Regulation No. 471 of 2012 on the Preservation of Air Quality Kigali amendment, 2016). • Protection of Ambient Air Quality Regulation No. 3 of 2012 All these policies, strategies, acts, regulations, and commitment to • Environmental Assessment Law 37 of 2008 and 27 of 2009 international conventions, confirm the availability of basic enabling • Environmental Impact Assessment Categorization Instruction framework for the management of contaminated sites in Iraq. No. 3 of 2011 • Worker-Employer Labor Law 151 of 1970. 3.3.2 GAP ANALYSIS This section presents an analysis of gaps based on the above review of international examples and the regulatory framework in Iraq, together with the various steps for contaminated sites management relating to legal and regulatory requirements. Iraq has a comprehensive set of environmental regulations and includes certain aspects relevant to contaminated sites management (such as regulations for hazardous waste, storage and handling of chemicals, inclusion of “Polluter Pays” principle, and so on (Table 11). However, some important requirements for identifying, assessing, and remediating pollution, as well as the institutional mandate for the management of contaminated sites, are missing from the current regulatory framework. © Freepik 39 Conflict Pollution in Iraq Table 11: Environmental laws of Iraq relative to contaminated site management process Contaminated sites management steps Requirements or gaps in laws of Iraq IDENTIFICATION • National and local authorities are responsible for protection of the environment, but “contaminated sites” need to be defined. Identification of probably contaminated sites • Legal provisions for identifying suspected sites, notification, establishing a Preliminary investigation national inventory of suspected sites, and developing site management programs. Notification of contaminated sites Identification of priority sites • Per the Protection and Improvement of the Environment Law 27 of 2009, local councils have the authority to perform field inspections and to issue fines should provisions of the law be breached. Officials of these councils have already been trained through the current ASA and can perform initial assessment of sites. • Dutch Intervention Values (DIVs) for soil are currently applied for assessing hotspots, but these values or relevant local standards need to be legally notified. • Environmental Law 27 of 2009 provides for the establishment of an Environmental Protection Council represented by various ministries. While the mandate of the council is broad, this institutional arrangement can be used as an empowered body for the contaminated site management program in the country. • Regulation No. 3 of 2015 includes issuing environmental approvals for projects to rehabilitate contaminated sites. • Legal provisions to carry out site assessments and risk analyses, prioritize sites, and conduct remediation. • Legal provisions to determine the liability, although “Polluter Pays” principle is recognized by the Environment Law 27 of 2009. ASSESSMENT AND PLANNING • Legal provisions and guidelines for carrying out detailed assessment of contaminated sites. Detailed investigations • Standards for soil quality to be established. Provisions exist for the Remediation design management and disposal of hazardous wastes, wastewater discharge, Approval and financing management of hazardous chemicals, and air quality. • Projects that are likely to have effects on human health and environmental integrity (such as contaminated sites remediation) will require Environmental Impact Assessments. • Although the legislation requires polluters in the oil and gas sector to pay for remediation of contamination resulting from their activities, clear guidance on the responsibilities for funding remediation of contamination resulting from conflict is needed. There is reference to the “Polluter Pays” principle, an Environmental Protection Fund, and an approach to calculating the amount of compensation. These provisions can be used to develop an appropriate financing mechanism for remediation of contaminated sites. IMPLEMENTATION • Legal provisions related to implementation of remediation activities, including monitoring and reporting progress. Implementation of remediation • Provisions for defining and approving remediation completion. Approval of remediation completion • Labor law includes a requirement to adhere to an approved site safety plan, which must include a task-based hazard and risk assessment, and description of risk management measures. POST-REMEDIATION Provisions related to the post- remediation phase. Post-remediation plan and action Long-term monitoring Cost recover Priority list deletion Site reuse Source: Analysis by ASA team. Land Remediation for Livelihoods Restoration 40 3.3.3 REQUIRED POLICY AND REGULATORY ENHANCEMENTS Given the magnitude of risks and geographical spread of the sites, as well as the pollution challenges around them, Iraq requires a comprehensive national program that is supported by an appropriate policy and regulatory framework. The environmental legislation of Iraq includes elements that can be related to the management of contaminated sites, but key gaps should be addressed for the implementation of a broader program on pollution hotspots. Experience from other countries and regions provides valuable insights on how these gaps can be addressed.32 Policies for contaminated site management Iraq currently has no national policy that outlines its approach to managing contaminated sites. Countries have followed different approaches in developing their programs, primarily driven by the local context. However, decisions regarding the management of contaminated sites should be based on the level of risks they pose to humans and the environment. Moreover, remediation efforts are not free of consequence, and poorly planned remediation projects can also be associated with significant negative impacts. A policy for pollution hotspots in Iraq would be a constructive first step towards developing programs that address these challenges. Definition of contaminated site Defining what constitutes a contaminated site is an important gap in Iraq’s regulatory framework. The MoE currently refers to contaminated sites as “environmental hotspots”. An acceptable name and definition consistent with the country’s constitutional and policy framework and international good practice must be developed to form the basis for identifying and managing contaminated sites. Enabling legislation and regulations There are two broad options to strengthen the legislative framework related to the management of contaminated sites. The first option involves enhancing or strengthening existing legislation through amendments or additions. The second option is to develop dedicated legislation on contaminated sites management. Identifying the most suitable option will require comprehensive analyses of the legislation from both a technical and legal perspective, as well as consultations with various stakeholders in the country. These analyses and consultations should address both low- and high-level enabling legislation and answer the following: • Which legislative elements relating to contaminated site management already exist, are missing, or should be strengthened? • What are the pros and cons of strengthening existing regulations versus a dedicated legislation? If the option of enhancement or strengthening current legislation is chosen, the Protection and Improvement of the Environment Law (No. 27 of 2009) and laws relating to the protection of water resources could be amended. Ultimately, the chosen option should align with national policy and the definition of contaminated sites suggested above. Soil quality standards and screening levels Iraq has no standards or screening levels for pollutant concentrations © CLS, France in soil. The MoE currently draws on the DIVs for soil, but standards that considers country context should ideally be developed. The absence of national determinants of contaminated soil limits efforts to identify and manage contaminated sites. Internationally, soil quality screening levels are defined based on risks to human health and environmental integrity. The proposed standards should be included in relevant legislation (for example, Environment Law No.27 of 2009 or dedicated legislation on contaminated sites, as the case may be). However, given that the development of these standards is a prolonged process that requires consensus among stakeholders, the current practice of following DIVs could be formalized through appropriate regulatory action as an interim measure. 32 World Bank 2010. 41 Conflict Pollution in Iraq Framework for the management of contaminated sites A technically sound and logical framework for the identification, assessment, and remediation or management of contaminated sites is another important element that is absent in Iraq’s current regulatory regime. The framework should—with the help of other statutory provisions such as an overarching policy, sound definition of contaminated sites, and soil screening levels—clearly define the process to: 1 Assess suspected sites. 5 Decide the need for remediating a particular site and its design. 2 Identify contaminated sites. 6 Monitor the site after remediation. 3 Prepare an inventory and prioritize sites. 7 Close the site. 4 Carry out detailed investigations and risk assessments. Adoption of risk-based cleanup targets Full remediation, such as removing every contaminant from the site, is often excessively costly. The optimal target level for cleanups depends on the risks the contaminant poses to the environment and the surrounding population, which hinges on the site’s proximity to population centers and the intended use of the land. Cleanup targets should consider these risks, as well as the proposed or future land use of the site, threats to water resources, and other ecological and environmental attributes. 3.4 Institutional framework 3.4.1 CURRENT FRAMEWORK Designing, developing, and successfully implementing a hotspots At the broader level, the Ministry of Finance and the Ministry of management program involves effective coordination, and Planning will play a pivotal role in finalizing the overall framework active participation by, various public, private, and community and the financial aspects of a hotspots management program. stakeholders. Pollution hotspots in Iraq are diverse and owned or The Ministry of Science and Technology and the Ministry of managed by different entities, including the MoO and the Ministry Health will also play a role in the technological and health-impacts of Petroleum (oil wells and gas extraction sites); the Ministry of perspective of such a program. Agriculture (pesticides and fertilizer industry sites); the Ministry of Electricity (power plants and electrical industry sites); the Ministry Yet, aside from the MoE and the MoO, none of the ministries of Defense (defense facilities), the Ministry of Industries (various understand the issues related to the management of contaminated industrial facilities), and private owners of industrial sites. sites. Extensive awareness programs and consultations would be needed to achieve consensus when conceptualizing, designing, Although not covered in this ASA report, pollution hotspots developing, and implementing a hotspots management program. are likely present across all Iraq governorates. Implementing a hotspots management program will rely on the participation of all governorates, their respective municipalities, and other local agencies. Land Remediation for Livelihoods Restoration 42 Table 12: Role of stakeholder ministries in hotspots management Ministry/Department/Agency Role/ Function Ministry of Finance National ministry responsible for financial planning and budgeting. Will play a critical role in conceptualizing, designing, and funding the hotspots management program. Ministry of Planning National ministry that leads in policy development and the design of various projects in Iraq. Will be important for developing and monitoring the hotspots program, as well as developing the policy and regulatory framework around it. Ministry of Environment National ministry responsible for overall environmental management in Iraq. Will be the lead agency in coordinating with stakeholder ministries and in conceptualizing, designing, implementing, and monitoring the hotspots management program. Ministry of Science and Technology National ministry that leads on aspects relating to technology and research. Will play a crucial role in establishing soil standards or screening levels and identifying remediation technologies. Ministry of Agriculture National ministry responsible for formulating and implementing policy, as well as developing the country’s agriculture sector. Will play an important role in remediating sites contaminated with pesticides and fertilizer. Ministry of Electricity National ministry responsible for electricity generation, transmission, and distribution in Iraq. Will play an important role in remediating sites owned or monitored by the ministry. Ministry of Oil National ministry responsible for oil extraction, export/import, and related activities. Will play an important role in decommissioning and disposing of hydrocarbon-contaminated sites. Ministry of Industry National ministry responsible for industries. Will play an important role in the decontamination and remediation of sites and facilities owned or monitored by the ministry. Ministry of Construction, Housing, Municipalities, and Public Works National ministry that provides policy and administrative oversight for municipalities. Will play an important role in the post- remediation land use of sites and coordination with municipalities. Governorates in the project area Regional bodies of the Government of Iraq that provide administrative oversight of urban and rural bodies within their jurisdictions. Will play an important role in coordinating with various agencies and implementing the hotspots program. Municipalities and local agencies Local entities who benefit from project activities and will reap anticipated benefits from pollution management, will play an important role during implementation. Source: Discussions with MoE and other Government of Iraq entities. 3.4.2 INSTITUTIONAL MECHANISMS FOR HOTSPOT MANAGEMENT Contaminated site management requires a multi-stakeholder approach. International experience shows that one institution cannot lead such a comprehensive and complex program. Yet, due to its institutional mandate and technical knowledge in the sector, the MoE will be a key player in leading such a program. The Government of Iraq may explore the following institutional arrangements. 43 Conflict Pollution in Iraq Option 1: Program Management Unit at the MoE with an inter-ministerial steering committee Advantages • Will require no major parliamentary or constitutional approval process. • Can start quickly once overall program is approved by the government. • Will leverage the technical capacity developed at the MoE through the current ASA. • Will build implementation capacity and knowledge of hotspots management within the MoE and other Government of Iraq institutions, so providing long-term sustainability. Disadvantages • The MoE has no prior experience of implementing large pollution management projects, more so with participation from various other ministries. • Other ministries may be apprehensive of working with the MoE because it is a regulatory agency. • It would require hiring a number of external experts to support the MoE. • Implementation could be challenging for the MoE with limited local and regional presence. Option 2: Program Coordination Unit at the MoE with other ministries as implementing agencies Advantages • Ensures use of the MoE’s technical capacity and sectoral responsibilities of other ministries and agencies. • Has potential for good stakeholder coordination. • Offers stronger local presence and better implementation with support from other ministries. • Will also provide all other advantages of Option 1. Disadvantages • Clear roles, responsibilities, and fund-flow arrangements between agencies should be agreed upfront to avoid implementation disputes. • The number of national ministries, local governorates, and agencies could present challenges in overall program ownership and delivery. • Institutional structure and staffing distribution would need to be agreed between ministries to ensure that adequate capacity is available within all agencies. • A person or ministry to head the project, who can lead all these institutions and resolve obstacles as they arise, would need to be designated. Option 3: A dedicated institution/agency with an inter-ministerial coordination committee Advantages • Offers a clear mandate and responsibility to one agency. • Will offer the flexibility of developing a technical institution with strong expertise to handle the complex contaminated sites program. • Project implementation could be efficient and timely. • Would ensure long-term institutional capacity for the management of hotspots in Iraq. Disadvantages • Requires constitutional and parliamentary approvals, which could take time. • Setting up a new institution in terms of hiring people or redeploying people will take time. • The powers and responsibilities of the new institution should be clearly defined to avoid overlap with other agencies. • Coordination with other ministries could be challenging for a new institution. Ultimately, the choice of option should be based on detailed deliberations and consultations with the agencies and a more robust assessment of institutions. Land Remediation for Livelihoods Restoration 44 3.5 Technical, institutional, and infrastructure requirements Regardless of the choice of institutional mechanism, contaminated sites management will require a high level of technical and institutional capacity. This could vary for a new institution when compared to an existing institution, but the basic requirement will remain the same. This section focuses on the necessary technical and institutional capacities and infrastructure requirements to consider when choosing a suitable institutional model and designing the capacity-building components of a contaminated sites program. 3.5.1 TECHNICAL CAPACITY Technical capacity in a wide range of topics is required for the personnel involved in contaminated sites management. Depending on the nature and type of pollution at sites, subject-specific experts will likely be required. These experts could be contracted on a case-to-case basis. Technical capacities can be clustered under 10 broad functions to which specific skills can be related (Table 13). Table 13: Technical capacity requirements for contaminated sites management Function Capacity or skills required Concepts and principles of contaminated site management Professional with engineering or science background, and basic training and field experience on the subject. Identification, screening, and initial assessment of sites Professional with environmental engineering or science background and specific training (academic and field) on screening techniques, the development of data checklists, data collection, site assessments, use and handling of GPS instruments, analysis, and the interpretation of secondary and field data. Detailed site assessment and investigations Senior professional with advanced training and field experience in the design of environmental sampling programs, engineering investigations (topographic surveys), soil sampling, development of Conceptual Site Models, and data interpretation and analysis. Laboratory analysis and interpretation Senior chemists with experience in analyzing soil and water samples using advanced equipment such as Gas Chromatography-Mass Spectrometry, Inductively Coupled Plasma-Mass Spectrometry, and Energy Dispersive X-ray Fluorescence. Health risk assessment Senior professional with experience in carrying out Human Health Risk Assessments. Design and development of contaminated site management or Remediation experts with experience preparing remediation plans remediation plans relevant to the nature and type of contamination at the site. Communication, stakeholder engagement, and consultations Stakeholder consultation experts and other team members with a basic understanding of stakeholder engagement and consultation. Project structuring, procurement, supervision, and contract Experts on project structuring, procurement, and contract management management, with support from technical and remediation experts. Post-remediation monitoring Remediation and environmental monitoring experts. GIS and information management GIS experts with experience in using spatial tools, analyzing satellite imagery, and managing information. Source: Analysis by ASA team. The Government of Iraq has experience in some of the above functions together with the technical capacities of various entities. The MoE has a dedicated Contaminated Sites Assessment Department that performs site inspections and assessments. Through UNEP’s technical assistance and the current ASA, about 30 officials (from the Contaminated Site Assessment Department of the MoE, the MoO, and governorate officials) were trained on concepts and principles of contaminated site management and the identification, screening, and initial assessment of sites. Using the skills developed through these training programs, the joint MoE and MoO teams carried out the inventory and initial assessment of suspected hotspots in Iraq. 45 Conflict Pollution in Iraq Eight laboratory officials from the MoE were also provided with hands-on training to carry out laboratory analysis and interpretation of water and soil samples using advanced equipment. Training on GIS and information management was also provided for eight members of the MoE. This training covered the mapping of hotspot sites and updating site information using GIS tools. Overall, as highlighted in section 1,3, seven training programs for a total of 57 days were provided to 66 officials (cumulatively 134 participants and 7,638 person days of training) from the MoE, the MoO, and other Government of Iraq officials on all critical aspects of contaminated sites management. Although these training programs enhanced the capacity of the MoE team, additional capacity-building initiatives will be necessary to enable the ministry to independently manage a contaminated sites program. 3.5.2 INSTITUTIONAL CAPACITY Three aspects must be considered when assessing an institution’s capacity to perform mandated activities: the presence of adequate and qualified personnel, the presence of appropriate systems and procedures, and the presence of appropriate infrastructure. Adequate and qualified personnel The MoE’s Contaminated Sites Assessment Department currently has a total of 52 staff members, of which 22 work at the central/national level and 30 are distributed across all governorates in the country. Although this workforce may be adequate for routine monitoring and inspection of hotspots, contaminated sites management requires carrying out additional activities. These include identifying and assessing contaminated sites, preparing and implementing remediation plans, and monitoring sites after remediation. The need for additional staffing should be assessed based on detailed personnel planning and should, among other skills, include: • Personnel with expertise on contaminated sites. • GIS and database management specialists for maintenance and updating of the hotspots database. • Civil and construction engineers. • Procurement specialists. • Contract management experts. Appropriate systems and procedures To enable the MoE’s Contaminated Sites Assessment Department to perform its functions efficiently, specific procedures and protocols for inspecting and assessing contaminated sites need to be developed. Customized technical guidance will also need to be developed for each function of contaminated sites management. Such guidance will be based on the country’s regulatory and policy framework and should provide practical guidance to staff from the ministry, industries, and practitioners to execute contaminated site assessment, remediation, and management activities. © MoE and RSK LLC Key documents should include: • Procedures for identifying and conducting initial assessment of contaminated sites. • Guidance for designing sampling programs and performing field sampling. • Guidance for developing Conceptual Site Models. • Procedures for conducting human health and ecological risk assessment. • Protocols for developing cleanup objectives based on risk assessment. • Guidance on conducting feasibility studies and preparing remediation plans. • Supervision and monitoring protocols for implementing remediation plans. • Guidance for the post-remediation monitoring and management of contaminated sites. Land Remediation for Livelihoods Restoration 46 3.5.3 INFRASTRUCTURE REQUIREMENTS The required infrastructure can be divided into three categories: of organizational structure.33 However, the equipment required field sampling equipment, laboratory infrastructure, and office for analyzing advanced environmental parameters and the infrastructure including information technology and allied tools. trained staff to use such equipment is not available. Furthermore, although the laboratory has a quality assurance department, it For contaminated sites, field sampling equipment include does not have quality assurance certification (ISO 9000, 14001, or handheld GPS instruments, sampling tools for collecting samples 17025 accreditation). Similar deficiencies are noted in the MoE’s for environmental parameters, personal protective equipment regional laboratories. for conducting site assessments, and field sampling and site assessment toolkits. While the MoE has some GPS instruments, Basic office infrastructure and facilities for managing substantial these need to be upgraded. An adequate number of instruments data related to hotspots, such as computers, printers, scanners, should be made available for all field assessment staff of plotters, hardware, and software, also require upgrades. High-end the ministry. computers and other hardware infrastructure will be required to run specialized software (such as ArcGIS Pro) for mapping, for The MoE’s central laboratory in Baghdad is the main laboratory data interpretation through spatial tools such as GIS, and very at the national level. Based on UNEP’s assessment, the high-resolution images. laboratory has basic infrastructure and some key elements 3.6 Conclusion An analysis of regulatory, institutional, and capacity-building requirements for the management of pollution hotspots in Iraq indicate the need to; strengthen policy and regulatory framework in line with the international good practices; establish an institutional mechanism that ensures coordination between various stakeholder ministries; and build the technical and institutional capacity of MoE. While a broad set of options for each of the above enhancements have been identified, these options need to be further evaluated based on more detailed analysis of each element, more specifically in the context of an overall program on contaminated site management in Iraq and its specific interventions. 33 UNEP 2018b. © Adobe Stock 47 Conflict Pollution in Iraq 4 Technology Options for Remediation 4.1 Introduction Remediation technologies should be relevant to the nature, type, and local of context of Iraq. The selection of a specific technology for remediation will be dependent on whether a “risk-based” or “standards based” approach is taken. Factors influencing the technology’s performance and its indicative cost are other important considerations. This section discusses these points and presents a menu of technology options, which can be further assessed during the preparation of remediation plans for individual sites. © Adobe Stock Land Remediation for Livelihoods Restoration 48 4.2 Remediation approaches Internationally, the following two approaches are followed for the remediation of contaminated sites: • “Risk-based” or “fit for use” approach: Aims to remove or treat the contaminants to a level that reduces the risks to human health and existing/proposed land use of a site. • “Standards based” or “multifunctional soil remediation” approach: Aims to remediate the contaminated land to a pristine condition or to a prescribed concentration level. 4.2.1 RISK-BASED APPROACH This approach follows an acceptability criterion tied to human Contamination without receptors presents no risk, and a risk- health risks and future land use of the site to be remediated. based approach would not call for intervention. However, Present and projected land use can also be considered when alternative remediation options could be considered if it is decided identifying remediation objectives, in usage is expected to change to nonetheless remediate such a contaminated site in order to, soon. A basic principle is that reuse or redevelopment of a site for example, improve the quality of an aquifer to meet drinking should fix or improve soil and groundwater quality. water standards. The risk-based approach can be followed for every type of A risk-based approach also incorporates sustainability aspects source-pathway-receptor contamination. In cases of immobile soil by providing the opportunity to choose technologies that combine contamination, as with many heavy metals, it requires assessing economic and sustainable benefits without sacrificing public health the quality of the topsoil layer alone because the quality of this or safety. In doing so, it facilitates a balance between human part of the soil is responsible for most human and environmental health and environmental protection versus the opportunity to risks. This approach saves effort in carrying out assessment of reuse contaminated soil and to optimize the economic aspects contaminated sites deeper than the top layer of the soil, thus of site redevelopment. providing an opportunity to balance the scientific assessment of sites with the pragmatism of dealing with site or region-specific In the context of Iraq, where a broader national program for preconditions at the contaminated sites. The threshold values for remediation of multiple contaminated sites is needed, adoption a specific site use offer basic safety warranties. of a “risk based” approach offers opportunities for choosing remediation technologies that optimize the need for remediation while considering the economic and health benefits of local communities. 4.2.2 STANDARDS-BASED OR MULTIFUNCTIONAL SOIL REMEDIATION APPROACH The standards-based approach aims to remediate all contaminated term. An example of the costs and inefficiency of a multifunctional land to a pristine condition, which would entail restoring soil quality remediation approach would be removing every last drop of from an intervention value back to a standard target or natural mineral oil from mineral oil-contaminated soil—a technical background level, regardless of the site’s current characteristics or challenge that would be disproportionate to the costs and energy future land use. This approach is also known as a multifunctional required to achieve it, because the extraction of every last drop soil remediation approach because remediated sites would ideally would likely demand much more energy than represented by the be fit for all uses. drop itself. Given that the target levels are well defined and non-negotiable, The idea that soil contamination could stagnate the (re) this approach provides a simple decision-making system that is development of urban or prime sites gained traction during the easy to apply. If remediating the soil of a site is not feasible with first half of the 1990s. This stagnation was largely due to the this approach, a fallback option would be containing the pollutant. stringent contamination policies in place, which leaned towards However, containment should be comparable to the complete a standards-based or multifunctional approach. Given the higher removal of the pollutant and be designed in a way that results in cost of remediation when following this approach, developers the lowest possible emissions. were dissuaded from working on (potentially) contaminated sites. Even in the densely populated areas of north-western Europe, The concept of multifunctionality was most relevant during 1990s greenfield developments were the most economical option. when the direct link between soil contamination and serious health risks could be established on a one-to-one basis. This Despite these drawbacks, a multifunctional approach has was the ultimate aim of contaminated land remediation at that not been phased out completely and it is still useful in specific time. However, subsequent studies indicated that, even after circumstances. For example, the cost of a multifunctional approach prohibitive investments in remediation, restoring soil to a pristine is relatively low in a small contaminated area. This approach may state would take a long time. Multifunctionality is therefore not also be the most appropriate option for a liable party when the likely to be technically feasible or economically viable in the short policy is to avoid any future liability issues. 49 Conflict Pollution in Iraq 4.2.3 POSSIBLE APPROACH FOR HOTSPOTS MANAGEMENT IN IRAQ Compared to a risk-based approach, a standards-based targets, which can be derived from—or combined with—other approach is relatively simple and easy to understand, even target values, such as drinking water standards. A risk-based for non-professionals. While some countries (notably Finland, approach, however, requires more data on the local situation. In the Netherlands, and Switzerland) have retained the goal of most cases, the return on investment in acquiring this information multifunctionality, most countries follow a risk-based approach. increases with time because of the reduced costs of remediation. This characteristic may attract support, especially from residents, Considering the complexity of hotspots scenarios in Iraq, both when proposing remediation solutions. However, a standards- in terms of size and nature of the contamination, the importance based approach is also less flexible: Once the standards have of remediation cost cannot be ignored. The sites are distributed been set, which are policy-level decisions, remediation efforts are over a wide geographical area, meaning that remediation options far less likely to consider the local context of individual sites. Lastly, need to be tailored to meet local conditions and the requirements given their intensity and inflexibility, standards-based approaches of stakeholders. will be financially and energetically costly. Ultimately, the risk-based approach appears to be an appropriate By contrast, risk-based approaches develop remediation options approach for Iraq. However, the Government of Iraq and MoE specific to individual sites and local conditions. In accordance with should make a final choice on the acceptable approach with the site assessment phase, this approach also usually includes a detailed consultations with various stakeholders while preparing risk assessment to determine the need to remediate. Risk-based the broader program on hotspots remediation. approaches are more flexible in their individual, site-specific 4.3 Remediation options and technologies Once the broader approach for remediation has been decided, technology is the most important aspect that will determine the outcome of any intervention. Globally, several remediation technologies have been developed and applied successfully to treat and remediate contaminated sites. Potential options for remediation of contaminated sites, focusing on those that are most likely to be relevant in the context of Iraq, should consider the following: • Most of the hotspots identified in Iraq are contaminated by hydrocarbons and heavy metals. • The sources of contamination at most the sites are leaks at oil refineries and pipelines, or chemical spills at industrial sites. • Based on the initial assessment and environmental sampling, soil is the most impacted medium, while groundwater seems to have not been contaminated • Very few small-scale remediation projects have been implemented in the country, and there is limited local experience on the performance of remediation technologies. Table 14 provides a list of potential remediation technologies for pollution hotspots in Iraq. These technologies include both in situ treatments (at the site of the contamination) and ex situ treatment (contaminated material is removed from the original location and then treated) techniques, each with their own applicability (media, contaminant types, and so on). In certain instances, a combination of two or more of the technologies described in the table may be required to achieve remediation targets. The technologies discussed are indicative and not exhaustive. The actual choice of technology should be based on the overall remediation objectives, detailed site investigations, and health risk assessment of contamination at the site. © Freepik Land Remediation for Livelihoods Restoration 50 Table 14: Potential remediation technologies relevant to the profile of hotspots in Iraq Contaminants Description Advantages Disadvantages 1. Excavation and offsite disposal Heavy Metals Removes contaminated soil and Technically less complicated. Creates large volumes of disposes it at an authorized site Widely available and accepted. contaminated solid waste. Not feasible in some geological situations. Excavation below water table would be expensive. 2. Phytoremediation Heavy Metals and Petroleum Uses plants to absorb Less expensive with limited Requires long preparation time Hydrocarbons contaminants from the surface maintenance. Only periodic and long-term access to treat and to store them in tissue. maintenance is needed soils. Difficult to treat deep (harvesting and processing of groundwater. Requires hyper- plants or plant detritus) once accumulating plants that may plants are established. not exist for metals that are not essential nutrients. 3. Soil washing Heavy Metals and Petroleum Dissolves contaminants in a Can be used for a wide range of Complex waste mixtures make Hydrocarbons wash solution or concentrates contaminants. formulating a wide range of them into a smaller volume. fluids difficult. High humic content in soil may require pretreatment. Aqueous streams need demobilization. 4. Electrokinetic separation Heavy Metals Deploys electrodes in sub- Effective in clay-rich aquifers. Increase of pH near cathode surface to create an electric Potential for less solid waste. could cause precipitation of field that drives contaminants to metal salts. Efficiency decreases electrodes. outside of specific aquifer and contamination conditions. 5. Solar vapor extraction Petroleum Hydrocarbons Extracts vapors from the Low cost. Can be applied in- Vapor requires treatment. soil above the water table by situ. Very effective in removing Effectiveness typically applying a vacuum to pull the volatile contaminants such diminishes over time as readily vapors out. as Petroleum Hydrocarbons. extracted contaminant mass Established process. is removed. 6. Landfarming Petroleum Hydrocarbons Places excavated contaminated Low cost. Facilities are simple to Requires large land mass. soils over a treatment area or construct and easy to operate. Regulatory limitations on wastes in a biotreatment cell, typically Uses standard equipment. that can be treated. May not lined to prevent leaching. be effective for highly impacted soils. Dust and vapor emissions may pose air-quality concerns. 7. Natural Source Zone Depletion Petroleum Hydrocarbons Uses naturally occurring Low cost: Little to no engineering Sophisticated monitoring is processes of dissolution, effort is required. required. Site-specific conditions volatilization, and biodegradation will drive the magnitude and to reduce containment mass. rates of degradation. Source: Compiled by the ASA team. 51 Conflict Pollution in Iraq 4.3.1 EXCAVATION AND OFFSITE DISPOSAL According to the US Federal Remediation Technologies Roundtable (FRTR), the excavation and off-site disposal process involves selecting the “appropriate methods for dewatering, handling, transport, pre-treatment, and disposal”, while “excavation and off-site disposal is a proven and readily implementable technology”.34 Excavation and Offsite Disposal can be used as a remediation technology for handling a variety of contaminants, including Petroleum Hydrocarbon and Heavy Metals. According to the FRTR, the major steps of this technology are excavation, dewatering, soil handling, and pre-treatment and disposal. These steps are described in detail below: Excavation: Excavation is the mechanical removal of waste or contaminated soil from the subsurface with a variant of an excavator or backhoe. Other earthmoving equipment (e.g., clamshell buckets, bulldozers) may also be used based on the size and configuration of the excavation. Air knife techniques followed by a hi-tech vacuum are also used for precise removal of soil from around sensitive structures, utilities, or plant roots. Dewatering: Dewatering refers to control of groundwater in the area of excavation, removal of water (stormwater or infiltrated groundwater) from within an excavation area or draining of excavated material to meet transport and disposal restrictions. All water generated from dewatering requires on-site management, and typically requires treatment prior to discharge. In some cases, the removed water is classified as a hazardous waste and must be managed as such. Portable water treatment systems to manage stormwater at standard grading sites can be used in some cases, but often additional treatment must be performed, and discharge requirements must be met based on the site contaminants and receiving facility (typically storm drains or a publicly owned treatment works). Soil handling: Involves relatively simple (e.g., direct loading of trucks by the excavator) to a very complex (e.g., segregation of hazardous and non-hazardous waste streams, segregation of debris and other waste, lead recovery, on-site stabilization or other ex situ treatments, dewatering, and stockpiling) process depending on the site situation. Planning soil handling and transport during the design phase is critical to a successful excavation project. For example, sufficient land area must be identified near the excavation site to provide for soil handling, and temporary haul roads must be laid around the site of excavation, a stable surface shall be provided for on-road dump trucks that bring them near the load-out area. For some projects a combination of truck and rail transport is warranted. For sites with mixed hazardous and non-hazardous waste with different transport restrictions, careful management of truck traffic and manifesting is necessary. For large projects during peak construction season, securing adequate transport resources (e.g., a sufficient number of trucks each day) should be planned well in advance. Pre-Treatment and Disposal. The type of contaminant and its concentration will impact off-site disposal requirements. Soil characterization as dictated by land disposal restrictions is required. Most hazardous wastes must be treated to meet either Resource Conservation and Recovery Act or non-[Resource Conservation and Recovery Act] treatment standards prior to land disposal. Pre-treatment, generally consisting of stabilization by mixing with fly ash or similar amendments to reduce contaminant leaching potential, is often conducted at the receiving facility but is sometimes performed on site Pretreatment or placement of hazardous waste outside the area of contamination (on site or off site) may require development of a Corrective Action Management Unit, so as to not violate requirements. Radioactive wastes would have to meet disposal facility waste form requirements based on waste classification.35 34 https://www.frtr.gov/matrix/Excavation-and-Off-Site-Disposal. 35 https://www.frtr.gov/matrix/Excavation-and-Off-Site-Disposal. Advantages • The technology is well-established and readily deployable. • Applicable to the complete range of contaminant groups and has no particular target group. Disadvantages • A large amount of solid waste is generated. • It is not feasible in some geology, such as heaving sand. • The cost increases significantly for excavation below the water table. • The accessibility (that is, depth) of contaminated soil is limited by the excavation equipment. • The presence of any infrastructure needs to be removed or protected. The need for dewatering for groundwater control, maintaining a dry excavation, and draining of the removed media, as well as treatment of recovered water, adds additional costs and effort to the project. Health and safety requirements for on-site workers and off-site population also need to be ensured. Costs The FRTR describes the costs of Excavation and Offsite Disposal as the following: “Upfront costs for excavation and disposal can be high compared to in situ treatment technologies. However, excavation can result in substantially shorter restoration timeframes, resulting in lower lifetime costs when operation, maintenance, and monitoring costs for in situ systems are considered. An overall life cycle assessment of costs can be challenging.”36 4.3.2 PHYTOREMEDIATION The phytoremediation approach involves cultivating specific species of plant on the contaminated medium (either water or soil) and the contaminants are then either taken up into the plant tissues or absorbed to the surface of the roots. Once the concentration of contaminants in the medium is below target levels, the plants (and associated contaminants) are removed and either disposed of safely or incinerated. Phytoremediation is particularly effective for removing heavy metals from soil. While phytoremediation may include the use of microorganisms in conjunction with plants, it is distinguished from bioremediation in that bioremediation does not use macroscopic plants or trees. Plants can be used for phytoremediation in several ways. These are described as follows by the FRTR: Enhanced Rhizosphere Biodegradation takes place in the soil surrounding plant roots. Natural substances released by plant roots supply nutrients to microorganisms, which enhances their ability to biodegrade organic contaminants. Plant roots also loosen the soil and then die, leaving paths for transport of water and aeration. This process tends to pull water to the surface zone and dry the lower saturated zones. Hydraulic Control. Depending on the type of trees, climate, and season, trees can act as organic pumps when their roots reach down towards the water table and establish a dense root mass that takes up large quantities of water. Phyto-degradation is the metabolism of contaminants within plant tissues. Plants produce enzymes, such as dehalogenase and oxygenase, that help catalyze degradation. Investigations are proceeding to determine if both aromatic and chlorinated aliphatic compounds are amenable to phyto-degradation. Phyto-volatilization occurs as plants take up water containing organic contaminants and release the contaminants into the air through their leaves. Plants can also break down organic contaminants and release breakdown products into air through leaves.37 36 https://www.frtr.gov/matrix/Excavation-and-Off-Site-Disposal. 37 https://www.frtr.gov/matrix2/section4/4-33.html. 53 Conflict Pollution in Iraq Advantages • The cost is low, because it uses plants to remediate contaminants. • Phytoremediation only requires periodic maintenance once the plants are installed. • The technology is versatile and can be used to clean up heavy metals and organic contaminants from soil, groundwater, surface water, and leachate. • The plants produce enzymes that help catalyze the degradation of contaminants. Disadvantages • Phytoremediation requires long-term access to treat soils. • The FRTR specifies the following limitations of this technology: › It is limited to shallow soils, streams, and ground water. › High concentrations of hazardous materials can be toxic to plants. › It involves the same mass transfer limitations as other biotreatments. › Climatic or seasonal conditions may interfere or inhibit plant growth, slow remediation efforts, or increase the length of the treatment period. © MoE and RSK LLC › It can transfer contamination across media, e.g., from soil to air. › It is not effective for strongly sorbed (e.g., Polychlorinated Biphenyls) and weakly sorbed contaminants. › Phytoremediation will likely require a large surface area of land for remediation.38 Costs The key drivers of the cost of deploying phytoremediation technology are the area of contamination and the tree size (maturity). Based on the cost analysis developed in 2006 using the Remedial Action Cost Engineering and Requirements software published by the FRTR, it is estimated that the cost of remediating a small site would be around US$5.40 per cubic meter for an easy site to US$6.00 per cubic meter for a difficult site. Phytoremediation of a large site would cost about US$1.60 per cubic meter for an easy site and up to US$2.30 per cubic meter for a difficult site. 4.3.3 SOIL WASHING Soil Washing is described by the FRTR as follows: Soil washing is a water-based process for scrubbing soils ex situ to remove contaminants. The process removes contaminants from soils in one of the following two ways: • By dissolving or suspending them in the wash solution (which can be sustained by chemical manipulation of pH for a period of time); or • By concentrating them into a smaller volume of soil through particle size separation, gravity separation, and attrition scrubbing (similar to those techniques used in sand and gravel operations). Soil washing systems incorporating most of the removal techniques offer the greatest promise for application to soils contaminated with a wide variety of heavy metal, radionuclides, and organic contaminants. The concept of reducing soil contamination through the use of particle size separation is based on the finding that most organic and inorganic contaminants tend to bind, either chemically or physically, to clay, silt, and organic soil particles. The silt and clay, in turn, are attached to sand and gravel particles by physical processes, primarily compaction and adhesion. Washing processes that separate the fine (small) clay and silt particles from the coarser sand and gravel soil particles effectively separate and concentrate the contaminants into a smaller volume of soil that can be further treated or disposed of. Gravity separation is effective for removing high or low specific gravity particles such as heavy metal-containing compounds (lead, radium oxide, etc.). Attrition scrubbing removes adherent contaminant films from coarser particles. However, attrition washing can increase the fines in soils processed. The clean, larger fraction can be returned to the site for continued use. The contaminated water generated from soil washing are treated with the technology(s) suitable for the contaminants.39 38 https://www.frtr.gov/matrix/Excavation-and-Off-Site-Disposal. 39 https://www.frtr.gov/matrix2/section4/4-19.html. Land Remediation for Livelihoods Restoration 54 Advantages • Its ability to target various contaminant groups (such as VOCs, fuels, and Heavy Metals). • According to the FRTR, the technology offers the ability to recover metals and can clean a wide range of organic and inorganic contaminants from coarse-grained soils.40 Disadvantages • According to the FRTR, factors that may limit the applicability and effectiveness of the process include: › Complex waste mixtures (e.g., metals with organics) make formulating washing fluid difficult. › High humic content in soil may require pretreatment. › The aqueous stream will require treatment at demobilization. › Additional treatment steps may be required to address hazardous levels of washing solvent remaining in the treated residuals.41 Costs Soil quantity and treatment speed are the key drivers in adopting this technology. Based on the cost analysis developed in 2006 using the Remedial Action Cost Engineering and Requirements software published by the FRTR, it is estimated that, through soil washing technology, the cost of remediating a small site would be around US$187 per cubic meter and a large site would be about US$70 per cubic meter. 4.3.4 ELECTROKINETIC SEPARATION The Electrokinetic Separation process removes metals and organic contaminants from low permeability soil, mud, sludge, and marine dredging. It uses electrochemical and electrokinetic processes to desorb, and then remove, metals, and polar organics. This in situ soil processing technology is primarily a separation and removal technique for extracting contaminants from soils. The FRTR provides the following description of Electrokinetic Separation: The principle of Electrokinetic Remediation (ER) relies upon application of a low-intensity direct current through the soil between ceramic electrodes that are divided into a cathode array and an anode array. This mobilizes charged species, causing ions and water to move towards the electrodes. Metal ions, ammonium ions, and positively charged organic compounds move towards the cathode. Anions such as chloride, cyanide, fluoride, nitrate, and negatively charged organic compounds move towards the anode. The current creates an acid front at the anode and a base front at the cathode. This generation of acidic condition in situ may help to mobilize sorbed metal contaminants for transport to the collection system at the cathode. The two primary mechanisms transport contaminants through the soil towards one or the other electrodes: electromigration and electroosmosis. In electromigration, charged particles are transported through the substrate. In contrast, electroosmosis is the movement of a liquid containing ions relative to a stationary charged surface. Of the two, electromigration is the main mechanism for the ER process. The direction and rate of movement of an ionic species will depend on its charge, both in magnitude and polarity, as well as the magnitude of the electroosmosis-induced flow velocity. Non-ionic species, both inorganic and organic, will also be transported along with the electroosmosis induced water flow.42 Advantages • Being an in situ technology avoids the efforts and costs related to the excavation and transportation of contaminated soil. • The ability to treat a wide range of contaminant concentration levels in soil. • Efficacy in treating soil with low permeability, which is difficult to treat with many other in situ technologies. 40 https://www.frtr.gov/matrix2/section4/4-19.html. 41 https://www.frtr.gov/matrix2/section4/4-19.html. 42 https://www.frtr.gov/matrix2/section4/4-4.html. 55 Conflict Pollution in Iraq Disadvantages • According to the FRTR: › Effectiveness is sharply reduced for wastes with a moisture content of less than 10 percent. Maximum effectiveness occurs if the moisture content is between 14 and 18 percent. © MoE and RSK LLC › The presence of buried metallic or insulating material can induce variability in the electrical conductivity of the soil, therefore, the natural geologic spatial variability should be delineated. Additionally, deposits that exhibit very high electrical conductivity, such as ore deposits, cause the technique to be inefficient. › Inert electrodes, such as carbon, graphite, or platinum, must be used so that no residue will be introduced into the treated soil mass. Metallic electrodes may dissolve as a result of electrolysis and introduce corrosive products into the soil mass. › Electrokinetics is most effective in clays because of the negative surface charge of clay particles. However, the surface charge of the clay is altered by both charges in the pH of the pore fluid and the adsorption of contaminants. Extreme pH at the electrodes and reduction-oxidation changes induced by the process electrode reactions may inhibit ER’s effectiveness, although acidic conditions (i.e., low pH) may help to remove metals. › Oxidation/reduction reactions can form undesirable products (e.g., chlorine gas).43 Costs As per the analysis done by the FRTR: Costs will vary with the amount of soil to be treated, the conductivity of the soil, the type of contaminant, the spacing of electrodes, and the type of process design employed. Ongoing pilot-scale studies using “real-world” soils indicate that the energy expenditures in extraction of metals from soils may be 500 kilowatt hours/m3 or more at electrode spacing of 1.0 m to 1.5 m. Direct costs estimates of about US$15/m3 for a suggested energy expenditure of US$0.03 per kilowatt hours, together with the cost of enhancement, could result in direct costs of US$50/m3 or more. A recent study estimated full scale costs at US$117/m3. If no other efficient in situ technology is available to remediate fine-grained and heterogeneous subsurface deposits contaminated with metals, this technique would remain potentially competitive.44 4.3.5 SOIL VAPOR EXTRACTION Soil vapor extraction is a remediation technology that extracts vapors from the soil above the water table by applying a vacuum to pull the vapors out. The technology involves drilling one or more extraction wells into the contaminated soil to a depth above the water table, which must be deeper than three feet below the ground surface. Attached to the wells is equipment (such as a blower or vacuum pump) that creates a vacuum. The vacuum pulls air and vapor through the soil and up the well to the ground surface for treatment. The basis of Soil Vapor Extraction can also be understood as follows: The technology is based on mass transfer of contaminant from the solid (sorbed) and liquid (aqueous or non-aqueous) phases into the gas phase, followed by collection and extraction of the contaminated soil gas. Extracted contaminant mass in the gas phase (and any condensed liquid phase) is then treated in above ground systems. The technology is most effective for contaminants with higher Henry’s Law constants, including a range of chlorinated solvents and petroleum hydrocarbons. It is not effective for remediating heavy metal impacted sites. The technology is a well-demonstrated, mature remediation technology that has been identified by the US EPA as a presumptive remedy.45 43 https://www.frtr.gov/matrix2/section4/4-4.html. 44 https://www.frtr.gov/matrix2/section4/4-4.html. Land Remediation for Livelihoods Restoration 56 Advantages • As an in situ technology, it avoids the effort and costs related to the excavation and transportation of contaminated soil. • Very effective in removing volatile contaminants, such as Petroleum Hydrocarbons • Relatively simple and well established. Disadvantages • Requires a secondary process (for example, granular activated carbon) to treat the volatile contaminants extracted from the subsurface in the vapor phase. • Effectiveness diminishes over time as readily extracted contaminant mass is removed. • At decreased contaminant levels, mass transfer limitations begin to control the recovery of remaining contaminant mass. Costs The key drivers of soil vapor extraction cost are quantity of soil to be treated and the speed of treatment. The cost can be radically different if no airflow treatment is required at a site. Based on the cost analysis developed in 2006 using the Remedial Action Cost Engineering and Requirements software published by the FRTR, it is estimated that the cost of remediating a small site would be around US$1,275 per cubic meter for an easy site to US$1,485 per cubic meter for a difficult site. A large site would cost about US$405 per cubic meter for an easy site and US$975 per cubic meter for a difficult site.46 4.3.6 LANDFARMING The process and aftermath of Landfarming can be laid out as follows: Landfarming is a well proven ex-situ bioremediation technology that has been successfully used since the 1980s for treating petroleum impacted soils/sediments, drill cuttings, low brine drilling fluids, oily sludges, tank bottoms and pit sludges. The material to be treated is incorporated into surface soil. Naturally occurring microbes in the soil and waste material transform the organic contaminants to carbon dioxide, water and biomass. Maintaining optimum soil conditions for rapid biodegradation of organic contaminants can help meet clean-up goals within a reasonable timeframe. During landfarming, the waste materials are typically placed as a layer on the ground surface with variable thickness. The waste is then tilled and amended with nutrients to enhance biodegradation by naturally occurring bacteria. Fertilizers such as urea and triple superphosphate are used to provide nitrogen and phosphate necessary for biodegradation. Reduction in hydrocarbon concentrations can be expected within a span of weeks to months, depending on the initial concentration and composition of hydrocarbons, and whether the soil conditions are optimized for biodegradation. Once clean-up goals have been achieved, the treated material can be i) re-used in construction activity such as berms, landfill cover, backfill, re-grading, or for agricultural purposes, ii) disposed at a landfill and/or iii) left in place and revegetated, depending on local regulations or site-specific considerations.47 © Adobe Stock 45 https://www.enviro.wiki/index.php?title=Soil_Vapor_Extraction_(SVE). 46 https://www.frtr.gov/matrix2/section4/4-7.html. 47 https://www.enviro.wiki/index.php?title=Landfarming. 57 Conflict Pollution in Iraq Advantages • The FRTR describes landfarming as a low-cost technology, adding that “facilities are simple to construct and easy to operate. Standard construction and farming equipment can be used to move soils to the land treatment facility, to amend the soils with fertilizer, to apply water to the soils and to till the soils (e.g., excavator, plough, rotovator, water truck)”.48 © MoE and RSK LLC Disadvantages • The limitations of landfarming are as follows: › It requires a large land area for treatment. › There may be regulatory limitations on wastes that can be treated by landfarming. For example, U.S. regulations prevent landfarming soil impacted with hazardous wastes such as motor oil, hydraulic oil, and solvents. › It may not be effective for highly impacted soils or soils impacted with severely degraded hydrocarbons (e.g., if soils contain >8% w/w petroleum hydrocarbons after spreading). › Although landfarming is effective for reducing hydrocarbon concentrations, it is not effective for reducing concentrations of other oil field waste components, such as elevated concentrations of metals, salt or wastes containing naturally occurring radioactive materials... › Concentration reductions >95% or final concentrations <0.1% may not be successfully obtained based on the extent impacted and nature of the hydrocarbons. › Dust and vapor emissions may pose air quality concerns.49 Costs Costs for landfarming are typically below US$100 per cubic meter of soil to be remediated.50 4.3.7 NATURAL SOURCE ZONE DEPLETION Natural Source Zone Depletion (NSZD) is a term used to describe “the collective, naturally occurring processes of dissolution, volatilization, and biodegradation that result in mass losses of light non-aqueous phase liquid (LNAPL) petroleum hydrocarbon constituents from the subsurface”.51 The passage below explains why NSZD is gaining traction as an option for remediating petroleum hydrocarbon sites: [With NSZD,] much higher source attenuation rates are now being measured compared to previous rates based on incomplete conceptual models. NSZD processes occur at most petroleum release sites and quantifying NSZD rates is an important part of an overall site remediation strategy. After a release into the environment, petroleum hydrocarbon constituents in LNAPL undergo various different degradation processes including dissolution, volatilization, and biodegradation. NSZD processes occur naturally within LNAPL-impacted zones in the subsurface. These processes physically degrade the LNAPL by mass transfer of chemical components to the aqueous and gaseous phases where they are biologically broken down via anaerobic and aerobic biodegradation. Traditional methods of NSZD monitoring have focused on the groundwater transport of the solubilized LNAPL constituents and aqueous phase biodegradation that occurs through various terminal electron acceptor processes. Aerobic respiration, denitrification, sulfate reduction, iron and manganese reduction, and methanogenesis each support hydrocarbon degradation as the supply of each electron acceptor (e.g., dissolved oxygen, nitrate, sulfate), oxidation-reduction state, and the microbiological conditions allow. These processes manifest themselves as decreases in dissolved electron acceptor concentrations and production of soluble by-products such as ferrous iron, dissolved methane, and carbon dioxide. Through stoichiometric conversion of the mass of electron acceptor loss and by-product formation, the soluble or aqueous contribution to NSZD can be estimated.52 48 https://www.enviro.wiki/index.php?title=Landfarming. 49 https://www.enviro.wiki/index.php?title=Landfarming. 50 https://www.frtr.gov/matrix2/section4/4_13a.html. 51 https://www.enviro.wiki/index.php?title=Natural_Source_Zone_Depletion_(NSZD). 52 https://www.enviro.wiki/index.php?title=Natural_Source_Zone_Depletion_(NSZD). Land Remediation for Livelihoods Restoration 58 Advantages • NSZD is a low-cost technology because it uses naturally occurring processes to treat contaminants. • Little or no engineering effort is required. Disadvantages • NSZD is used for petroleum hydrocarbon but does not work for heavy metals. • Sophisticated monitoring is required to estimate the NSZD rate before it can be demonstrated as an effective remediation technology at any specific site. • Other previously established limitations include: › NSZD occurs at most petroleum release sites. However, site-specific conditions will drive the magnitude of rates. › NSZD rates measured using the methods described above quantify total hydrocarbon mass loss and do not speciate loss or degradation rates of individual chemicals such as benzene or naphthalene from soil or LNAPL phases. › NSZD can fluctuate seasonally with change in ambient temperature which may induce cold/warm temperature cycles in the subsurface and also fluctuate with changes in surrounding water use.53 Costs NSZD is a relatively low-cost technology. It is assumed that a detailed Conceptual Site Model is available and, therefore, the nature and extent of contamination, hydrogeology, lithology, and other site-specific conditions are relatively well understood. Similar to monitored natural attenuation, primary costs are associated with sampling and analyses. 4.4 Factors influencing technology selection and applications Various successful technologies are available for contaminated site remediation. These technologies have different mechanisms for treating contaminants and each has its own strengths and limitations. However, there is no “silver bullet” in contaminated site remediation. No single technology can be applied to all contaminated sites due to the complex nature of contamination and site conditions. Instead, a site-specific feasibility study should be conducted to evaluate and select the most appropriate remediation technology for a particular site. This feasibility study should consider the following key factors that may influence technology selection and applications: • The characteristics of contamination • Distribution of contaminants • Property of the impacted media. The characteristics of contamination When selecting remediation technologies, the first consideration is the type and properties of contaminants identified at a site. The contaminants can be generally separated into four groups: • Metals and metalloids, organometallic pesticides, and herbicides • VOCs such as Petroleum Hydrocarbons, chlorinated VOCs, Benzene, Toluene, Ethylbenzene, Xylene, and other non-halogenated VOCs • SVOCs, such as Polychlorinated Biphenyl, Polycyclic Aromatic Hydrocarbons, organic pesticides and herbicides • Other compounds, such as Asbestos and non-metallic inorganics. Each of these contaminants have their own property that should be considered during remedial selection. For example, when applied properly, Soil Vapour Extraction and Thermal Desorption Technologies are highly effective for treating VOCs-impacted soil. These technologies are less effective for removing SVOCs (due to lower vapor pressure) or metals. 53 https://www.enviro.wiki/index.php?title=Natural_Source_Zone_Depletion_(NSZD). 59 Conflict Pollution in Iraq Distribution of contaminants The spatial and horizontal distribution of contaminants, contaminant concentrations, and identification of source zone and plume can play an important role in selecting a remediation technology that is most likely to be successfully applied. For instance, some technologies, such as thermal desorption, are more suitable for treating high contaminant source zones where much of the contaminant mass resides. By contrast, thermal desorption is less efficient at treating low-level contaminant plumes due to the high operation and maintenance costs. Property of the impacted media The physical properties of the soil in which contaminants are present, and through which they may be moving, should be considered during technology selection. Examples of these properties include soil type, dry bulk density, permeability, hydraulic conductivity, the organic carbon content, porosity, field descriptions from boring logs, heterogeneities within the soil column, the existence of a smear zone, and the depth to groundwater and/or bedrock. Many in situ technologies rely on injecting remedial agents (either oxidants or reductants) to the subsurface to mix with contaminants or contaminant-affected media, which would prove challenging for soil formations that have low permeability, such as clay or silt. 4.5 Criteria for remediation technology selection The US EPA has developed nine criteria for evaluating remedial alternatives that ensure the inclusion of all key factors in selecting a suitable remediation technology and during the feasibility study stage. The criteria stem from both the statutory requirements of environmental laws and the technical and policy considerations that have demonstrated importance in selecting remediation technologies. The MoE may wish to consider adopting or developing similar criteria for determining appropriate remediation technologies. The nine evaluation criteria can be categorized into three groups based on their significance: threshold criteria, primary balancing criteria, and modifying criteria (see detailed discussion below). Threshold criteria The first step in selecting a remediation technology is to identify the alternatives that satisfy the threshold criteria. To be eligible for selection, an alternative that does not justify a waiver must provide adequate protection to human health and the environment and comply with Applicable or Relevant and Appropriate Requirements (ARARs). Ineligible options should not be evaluated further. Threshold criteria are typically as follows: • Overall protection of human health and the environment: • Assessment of compliance: This determines whether a This addresses whether a remedy will provide adequate remedy will fulfil the ARARs of various levels of environmental protection and how the risks posed through each exposure laws, or whether a waiver can be justified. Examples of ARARs pathway (assuming a reasonable maximum exposure) will include air-discharge-permit requirements and wastewater- be eliminated, reduced, or controlled through treatment, discharge permit requirements. engineering controls, or institutional controls. Primary balancing criteria The second step assesses the trade-offs between protective and ARAR-compliant alternatives by focusing on the five primary balancing criteria and, if known, the modifying criteria. The five primary balancing criteria are: • Long-term effectiveness and permanence. • Reduction in toxicity, mobility, or volume achieved through treatment. • Short-term effectiveness. • Implementability. • Cost. © MoE and RSK LLC These five primary balancing criteria are used to identify the major trade-offs between remedial alternatives, which are ultimately balanced to identify the preferable alternative and select the final remedy. The sequence in which the criteria are generally considered, and pertinent considerations related to each, is as follows: 1 Long-term effectiveness and permanence refer to the 4 Implementability refers to the technical and administrative ability of a remedy reliably protect human health and the feasibility of a remedy, including the availability of environment over time once clean-up goals have been materials and services needed to implement a particular met. During remedy selection, this criterion is crucial option. This criterion is important in the context of Iraq for determining the extent to which performance and as some remediation materials or equipment may not treatment are practicable. This factor is often determined be readily available. It is also a key factor in evaluating by the types of residuals that will remain on site remedies at sites with highly heterogeneous wastes per alternative. or media that could make the performance of some technologies highly uncertain. Lastly, implementability is also crucial when evaluating technologies with lower 2 Reduction of toxicity, mobility, or volume through scientific backing and remedies that are dependent on a treatment refers to the anticipated performance of the limited supply of equipment, experts, or facilities such as treatment technologies that a remedy may employ. This permitted hazardous waste disposal facilities. criterion is also crucial in determining the extent to which performance and treatment of a remedy are practicable. Remedies that address the most threatening materials 5 Cost includes estimated capital costs, operation and at a site are preferred over those that do not. Treatment maintenance costs, and the net present value of capital. should generally achieve reductions of 90 to 99 percent in Cost plays a significant role in selecting between the concentrations or mobility of individual contaminants options that appear to be comparable in criteria (such of concern. There will, however, be situations where as long-term effectiveness and permanence) or when reductions outside the 90 to 99 percent range will be choosing between treatment technologies that provide appropriate to achieve site-specific remediation goals. similar performance. Cost generally will not be used to determine whether or not principal threats will be treated except under special circumstances that make treatment 3 Short-term effectiveness addresses the time impracticable. Cost is generally not being used to select required to achieve protection of human health and a remedy that is not protective. the environment, as well as any threats that may arise during the construction and implementation period until clean-up goals are met. Many potential adverse impacts can be avoided by incorporating mitigative steps into the remedial alternative. Poor short-term effectiveness may lead to an alternative being rejected on the basis of being unprotective if adverse impacts cannot be adequately mitigated. Modifying criteria These criteria may not be considered fully until after the former public comment period of the proposed remedial plan although the US EPA works with the State and community throughout the project. • State acceptance refers to the support agency’s comments where a state/local or federal/national agency is the lead agency. The US EPA’s (the national agency’s) acceptance of the selected remedy is also required to meet this criterion, while doing so, the state agency’s views on compliance with ARARs shall also be considered. • Community acceptance refers to the public’s general response to the remedial alternatives that were selected in the proposed plan. 61 Conflict Pollution in Iraq Summary Once the relative performance of the protective and By balancing the trade-offs between the remedial alternatives ARAR-compliant remedial alternatives under each criterion with respect to the balancing criteria (and, if known, the modifying has been established, the preferred alternatives are chosen by criteria), a decisionmaker can make a risk-management decision identifying which are cost-effective and use permanent solutions to determine which cost-effective alternatives use permanent that provide treatment to the maximum extent practicable. Cost- solutions and treatment to the maximum extent practicable. effectiveness is determined by comparing the alternatives’ costs As a general rule, the criteria that varies the most between with their overall effectiveness. Overall effectiveness, for the alternatives will also be the most decisive factors in the balancing. purpose of this determination, includes long-term effectiveness Ultimately, the preferred alternative will provide the best balance and permanence; reduction of toxicity, mobility, and volume through of trade-offs as considered in light of the statutory mandates, treatment; and short-term effectiveness. It is possible that more than preferences, and expectations. one alternative can be cost-effective. 4.6 Conclusion Reviewing the above four critical elements of remediation technologies underscores the importance of remediation approaches, the range of available technologies, factors that influence the selection of technologies, and the established selection criteria. Evaluating these elements and consulting stakeholders will be crucial in the development of remediation programs in Iraq. © Adobe Stock Land Remediation for Livelihoods Restoration 62 5 Roadmap for Contaminated Sites Management 5.1 Need for a national program Analysis of environmental hotspots (contaminated sites) in seven conflict affected governorates of Iraq indicates significant hydrocarbon and chemical contamination in the country. With the support through this ASA, MoE screened 216 sites and identified 76 ‘suspected hotspots.’ Initial assessment of 69 of these hotspots spread over 47 locations, estimated that about 1333.03 ha of land is likely to have been contaminated affecting an estimated 55,050 people directly and over 1.70 million people indirectly. Environmental analysis of the soil and water at these sites further identified that the contamination levels exceeded 100 times the DIV in 32 sites and, 50 times the DIV in 7 sites and 10 times the DIV in the remaining 30 sites. Land use analysis around these sites through satellite imagery further indicated that over 1,569 ha of agriculture land, about 3,018.38 ha of vegetation, about 8.482 structures and 20 industrial units are impacted due to the damages and contamination at these hotspots. Among these nine major industries are completely damaged and are currently not in operation. A preliminary and conservative estimate of HEAL impacts (burden of disease, lost industrial productivity, lost agriculture yield and industrial and agriculture jobs lost) indicates that about US$1.44 billion dollars is lost every year due to contamination of the hotspots. While this ASA has focused on seven governorates, it is possible that there are additional pollution hotspots in the remaining 12 governorates. Given Iraq’s industrial profile, these hotspots may be due to industrial activities rather than conflicts. However, identifying and managing all pollution hotspots, regardless of the underlying cause, is important for the country’s post-conflict reconstruction because revitalizing the environment and natural resources is essential for the resilient, sustainable, and enhanced economic advancement of Iraq. Importantly, managing pollution will reduce risks to human health and enable internally displaced people to go back to their lands and return these lands back to a productive state, ultimately lowering the risk of conflict over land and other natural resources. The Government of Iraq, and the MoE in particular, is responsible for identifying and managing contaminated sites in Iraq. The MoE’s capacity is, however, limited, and effectively managing geographically dispersed contaminated sites across large and often hazardous landscapes can be challenging. The remediation or management of contaminated sites requires a well-developed legal and institutional framework and adequate financial resources. Given these conditions, Iraq would benefit from establishing a National Program on Contaminated Sites Management (NPCSM) to help the MoE to prioritize sites based on quantitative analysis and manage them effectively, so contributing to other benefits such as agriculture productivity, livelihood opportunities, and local economic development. This section presents a recommended roadmap for developing such a national program and details its key components. 9 UNEP 2005. 10 UNEP 2007. 11 UNEP 2018a. 12 MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. 63 Conflict Pollution in Iraq 5.2 Objectives The overarching objectives of the recommended NPCSM should ideally be to: • Eliminate or minimize threat to human health and the environment caused by the existing or potential discharge of hazardous substances from contaminated sites, so as to contribute to Iraq’s post-conflict socioeconomic recovery. • Proactively identify and prioritize contaminated sites, investigate all identified sites and, where contamination exists, remediate the sites by applying sustainable and risk-based land management or another suitable approach that follows international good practices and tailored to Iraq’s context. • Use post-remediation measures and site restrictions where contamination cannot be fully removed. • Enhance the Government of Iraq’s capacity to implement a successful national program by addressing current gaps in legislation; conducting an economic valuation using quantitative analysis; attracting sustainable sources of adequate financing; ensuring adequate and appropriately skilled personnel; and by ensuring appropriate infrastructure for the MoE and its team. These objectives should ideally be achieved by applying appropriate international guiding principles. 5.3 Guiding principles The guiding principles recommended for the recommended NPCSM are sustainable, informed by risk, and based on international good practice in contaminated site management.54,55 They are: Principle 1: Protection of human health and the wider environment and maximize socio-economic outcomes The main aim of NPCSM should be to eliminate unacceptable risks to human health and to protect the wider environment, now and in the future, for the agreed land use with due consideration to the costs, benefits, effectiveness, durability, and technical feasibility of the available options. To ensure this, the decisions on affected sites should be based on quantitative analysis of information to maximize environmental, economic, and social outcomes. Principle 2: Reliance on sound technical analysis and relevant and accurate data Decisions on managing contaminated sites should be based on sound technical analysis with clearly explained assumptions and uncertainties related to data and professional judgement. All efforts should be made to carry out necessary studies and assessments ensuring adherence to this principle so that the decisions are based on the best available information and datasets; are justifiable; and are reproducible. Principle 3: Risk-based decision-making should focus on HEAL impacts and outcomes All decision on the management or remediation of contaminated sites should be consistent, clear, and based on objective rationale that consider the HEAL impacts of a particular site; the socioeconomic and environmental conditions; and both current and likely future implications. Such sustainable and risk-based remediation solutions maximize the potential benefits achieved given available public resources. Where benefits and impacts are aggregated or traded in such a way that the process is explained, and a clear rationale is provided. Principle 4: Good governance and stakeholder engagement Remediation decisions should be made with the active participation of stakeholders through a transparent and inclusive process. 54 World Bank 2019. 55 CL:AIRE 2010. Land Remediation for Livelihoods Restoration 64 Principle 5: Safe working practices Throughout the process of identifying, assessing, and managing or remediating contaminated sites, safe working practices should be followed. Risks to the teams working at contaminated sites and local communities should be avoided and minimized. Principle 6: Transparent reporting and record-keeping Remediation decisions, including the assumptions and supporting data used to reach them, should be documented in a clear and easily understood format in order to demonstrate that a sustainable solution has been adopted. Regular updates on the progress of implementing remediation or management measures and the achievement of outcomes shall also be shared, in a transparent manner, with all stakeholders with an opportunity to provide feedback. 5.4 Characteristics of a National Program for Contaminated Sites Management Once fully implemented, a successful NPCSM would include:56 • An efficient and effective mechanism to report suspected › Detailed site investigations (including health and environmental contaminated sites. assessments as well as cost of environmental degradation) and • A GIS-based national inventory of contaminated sites that remediation for priority contaminated sites are completed within can be updated regularly. six months of completion of an initial assessment. • Processes are in place to ensure that: › Remediation of contaminated sites is initiated within › Any new site in the inventory is screened, assessed. and an 12 months of such site being included in the priority list of sites initial assessment is conducted within one month from the date for remediation. of identification or receipt of a notification. Where there is high › More than 90 percent of remediated sites that are suitable probability that a site poses a significant and immediate threat are put to productive reuse within two years of completion of to human or environmental health, an initial site assessment remediation and post remediation measures. is completed within one week from notification. • Polluters remediate polluted sites and pay for all costs in › Detailed assessment is carried out for sites where initial more than 50 percent of remediation cases. assessment has identified a high likelihood of an immediate and significant threat to human or environmental health. Interim measures to limit exposure or spread of contamination are also implemented within two weeks of completing the initial assessment. 5.5 Roadmap for developing a national program The following roadmap sets out potential steps for the Government of Iraq to follow towards developing a potential NPCSM. The steps are cross-cutting and relate to all four key stages of contaminated site management, namely, identification; planning and prioritization; implementation; and post-remediation monitoring. Interventions are proposed under three key themes, namely, legislation and policy; institutional capacity; and financing. These are followed by additional interventions relating to stakeholder engagement and the implementation of pilot projects. 56 Specific targets mentioned for each indicator are indicative and shall be finalized by the Government of Iraq as part of the overall NPCSM preparation process. 65 Conflict Pollution in Iraq 5.5.1 ENHANCING THE LEGAL AND POLICY FRAMEWORK As discussed earlier, although the Protection and Improvement This works in tandem with the Comprehensive Environmental of the Environment Law 27 of 2009 includes requirements for Response, Compensation, and Liability Act (the Superfund preventing pollution and includes the “polluter pays” principle, Law)58 to give federal authorities in the United States the power neither this nor any other national legislation explicitly to remediate certain categories of contaminated sites describes requirements or obligations for the and ensure the cooperation of responsible parties. management of contaminated sites. Moreover, The Superfund Law also established a National there is no specific requirement to establish Priorities List, a list of national priority sites with a national register of contaminated sites. known or threatened releases of hazardous The absence of national determinants of substances, pollutants, or contaminants. This contaminated soil also represents a major law further created a trust fund (financed by a constraint to the MoE’s efforts to identify tax on the chemical and petroleum industries) and manage contaminated sites. This lack for the remediation of abandoned or uncontrolled of standards and guidelines on contaminated hazardous-waste sites. sites complicates efforts to develop a © MoE and RSK LLC regulatory framework. Similarly, South Africa has the National Environmental Management: Waste Act,59 which The Government of Iraq can draw on several international includes specific, comprehensive “contaminated land examples to enhance national legislation for contaminated provisions” that define contamination and specify requirements site management. For example, the United States has a suite for reporting, assessing, and managing of suspected of legislations related to this issue, including the Resource contaminated sites. The act also includes a requirement to Conservation and Recovery Act,57 which gives the US Environment establish a national contaminated land register. In parallel, the Protection Agency the authority to manage environmental National Water Act specifies requirements for contaminated pollution originating from underground storage tanks. water resources. Recommended actions Establish a technical advisory group and a stakeholder platform to support and inform the design, development, 1 and implementation of an NPCSM. The first step to comprehensively address the issues of contaminated hotspots is to establish the following: • A technical advisory group comprising relevant government, academic, and internal experts. This group should lead the review and implementation of actions recommended in this roadmap. • A stakeholder platform comprising various CSOs and other national and local stakeholders who are well positioned to contribute to hotspot management efforts. 2 Develop a contaminated site management policy (or incorporate relevant considerations into appropriate existing policy). This policy will form the foundation of the NPCSM on which all subsequent interventions will be based. It will include, among other things, objectives, targets, roles and responsibilities, and resource requirements. 3 Enhance existing provisions or promulgate legislation on contaminated site management. Conduct an in-depth review of existing regulations and identify opportunities to enhance or promulgate legislation on contaminated site management. This intervention will form the foundation for future actions aimed at strengthening the national approach to managing contaminated sites and should therefore be considered a high priority. Legislative enhancements would benefit from the following steps: • Establish international benchmarks and identify national legislative gaps. • Draft new or revised legislation and guidelines. • Promulgate and implement revised legislation. 57 42 U.S.C. §6901 et seq. (1976) as amended (1986). 58 42 U.S.C. §9601 et seq. (1980). 59 NEMWA. Act 59 of 2008. Land Remediation for Livelihoods Restoration 66 Establish international benchmarks and identify national legislative gaps An international benchmark for best practice should draw on assessments from developed and developing nations. This benchmark will form the basis of a comprehensive gap analysis on Iraq’s legislation for contaminated sites and can be used to inform a clear plan to address gaps or introduce enhancements. At minimum, legislation should include provisions to establish: • An NPCSM that covers all categories of contaminated sites, including orphan sites and those where contamination has resulted from conflict. This NPCSM should include a strategy to minimize risks to human health and the environment in the short term. It should draw on quantitative analysis to establish clear medium- and long-term objectives. • An inventory of contaminated sites and associated minimum requirements and update it on ongoing basis. • A mechanism for the adequate and sustainable financing of the NPCSM, including orphan sites and those where contamination has resulted from conflict. • A national definition for contaminated land, water, and ecosystems, and associated remediation targets depending on future land and resource use. • National technical guidelines on the approach to contaminated site management and implement them. Draft new or revised legislation and guidelines This will involve drafting new legislation and guidelines for contaminated site management or addressing gaps by amending existing legislation. This process will involve extensive consultation with a wide range of stakeholders from the Government of Iraq, the private sector, and others to ensure that revised legislation reflects, to the extent practical, the long-term interests of all. Preparing clear technical guidance documents will facilitate communication and interpretation of the revised or new legislation and promote uniform implementation. Promulgate and implement revised legislation Full implementation of the amended or new legislation is likely to take time. However, appropriate legislation is a key catalyst for realizing the subsequent objectives set out below. Technical guidelines should be made available at the same time that legislation changes are made. 4 Develop national standards and guidelines for remediation. National standards (screening levels) provide a consistent tool for defining, assessing, and prioritizing contaminated sites. The following standards and guidelines are recommended: • A national standard or screening levels for contaminants • National guidelines for risk assessment. National standards or screening levels for contaminants Screening levels are chemical-specific concentrations for individual contaminants (in soil, groundwater, drinking water or other mediums) and are used to decide which sites are “clean” and no further action is required, versus those that require additional investigation and remediation. In line with international best practice,60 the national standard should consider the risks the site poses to human health and the environment health, as well as the proposed land use. 60 Refer to approaches employed by the USA EPA, South Africa (National Norms and Standards for the Remediation of Contaminated Land and Soil Quality, 2014), and China (Health & Environmental Risk Assessment approach). 67 Conflict Pollution in Iraq National guidelines for risk assessment National guidelines for risk assessment seek to embed a risk-based approach to carrying out site assessments, to developing management or remediation plans, and to estimating costs so as to ensure the protection of human health and the environment. Such guidelines allow for a site to be remediated to a level that matches the future intended land use, whether this be industrial, commercial, or high-density residential use. 5.5.2 ENHANCING INSTITUTIONAL CAPACITY AND PLANNING The absence of a systematic approach to managing contaminated Iraq’s existing laboratory facilities are understaffed and lack sites and a lack of sufficient trained personnel and technical adequate, fully operational equipment to support efforts to facilities are key constraints to implementing an NPCSM in Iraq. investigate and manage a large number of contaminated sites Although the exact shortfall in capacity is unknown, a larger cohort across the country.61 of trained personnel with appropriate and diverse technical skills will be required at both the national and the governorate level Chain-of-custody and quality assurance are also essential to implement identification, planning, implementation, and post- components of managing contaminated sites. Iraq’s Central remediation monitoring. Enhanced legislation for contaminated Environmental Laboratory does not yet hold any quality assurance site management will also likely lead to an increase in the need certification (for example ISO 17025). Although private laboratories for personnel to enforce such legislation. could be used for analysis of environmental samples, this is unlikely to be cost-effective in the long term. Recommended actions 1 Carry out a comprehensive analysis of national capacity needs. The objective of this analysis is to identify gaps between existing human and laboratory resources and the resources that will be required to implement the NPCSM over the short, medium, and long term. The analysis of human resources should consider the number and geographical distribution of personnel as well as the skills required. The potential for outsourcing certain functions to external service providers and minimum requirements for their accreditation should also be considered. The analysis of laboratory facilities and equipment could draw on previous assessments but should also reflect the current situation and the NPCSM’s specific requirements. Quality assurance at laboratories and relevant certification should also be included in this assessment. 2 Develop and implement a clear, time-bound resourcing plan to close gaps in internal capacity. This plan should be based on the findings of the above-mentioned capacity needs analysis and is likely to involve a combination of new recruitment and building capacity through training. A detailed budget should be included in the plan. 5.5.3 ALLOCATING BUDGET AND SECURING FINANCING The total cost of implementing an NPCSM is difficult to estimate because it depends on a wide range of factors including the program’s final contours, site-specific factors for remediation, and the overall approach for the management of contaminated sites. However, based on the key elements of the program detailed in this section and the information contained in the hotspots inventory developed by the MoE, implementation it is broadly estimated that the implementation of NPCSM could cost about US$422 million (Table 15). 61 UNEP 2018b. Land Remediation for Livelihoods Restoration 68 Table 15: Indicative budget for implementing remediation program Program component Estimated cost (US$) Program development, legal, and technical studies 2,000,000 Site inventory (100 sites). Assessment and plan preparation (75 sites) 10,000,000 Implementation of remediation plan and post-remediation monitoring (50 sites) 400,000,000 Laboratory equipment, GIS, IT, and other infrastructure (lump sum) 3,000,000 Capacity-building and training (lump sum) 2,000,000 Project management and operating costs (US$1 million per year for five years) 5,000,000 Total budget 422,000,000 Source: Estimates by the ASA team. The following key assumptions were used in arriving at this cost: • NPCSM implementation period: five years • Program development, legal, and technical studies: 10 studies at US$200,000 each (based on cost of studies carried out in the current ASA) • Inventory, site assessment studies, and health and environmental impact assessments: 100 sites at US$25,000 each (based on the costs incurred on assessments carried out in the current ASA) • 75 percent of identified hotspot sites (based on the current inventory) would likely require detailed investigation and remedial plan preparation: 75 sites at US$100,000 (ASA team’s professional judgement based on similar assessments internationally) • 50 percent of identified hotspot sites will require remedial action: 50 sites at US$8 million each (broad cost estimate based on technologies reviewed). The Government of Iraq would need to increase the MoE’s incentives and funds. Economic and financial instruments, such as budgetary allocation to enable it to implement the NPSCM. environmental taxes; clean-up subsidies; and loans, guarantees, Alternatively, external financing may be sought. and market licences can also be considered. In addition, the mechanism for managing these funds needs to address National legislation requires polluters in the oil and gas existing challenges, including a lack of understanding sector to pay for the remediation of contamination amongst officials of the costs of contaminated site resulting from their activities and allows for the management, and governance of the fund. establishment of an Environmental Protection Fund. However, the long-term sustainability of Experience in Europe and the United States this source of funding, as well as its adequacy also shows that the private sector could play for implementing a systematic NPCSM, is a role in remediating and reactivating the nine uncertain. The extent to which these funds destroyed industrial units (the “brownfield can be deployed for the remediation of sites remediation” model). This approach would contaminated due to conflict also needs to provide the twin benefits of addressing site be evaluated. contamination and contributing to the economy © MoE and RSK LLC by way of industrial rejuvenation. As noted in The experience of the United States and other Section 2.4 of this report, reactivating the four countries shows that it is important that sustainable damaged industrial units (where it was possible to estimate) funding mechanisms are established for contaminated site clean- could contribute about US$1.17 billion per year to the economy. This up activities in order to accelerate remediation activities for the most is a strong factor for exploring the participation of the private sector urgent sites.62 The financing mechanism may include economic in the remediation of contaminated sites. 62 The US government established a Superfund program that is funded through a combination of appropriations from the US Congress and a tax on certain industries, including the chemical, petroleum, and manufacturing sectors. The tax is used to create a trust fund, known as the Superfund Trust, which is used to pay for the cleanup of hazardous waste sites that are not covered by responsible parties. Recommended actions 1 Review existing funding and benchmarking. The adequacy of existing national funding mechanisms for contaminated site management should be reviewed to confirm adequacy and identify gaps relating to implementing an NPCSM. This review should consider: • The expected value of the fund over time versus the predicted costs of the NPCSM • The long-term sustainability of existing revenue streams of the fund • The governance of the fund • Permitted activities supported by the fund • The effectiveness of the “Polluter Pays” Principle • Alternative options to increase the size and reliability of the Fund • The potential role of the private sector in remediation activities and reactivating the destroyed industrial units. This review should draw on experiences from other countries and benchmark in the context of Iraq. 2 Implement a revised funding strategy. Based on the outcome of the review process, the next step is to develop and implement a clear plan to address gaps and shortcomings in the existing funding strategy for contaminated sites management. This intervention may require revision of existing legislation or introduction of new legislation. 5.5.4 STAKEHOLDER CONSULTATIONS Stakeholder consultations are critical for ensuring that knowledge This may be particularly relevant where contaminated sites and information is not missed, for providing engagement and are still in active use (for example at industrial facilities), close transparency, for supporting the development of policy, regulations, to residential areas, or where communities are currently using and guidance, and for developing sectoral awareness and know-how. contaminated resources (for example, contaminated water). As discussed, a key question is the extent to which the public will have Transparent regulatory procedures underpin the effective access to information on contaminated sites. The international prioritization of resources while optimizing the mitigation of trend is to exercise a high level of transparency, which involves harm and delivery of wider value. Monitoring and reporting on sharing information on contaminated sites through various public environmental policy effectiveness will allow the government to communication channels. manage and refine the guiding principles suggested in section 5.3 over the implementation period based on performance.63 The United States’ Superfund program encompasses extensive stakeholder engagement. Stakeholders, including communities, Internationally, the principle of stakeholder consultation is are proactively encouraged and supported in participating generally embedded within environmental legislation and features in all steps of the program. The goal of Superfund community prominently in the areas of Environmental and Social Impact involvement is to advocate and strengthen early and meaningful Assessment. These assessments are typically conducted prior community participation during clean-up projects, and the public to government approval for projects that could have negative is involved in reporting suspected contaminated sites, preliminary socioeconomic or environmental impacts. Stakeholders, including site assessments, and reviewing proposed plans for remediation the general public, are normally informed of the assessment of specific sites.64 Several mechanisms have been established in the early stages and are offered an opportunity to review specifically to aid meaningful involvement by the public including draft reports and mitigation plans in order to maximize the establishment of a Technical Assistance Services for Communities, likelihood that any decisions by authorities regarding a proposed which aims to assist communities to interpret information development project considers the interests of a broad range of about sites. The US EPA also develops a Community Involvement stakeholder groups. Plan once a contaminated site has been added to the National Priorities List and must also maintain a publicly available repository Similarly, engagement with stakeholders should be an important of information. Similar approach may also be considered by GoI, element of sustainable contaminated site management where as part of NPCSM Consultation with stakeholders was initiated as sharing information can help with the development of targeted part of the initial site assessment carried out by the MoE. Although legislation, the identification and prioritization of contaminated relatively limited, this served to demonstrate a collaborative, sites, establishing remediation targets, and so on. Sharing of inclusive, and transparent approach to managing contaminated information can also be important to protect communities from sites in the country. At this time, however, there is no regulation or harm until such time as contaminated sites can be remediated. framework outlining the nature of future stakeholder consultations within the context of contaminated site management in Iraq. 63 World Bank 2019. 64 https://www.epa.gov/superfund/superfund-community-involvement. Land Remediation for Livelihoods Restoration 70 Recommended actions 1 Develop a national framework for stakeholder engagement. The objective of a national framework would be to ensure that an inclusive, transparent, and consistent approach is applied to all elements of the NPCSM. In addition to the approach adopted by the Superfund program (see above), the MoE and other relevant parties could draw on approaches employed in other countries to develop a framework that is effective in terms of information-sharing and gathering while not being overly bureaucratic and resource-intensive. To the extent practical, the framework could align with existing national requirements for stakeholder consultations. The framework should include requirements and guidance on at least the following topics: • The objectives of stakeholder engagement within the context of the NPCSM • The requirements for stakeholder mapping at different levels (national, regional, site, and so on) and different elements of the NPCSM (in other words, site prioritization, site-specific remediation strategies, and so on). • Minimum requirements for sharing information, for example, the key steps of consultation, the type of information shared, stakeholder notification, the modes of communication, timing, review period feedback, and so on. • Reporting requirements, for example, annual reporting on NPCSM progress. 5.5.5 PREPARING THE NPCSM AND DEMONSTRATION REMEDIATION PROJECTS The policy, regulatory, institutional, and technical actions identified Considering this, and as a first step to develop NPCSM, it is in the sections above for the establishment of an NPCSM would recommended that a project that aims to carry out all critical studies require a number of preparatory studies, technical inputs, and required for the NPCSM and implement demonstration projects financial allocation by the Government of Iraq. Completing these at priority sites is initiated. The objective of the project would be actions and implementing the NPCSM would take a long time. In to prepare the NPCSM based on inputs from preparatory studies addition, many of these studies and assessments would require and actions recommended in 5.5.1 to 5.5.4 above and experience support from international agencies and experts. from demonstration projects. The following components may be considered for such a project. Component 1 Technical and regulatory studies and the development of an NPCSM. Component 2 Laboratory and technical capacity-building of the MoE. Component 3 Detailed assessment and remediation plans for very high-risk hotpot sites. Component 4 Detailed assessment and remediation plans for very high-risk hotpot sites. 71 Conflict Pollution in Iraq The advantage of such a project would be that it would allow to adopt or apply new guidelines or regulatory processes on for remediation plans to be implemented in a selection of high- actual remediation projects while practitioners can adopt and priority hotspots while a long-term NPCSM is being prepared. In apply investigation and remediation tools and technologies at addition to the project will demonstrate pro-activity on behalf of contaminated site, therefore enhancing in-country capacity the Government of Iraq and provides specific technical inputs for regarding contaminated site remediation and management. the development of NPCSM. The demonstration remediation projects can also help identify any problems or challenges that need to be addressed before a Since Iraq has limited experience in implementing remediation regulatory process or technology can be implemented on a large projects, information on the costs of, carrying out detailed scale. This can help ensure that any issues are identified and assessment studies, remediation plan preparation studies addressed early on, which can save time and resources in the (including Health and Environmental Impact Assessment), and long run. implementing various technologies is unknown. In addition, intervention values for soil and other technical standards are Demonstration remediation projects can also provide a safe not available in Iraq. Considering these factors, the detailed and controlled environment in which to test new processes and assessments (Component 3) and proposed demonstration approaches. This can help identify the strengths and weaknesses projects (Component 4) suggested in the project above will of different approaches and can inform decision-making about provide valuable inputs to the preparation of NPCSM. which approaches are most likely to be successful in the long term. The project would also help increase public understanding The project would also build Iraq’s capacity to remediate and and awareness of contaminated site management processes, manage contaminated sites through a learning-by-doing approach. procedures, and remediation technologies, and can build support The demonstration remediation projects would enable various for their implementation. government agencies, and possibly academia, the opportunity 5.6 Conclusion Based on the analysis of hotspots, their potential to cause health and environmental impacts, and a review of legal, institutional, and technological aspects related to contaminated sites, the ASA recommends establishing a National Program on Contaminated Sites Management (NPCSM). In the initial phase, the NPCSM is recommended for five years at an estimated cost of US$ 422 million. A roadmap comprising specific actions for policy, regulatory, institutional, and demonstration remediation projects is proposed. The actions recommended in the roadmap include developing a contaminated site management policy; promulgating legislation on contaminated sites; establishing standards for remediation; establishing an institutional mechanism supported by capacity-building measures; identifying financing mechanisms; and ensuring the participation of all government and community stakeholders in the NPCM. A project to implement the actions recommended for the development of an NPCSM, along with demonstration remediation projects, has also been recommended. Implementation of the project and roadmap actions will help better manage contaminated sites in Iraq. © Freepik Land Remediation for Livelihoods Restoration 72 Appendixes Appendix A: General profile of pollution hotspots in Iraq Table A1: General profile of pollution hotspots in Iraq Site Site Area (ha) Population Land use number description Direct Indirect Direct Indirect Direct Indirect Baghdad (6 sites) Lead Extraction Factory 1 3.20 12.56 230 1,500 Industrial Agricultural (08) 2 Ibn Sina Company (01) 3.14 12.56 200 1,500 Industrial Residential 3 Bader Company (02) 10.00 12.56 4,000 30,000 Industrial Residential That-Alsawary Company 4 0.30 3.14 1,000 7,000 Industrial Agricultural and village (03) 5 Ibn Al-Waleed (04) 1.00 3.14 500 3,500 Industrial Agricultural and village 6 Al-Harith Factory (06) 10.00 12.56 5,000 35,000 Industrial Agricultural and village Subtotal 27.64 56.52 10,930 78,500 Industrial Ninevah (17 sites) 7 Al-Qayyarah 1/2 1.70 3.14 15,000 100,000 Industrial Agricultural and village 8 Al-Qayyarah 3 4.00 12.56 2,000 15,000 Industrial Agricultural and village 9 Al-Qayyarah 4 0.30 0.80 250 Industrial Agricultural and village 10 Al-Qayyarah 5 8.70 12.56 50 Industrial Agricultural and village 11 Al-Qayyarah 17/18 0.30 3.14 50 Industrial Agricultural and village Ein Zalah Station 12 1.20 3.14 20 500 Industrial Agricultural and village (6/7/8/9) 13 Alkask Refinery (10) 0.40 3.14 1,500 10,000 Industrial Agricultural and village 14 Ninevah 11 0.60 3.14 100 1,000 Industrial Agricultural and village Alhukama 15 2.50 12.56 300 5,000 Industrial Agriculture Pharmaceuticals (12) Ninevah Pharmaceuticals 16 250.00 12.56 5,000 35,000 Industrial Agricultural and village (14) 17 Ninevah 15 4.00 12.56 300 5,000 Industrial Residential Al Kindy General 18 1.50 3.14 1,000 10,000 Industrial Agricultural and village Company (16) Subtotal 275.20 82.44 25,570 181,500 73 Conflict Pollution in Iraq Table A1: General profile of pollution hotspots in Iraq (continued) Site Site Area (ha) Population Land use number description Direct Indirect Direct Indirect Direct Indirect Babil (1 site) 19 Al Furat Company (01) 6.20 12.56 1,080 10,000 Industrial Residential and agricultural Diyala (1 site) 20 Diyala Electricals (01) 0.30 3.14 1,200 10,000 Industrial Residential Al Anbar (5 sites) General Phosphate 21 500.00 12.56 2,250 15,000 Industrial Residential Company (01) 22 Alamer Factory (03) 0.30 3.14 400 30,000 Industrial Residential 23 Haditha Oil Refinery (04) 0.50 3.14 1,000 10,000 Industrial Residential 24 Al Anbar Pesticides (05) 0.30 3.14 60 4,000 Industrial Residential 25 Al Shahid Company (06) 0.56 3.14 550 30,000 Industrial Residential Subtotal 501.66 25.12 4,260 89,000 Kirkuk (24 sites) 26 Sarolo Station 1 0.30 3.14 30 2,000 Industrial Residential 27 Sarolo Station 2 0.25 3.14 30 2,000 Industrial Residential 28 Sarolo Station 3 1.00 3.14 50 4,000 Industrial Residential 29 Dawood Station- Kir 6 0.30 12.56 410 3,000 Industrial Residential and agricultural Bay Hassan Station - 30 12.00 12.56 420 3,000 Industrial Residential Kir7,8,9,10,12,13 Baba Gurgur Station 31 8.00 12.56 260 1,500 Industrial Residential and agricultural (14/19) Bai Hassan Oilfield 32 0.30 3.14 110 1,000 Industrial Residential and agricultural (15/17/23) 33 Serbsach (16) 0.25 3.14 20 200 Industrial Staff and residential Haljira Isolation station 34 0.30 3.14 19 200 Industrial Staff and residential (18/20) 35 H-Showraw Station (24) 1.50 3.14 200 1,500 Industrial Staff and residential 36 Hawija Pesticides (25) 0.30 3.14 31 500 Industrial Staff and residential Mulla Abdulla Station 37 0.25 3.14 320 2,000 Industrial Staff and residential (26) 38 Qutan Gas Isolation (28) 0.40 12.56 500 4,000 Industrial Staff and residential Land Remediation for Livelihoods Restoration 74 Table A1: General profile of pollution hotspots in Iraq (continued) Site Site Area (ha) Population Land use number description Direct Indirect Direct Indirect Direct Indirect Kirkuk (24 sites) Jabal Bur Gas Separation 39 8.00 12.56 150 1,075,000 Industrial Staff and residential (30) 40 Khabaz Gas Station (31) 0.30 3.14 110 1,000 Industrial Staff and agricultural Subtotal 33.45 94.20 2660 1,100,900 Salah Al-Din (15 sites) 42 Alaas Oilfield (02) 3.00 3.14 100 1,000 Industrial Agriculture 43 Northern Fertilisers (03) 10.00 12.56 500 10,000 Industrial Residential and agricultural Al-Mansour Vegetable 44 1.00 3.14 500 5,000 Industrial Residential and agricultural Oils (04) 45 Baiji Power Plant (05) 5.00 12.56 1,500 10,000 Industrial Residential and agricultural 46 Salah Al-Din (06) 0.30 3.14 300 2,000 Open hotspot Residential and agricultural Al Seenia Oil Refinery 47 0.30 3.14 500 3,500 Industrial Residential and agricultural (07) 48 Baiji Refinery (09) 15.00 12.56 3,000 173,677 Industrial Staff and residential 49 Salah Al-Din 10 0.30 3.14 300 2,000 Open hotspot Residential and agricultural 50 K2 Pumping Station (13) 0.30 3.14 50 500 Industrial Staff and agricultural 51 General Company (14) 0.30 3.14 1,000 10,000 Industrial Staff and residential 52 Al Fatha (15) 0.30 3.14 300 2,000 Open hotspot Residents and agricultural 53 Al Sahl Valley (16) 0.30 3.14 300 2,000 Open hotspot Residents and agricultural Subtotal 136.10 78.50 9,350 231,677 Grand total (69 sites) 980.55 352.48 55,050 1,701,577 Source: Based on hotspots mapping and analysis MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. 75 Conflict Pollution in Iraq Appendix B: Methodology for hotspots inventory and mapping using spatial tools The overall approach to prepare the inventory and mapping of environmental hotspots through the ESA’s EO clinic involved multistage, consistent process that is used to systematically screen candidate pollutions sites. At each stage in the process, more information is developed about the candidate sites and a subset of the sites are selected for further analysis in the subsequent process. Each stage is described in the following subsections. 1 Hazard site inventory The first step in the process was to create an inventory of candidate pollution hotspot sites and to assemble various datasets that will be used in the screening, characterization, and detailed mapping process. A summary of the datasets is provided in Table B.1. Table B.1: Datasets hotspot inventory Dataset Source Description Spreadsheet with coordinates (latitude/longitude) of locations of Candidate sites Iraqi MoE suspected pollution, type, and name of facility (if known) based on MoE’s knowledge of conflict events. Converted to point geospatial 0.00 46.17 data by consultant. Industrial and military land Polygon geospatial data of industrial and military site boundaries/ OSM use polygons footprint, based on OSM community contributions. Landsat time series Google Cloud Full time series of Landsat 5, 7, 8, Surface Reflectance (1984–present). Full time series of Sentinel-2 a, 2b, Surface Reflectance Sentinel-2 time series Google Cloud (2015–present). Ikonos, Quickbird, GeoEye, Selected images (2000–present) available and exploitable in the Maxar SecureWatch WorldView web application. SPOT and Pleiades Airbus OneAtlas Selected images (2013–present) available from web application. Worldwide mapping of settlements (2015) using TerraSAR-X/ Global Urban Footprint German Aerospace Center TanDEM-X data. Environmental Systems Sentinel-2 10m land cover Worldwide mapping of land use/land cover using Sentinel-2 (2020). Research Institute Source: Based on inventory and mapping by MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. Other reports such as “Iraq Reconstruction and Investment: coordinate for each site and, if available, the name of the site and Part 2: Damage and Needs Assessment of Affected Governorates potential pollution hazard suspected at the site. (January 2018)”, which estimated damages by sectors of activities based on ground-based and remote-based data, and UNEP’s Since several sites were in proximity, spatial analysis using QGIS report “Assessment of Environmental ‘Hot Spots’ in Iraq”, which was completed to group adjacent sites. A 2×2 square kilometer provided detailed damage assessment on five priority sites were buffer (400 ha) was applied to the original list of 215 sites, and sites also referred. found in relative proximity (usually within 2 km) were grouped. The result was that 215 sites were consolidated into 121 polygons An initial compilation of the existing sites and pollution type for assessment. An initial selection (prioritizing hydrocarbon prepared by the MoE indicated that most sites are located in and waste pollution types) meant that CCDC was applied to 54 Ninevah (75) and very few sites in Al Anbar, Babil, and Diyala. polygons (containing 136 individual sites in total). Polygons for This list also formed the basis for the inventory. To expand the assessment ranged from 400 ha (for those containing a single candidate sites, the team extracted industrial and military land-use site) to 4,000 ha (for the polygons containing larger numbers of features from the OSM database for Iraq, which were reviewed sites). Only two groups had more than eight sites and were found jointly with the EO clinic team. Subsequently, an inventory of more in the large oil fields in the Ninevah governorate. than 215 sites was established. The inventory contained a point Land Remediation for Livelihoods Restoration 76 Table B.2: Output of the inventory component per vector dataset Sites Polygons for assessment Format Point shapefile Polygon shapefile Coordinate system EPSG:32638–WGS 84/UTM zone 38N EPSG:32638–WGS 84/UTM zone 38N Description 215 sites 121 polygons (54 selected for CCDC assessment) Source: Based on inventory by MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. 2 Hazard site screening Typically, very little is known about pre-conflict land use and land cover, the extent and timing of disturbance and damage, and post-conflict change at candidate pollution sites. What is known bears considerable uncertainty. The rationale for the site screening is to use the long-time series of free and open satellite EO data to provide consistent information for each site. Furthermore, the full time series and change detection methods of the site screening can be used to identify periods of abrupt change that may be due to natural or human-caused processes. To establish a site screening method across the candidate sites, the following aspects were considered: • Land cover and land use: Conditions vary, with some sites in • Type of infrastructure: The infrastructure and substances will urban/developed areas and others in remote rural areas, with affect the type of impacts that could be detected, for example land cover varying from bare soils, developed, to vegetated hydrocarbons vs chemicals. wetlands or croplands. • Land surface phenology: Conditions vary seasonally, with • Type of incident: The damage and impact vary depending on variability across the region. the incidents, e.g., explosives, accidents, and aerial bombings. The UNEP report “Assessment of Environmental ‘Hot Spots’ in Iraq” helped to investigate these considerations and to select suitable satellite EO image parameters (bands and spectral indexes) to detect changes at specific sites. In addition, the approach was informed by investigating changes in land cover and land use in arid and semi-arid regions. CCDC, a temporal segmentation algorithm introduced by Zhu and Woodcock (2014), was selected. This algorithm can use the full time series of Landsat (1984–present) or Sentinel-2 (2016–present) and offers flexibility to select the spectral bands and indexes that are sensitive to the change that is of interest in the context of land surface characteristics and phenology. The CCDC algorithm assembles dense time-series of observations for each pixel to predict reflectance values for a given band. These observations can be used to better characterize the temporal trajectories for each pixel through time as well as identifies when a series of new data points diverge from this prediction, triggering a temporal break.65 The predicted reflectance values account for both intra-annual (like phenological changes) and inter-annual changes, providing a decomposition between seasonal and long-term changes in the reflectance of a band or index. The equation for this reflectance prediction contains eight change coefficients: where x: Date i: The ith Landsat Band (i = 4, 5, 6, and 7) k: Temporal frequency of harmonic component (k = 1, 2, and 3) T: Number of days per year (T = 365.33 25) a 0,i : Coefficient for overall value for the ith Landsat Band ak,i, bk,i : Coefficients for intra-annual change for the ith Landsat Band c1,i : Coefficient for inter-annual change (slope) for the ith Landsat Band ̂ : Surface reflectance for the ith Landsat Band at x Julian date from model prediction. ρ i,x CCDC has been implemented in Google Earth Engine.66 Note that Zhu et al. (2020) provides an update to the CCDC method, which they refer to as the Continuous Monitoring of Land Disturbance (COLD) algorithm. While the Google Earth Engine implementation is expressly referred to as CCDC, it is actually an implementation of COLD algorithm. Hence, reference to CCDC means Google Earth Engine implementation of the COLD algorithm. 65 Zhu et al. 2020. 66 Gorelick et al. 2017. 77 Conflict Pollution in Iraq The CCDC algorithm uses harmonic modelling to distinguish If a data point exceeds a dynamic probability threshold, it is intra-annual change, like phenology, from gradual changes like considered an outlier. A user defined parameter identifies the inter-annual greening. A series of consecutive values that diverge number of consecutive outliers needed to classify an abrupt from the harmonic is identified as an abrupt disturbance, which disturbance—the optimal number was empirically determined would not be expected by the intra- and inter-annual change to be six. Outliers that occur in isolation, or in series less than modelled in the harmonic. the consecutive outlier threshold, are considered to represent ephemeral change and are omitted from further fitting. The harmonic is generated during an initialization period, where a minimum of 12 clear pixel values (not cloud or snow contaminated The CCDC algorithm produces a variety of model outputs, observations) occurring over the period of at least one year are including the date of each temporal break, the start and end date used to fit eight model coefficients using the Least Absolute of each initialization period and segment, the modelled change Shrinkage and Selection Operator, or LASSO. The spatial probability, Root Mean Square Error, and change magnitude distribution of available pixels can vary due to cloud cover and other for each segment, in addition to the eight harmonic coefficients factors, meaning that different pixels in a scene may have different representing intra- and inter-annual change. initialization periods. The area under consideration presented several challenges for the The CCDC algorithm can calculate harmonics for single bands, implementation of CCDC, as the algorithm had to handle a land for a combination of multiple bands, and for spectral indices. Zhu cover characteristically open and sparsely vegetated, with deserts et al. (2020) compared temporal segmentation accuracy with in some regions. Nevertheless, CCDC detected phenological various Landsat band combinations and indices and found the changes that were depicted by distinct sinusoidal curves, or highest overall disturbance detection accuracy using Green, Red, harmonics, each fit to a time-series model (see Figure B.1). NIR, SWIR1, and SWIR2 together. This band combination had the highest accuracy across several disturbance types, including An illustration of a break in CCDC harmonic models fit using forest harvesting, fire, mechanical, and hydrological disturbances. Landsat time-series is also presented in Figure B.1 using SWIR1 response. This example was captured during the 2016 armed Each new data point in the time series is compared to the expected conflict. Below the map, the graph depicts two harmonic (Fourier) harmonic value using normalized change vector magnitude, which models fitted before and after 2016. The lowest SWIR1 values in enhances the ability to identify change in a single band when late 2016 and early 2017 occurred over areas that were reportedly multiple bands are used as inputs. Because this approach uses a burned or at an oil spill site, likely caused by its bombing or an χ2 test between bands and/or indices, the segmentation results for oilfield explosion. The normal range of SWIR1 values here occurs a given band or index will change depending on the combination between 0.2 and 0.4 (pre-2016), and appeared to recover post- of bands and/or indices in the model. 2017, with a return to a normal phenological and seasonal cycle, showing high SWIR1 in June and low in January, however, with slightly lower values overall compared to pre-conflict conditions. Figure B.1: Phenological changes and break in harmonic models detected by CCDC and fit to a time-series model Source: Based on hotspots mapping by MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. Land Remediation for Livelihoods Restoration 78 For the parametrization of the CCDC algorithm, input variables were selected to capture the type of events that would best characterize hydrocarbon pollution. Parameters were set as follows: • Input variables (breakpointBand) were green, SWIR1, SWIR2, Tassel Cap Brightness, and Wetness. • The minimum number of observations that qualify as consecutive outliers (minObservations:) used to trigger a break in the harmonic was set to eight (default is six) to reduce the number of disturbance flag not related to pollution events. • The timeframe for the CCDC analysis was set to 2000–present. (Note that the Landsat archive allows to go further back in time (from 1984) and could be adjusted accordingly if the need would arise.) • All other parameters were set to their default values. The CCDC algorithm was run over 54 polygons containing 136 sites. An important element of the screening operation is the geo- processing of the outputs of the algorithm to enable visualization of the potential anomalies and disturbances that could be associated with the conflict and pollution events. The output included three main raster files composed of 20 bands, one for each year from 2001 to 2021, and information at each pixel include: date (fractional year) of harmonic model breaks; magnitude of change in SWIR1 values; and change probability. The latter was used to exclude low probability (<0.16) breaks. 3 Hazard site characterization Following screening using open satellite EO data, more detailed Status site characterization is required to further develop knowledge of the • Damage: Indicates if the cell has visible signs of damage physical, environmental, and socio-economic setting, as well as the to infrastructure history of the site and change. VHR satellite images with resolution below 1.5 m can support site characterization, with the archive of • Pollution: Indicates if the cell has visible signs of surface VHR images being from roughly 2000 for Maxar data and from pollution or fire. 2013 for Airbus data. Recently, cloud-based services have been developed to provide cost-effective and easy access to images. Type Maxar SecureWatch and Airbus OneAtlas are both web applications • Receptor: indicates if the cell land use is related to potential that provide tools to identify, view, and exploit images in the cloud. In pollution receptor addition, these web services enable direct streaming of the images • Neutral. into GIS software such as QGIS or ArcGIS. The Grid-Based Assessment process was completed for 20 polygons Given the large number of sites and years to be characterized, which contained 75 individual sites. VHR data available for these an efficient approach is needed to provide consistent information polygons was searched and viewed via Maxar SecureWatch and across sites. A Grid-Based Assessment approach was adopted, Airbus OneAtlas. For each polygon, three cloud-free images covering whereby a regular square grid is draped over the site and each grid three dates were selected. The selection of dates was informed by the cell is assessed for information pertinent to hazard characterization. changes that were identified using Sentinel-2 and Landsat-8 images and the outputs from the CDC algorithm. The Grid-Based Assessment This regular grid enables rapid calculation of statistics, such as grids were created as vector GIS datasets and used to create a series proportion of land cover and land use types or proportion of a site of one page map templates along with the corresponding source VHR with visible signs of damage or pollution. The grid also helps with images (see Figure B.2). sampling design for field investigations. A 2 km grid over the polygon of interest was considered, which could contain one or multiple sites. Each 100×100 m grid cell was visually assessed for each of the VHR image dates and classified with the following information. Land use classes • Residential • Commercial • Industrial • Military • Agriculture • Dense vegetation • Sparse vegetation • Bare ground • Water • Wetland. © Freepik 79 Conflict Pollution in Iraq Figure B.2: One-page map templates with Very High Resolution images Grid Assessment - Group 93 Site ID: 105 Name: Ayn-al Jahash Pollution Type: Oil spill 305 000 305 000 SPOT6, 26 June 2021 P P P P P P D D P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P 105 P P P P P P ! P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P 3 985 000 P P P P P P P P P P 3 985 000 P P P P P P P P P P P P Worldview 2, 25 October 2017 P P P P P P 105 ! P P P P P P P P P P P P P P P P 3 985 000 P P P 3 985 000 Quickbird 2, 11 September 2004 105 ! 3 985 000 3 985 000 ± 305 000 305 000 Legend ! Pollution Site 0 500 1000 Landcover/Landuse class Scale: 1:20 000 m Bareground Projection: WGS 1984 UTM Zone 38N Industrial D/P = damage/pollution Source: Based on MoE, Hatfield Consultants LLP, CLS, and GeoVille 2022. 4 Detailed site mapping Detailed mapping involved: • Extracting and characterizing a wide selection of relevant features, namely land use, land cover, buildings, physical barriers, transport network, and hazard-related ones by following geospatial intelligence techniques at 1:2,000 analysis scale. • Delineating key receptors such as livestock, aquatic species, and human population by mapping pastoral land use, water bodies, and settlements and work sites, respectively. • Identifying pathways of direct exposure by mapping distances/proximity to the pollution site, bioaccumulation by including drainage networks and water sources in maps, and transport from site by identifying drainage networks or other means of transport. The extraction rules of geometric features followed the internationally accepted standard for reference mapping in a context of defense and security, while using geometric positionality and careful assessment of thematic accuracies. Each hotspot map was based on a geospatial dataset, composed of multiple GIS-compatible layers, and contained feature geometries and attribute information. The geospatial dataset was also visualized through a comprehensive map that included annotations, descriptive texts, statistics, and photos. This presentation enables users to understand the situation even without any prior GIS experience. Land Remediation for Livelihoods Restoration 80 Appendix C: Site inspection checklist As part of the intial assessment of hotspots, a detailed site inspection checklist was developed to enable the collection of basic information such as the name of the site, GPS coordinates and possible pathways of contamination. This checklist is presented below. PROJECT: Initial Assessment of Environmental Hotspots in Iraq FACILITY / SITE NAME: FACILITY ADDRESS: DATE: INSPECTION BY: MoE These inspections can provide useful information on: • Suitable and appropriate locations for investigation • The groundwater and surface water environments • Potentially sensitive receptors (targets) including issues that require further investigation, e.g., ecology surveys • Potential sources of contaminants • Nature of contamination • Potential migration routes (pathways). During the walkover survey the consultant may mark locations of features described on a map or photograph them and give them a reference number. If this is undertaken, please add photograph number and map references to this table. Describe features in as much detail as possible. © Adobe Stock 81 Conflict Pollution in Iraq Table C1: Preliminary contamination observations Was there visible evidence of contamination? (Yes/No) Type of expected contamination (Please list the contaminants expected on site, for example, hydrocarbons, sulfur, explosives, etc.) Estimated area contaminated (hectares) Estimated depth of contamination (m) Cause of contaminant release (if known) Features Description Photo no. 1. Describe present land use and building types. Take photographs. 2. Note the presence of any suspected Asbestos Containing Materials in building structures or in waste materials on the ground. Take photographs. 3. Describe surrounding properties/land use especially any waste sites or industrial premises, rubbish dumping area, note the collection and how it gets rid of it. Take photographs. 4. Estimate the distance to the nearest residential house (if applicable). 5. Describe any soils and rocks exposed nearby to the site in road cuttings, quarries, etc. Take photographs. 6. Describe the types and condition of any vegetation on site and nearby. Take photographs. 7. Describe site topography. 8. Describe any damage to existing structures or buildings on site or adjacent to the site. Take photographs. 9. Note the location (distance) of streams, ponds, and rivers nearby, and any signs of previous flooding. 10. Examine all nearby surface waters for evidence of contamination. Note any sheen, color, odors. 11. Locate any ground water wells on site/nearby and coordinate them. 12. Note any odors, sheen, or discoloration in underground water. 13. Note any discolored ground on site or other evidence of ground contamination. 14. Note the presence of any above- or below-ground tanks and, if safe, inspect for evidence of ground contamination, contained liquids, and associated hazardous solid waste. 15. Note the presence of transformers and any electrical equipment. 16. Note any abandoned equipment such as air-conditioning units. 17. Examine nearby areas for evidence of contamination that could migrate onto the site. Land Remediation for Livelihoods Restoration 82 Table C1: Preliminary contamination observations (continued) Features Description Photo no. 18. Note the presence of any underground structures, services, mine workings, tunnels, etc. 19. Make a list of all chemicals and fuels used/stored on site. Is there an inventory on site and Material Safety Data Sheets? 20. Are all fuel, oil, chemical and waste stores within clearly marked and designated areas on-site with appropriate bunding/containment? 21. Are small containers/canisters of fuel, oil, or chemicals fit for purpose? 22. Confirm arrangements for waste disposal and segregation/ recycling. Do they keep waste transfer notes and records of waste produced site? 23. Confirm arrangements for dealing with environmental incidents. Are there spill kits available and other procedures in place? 24. Have there been any environmental incidents on-site? If yes, review incident report and summarize. 25. Are service plans available to show water pipes, drains, electricity, gas, etc? 26. Note any evidence of leaching from landfill sites/ dumping areas. 27. Note potential sources of contamination such as pipelines, fuel tanks, or underground utilities. 28. Note any evidence of buried services (water, gas, cable, pipelines). 29. Note any evidence/presence of leakage on site (water, gas, pipelines). 30. Note any exposed manhole and observe any sheen or evidence of NAPL. 31. Note any evidence/presence of scrap or metals not been used and could be risk of NORM. 32. Describe the site in terms of ground slopes and changes. 33. Describe any evidence of animal activity. 34. Note any anecdotal information in past uses of the site. 35. Note any evidence of gases releases (i.e., flare, smokestack, rubbish burned, generators or heavy-duty engine/turbine). 36. Note types of sewage. Is it all connected or separate? Note if any oil/water separators are available within sewage system. 37. Note the approximate number of people affected by contamination. 38. Who may benefit from remediation in this area (if applicable)? 39. Is the facility currently operational? 40. What is the estimated number of people in the nearby vicinity? Source: Discussions with MoE and other Government of Iraq entities. 83 Conflict Pollution in Iraq Appendix D: Source, pathway, and receptor for pollutants across hotspots Table D1: Source, pathway, and receptor for pollutants across hotspots Site name and Potential source Potential receptor Possible pathway hotspot ID Ninevah Al-Qayyarah Oil well 46: High viscosity Current / future site users Oral, dermal and inhalation exposure with NIN_01 hydrocarbon impacted soil, soil vapor and dust / fibers Approximately 1.7 ha of Current adjacent site users contaminated land. Leaching from soils / percolation to aquifer / Groundwater lateral migration of dissolved phase / NAPL. Surface water. Al-Qayyarah NA NA NA NIN_02 Al-Qayyarah Oil well 39: Hydrocarbons. Current / future site users Oral, dermal and inhalation exposure with NIN_03 2.6 ha at source impacted soil, soil vapor and dust / fibers 1.07 ha of surface staining Adjacent site users Leaching from soils / percolation to aquifer / Groundwater lateral migration of dissolved phase / NAPL. Surface water course. Al-Qayyarah Hydrocarbon Current / future site users Oral, dermal and inhalation exposure with NIN_04 Approximately 150 m2 at the impacted soil, soil vapor and dust / fibers loading site and a pathway Adjacent site users to the north of the pit, Leaching from soils / percolation to aquifer / approximately 1 m in width Buildings and services lateral migration of dissolved phase / NAPL and 120 m in length. Existing / future vegetation Potential contamination of groundwater extraction well. Groundwater Surface water course Fish farm / lake about 240 m northwest. The fish farm is supplied by a groundwater extraction well. Ecological receptors Al-Qayyarah Hydrocarbon Current / future site workers Leaching from soils / percolation to aquifer / NIN_05 and NIN_17 lateral migration of dissolved phase / NAPL Approximately 66,000 m2 of Surface water course: a pond pathway contamination near a pit of NIN-05 (sampled) Runoff into surface waters. of approximate area of 300 m2 Approximately 21,000 m2 of pits size contamination. Groundwater. Hydrocarbon sheen observed on top of water surface. Al-Qayyarah Explosions of oil well no. 78 Current / future site users Oral, dermal and inhalation exposure with NIN-18 during the war with ISIS. impacted soil, Groundwater soil vapor and dust / fibers, ingestion of Well pad 78: hydrocarbons. contaminated produce, inhalation of vapors Approximately 850 m2 from groundwater and / or NAPL if present Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Land Remediation for Livelihoods Restoration 84 Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Ninevah Ein Zalah Station NA Current / future site users NA NIN_06 Groundwater Vegetation including crops Further receptors may be identified in site sheets. Ein Zalah Station NA Current / future site users NA NIN_07 Groundwater Vegetation including crops Further receptors may be identified in site sheets. Ein Zalah Station Oil leakage: hydrocarbons Current / future site users Oral, dermal and inhalation exposure NIN_08 and NIN_09 with impacted soil, soil vapor and dust / 50×50 m near a damaged tank. Groundwater fibers, ingestion of home-grown produce, inhalation of vapors from groundwater and There is a contaminated pathway Vegetation, including crops. / or NAPL if present from the shelled tank towards the valley, of approximate distance Leaching from soils / percolation to aquifer 270 m slopped towards the valley. / lateral migration of dissolved phase / NAPL Discharged/leakage from a tank towards unlined pit covering a Root uptake leading to phytotoxicity. distance of approximately 200 m. Used diesel tank for generator. More few leaks within fuel tanks in the facility which are approximately 1×1 m ~ 1×2 m in size There is asbestos scattered and broken near to the tank. Alkask Refinery Oil leakage: hydrocarbons, Current / future site users Oral, dermal and inhalation exposure NIN_10 4,000 m2 with impacted soil, soil vapor and dust / Vegetation agricultural land fibers, ingestion of home-grown produce, Chemical storage on site. in the south of the site inhalation of vapors from groundwater and / or NAPL if present Groundwater Root uptake leading to phytotoxicity Surface water course Leaching from soils / percolation to Ecological receptors. aquifer / lateral migration of dissolved phase / NAPL There is a river in the south. The refinery discharge water to the river after physical treatment. Flare within the boundary of the refinery and there are gas odors due to the flare and oil spills. 85 Conflict Pollution in Iraq Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and hotspot ID Potential source Potential receptor Possible pathway Ninevah Chemical Contaminated Site Chemical contamination: Current / future site users Oral, dermal and inhalation NIN_11 electrical transformer stores exposure with impacted soil, Groundwater. soil vapor and dust / fibers, Mainly electrical scrap ingestion of home-grown and minor oil stain leaked produce, inhalation of vapors from transformers. from groundwater and / or NAPL if present Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Alhukamaa Pharmaceutical Chemical contamination: rubble, Groundwater Leaching from soils / Company damaged tools and scrap percolation to aquifer / NIN_12 lateral migration of dissolved 250 km2. phase / NAPL. Ninevah Pharmaceutical Chemical contamination: Current / future site users Oral, dermal and inhalation Industrial Company contaminated with chemical exposure with impacted soil, NIN_14 materials as a result of spills Current adjacent site users soil vapor and dust / fibers, from inside the chemical ingestion of home-grown material storage. Materials Groundwater. produce, inhalation of vapors have also expired. from groundwater and / or NAPL if present Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Chemical Contaminated Site Chemical contamination: Future site users Oral, dermal and inhalation NIN_15 explosives, area not fully exposure with impacted soil, cleared from mines. Also Current adjacent site users soil vapor and dust / fibers, partially contaminated. ingestion of home-grown Groundwater. produce, inhalation of vapors 200×200 m2 from groundwater and / or NAPL if present There is a lot of broken up asbestos Leaching from soils / percolation to aquifer / Pesticides known to have lateral migration of dissolved been stored on site. phase / NAPL. Oil manhole Old transformer. Al Kindy General Company The source of the surface Flora and fauna Surface runoff NIN_16 water contamination is unknown, and it is thought that Current / future site users Oral, dermal and ingestion of it could potentially originate contaminated water from off site. Current adjacent site users leaching from surface water / Groundwater percolation to aquifer / lateral migration of contaminants. Land Remediation for Livelihoods Restoration 86 Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Baghdad Ibn Sina Chemical contamination: liquid fertilizer, Current / future site users Oral, dermal and inhalation exposure Company sludge, and asbestos within building with impacted soil, soil vapor and dust / BAG_01 structure. Adjacent site users fibers, ingestion of contaminates through food Vegetation including crops Root uptake leading to phytotoxicity Groundwater Leaching from soils and percolation to Surface water course—Tigris river groundwater likely to be in hydraulic 300 m south and east of the continuity with Tigris. station. Bader Company Chemical contamination: Poly Chlorinated Current/future site users Oral, dermal and inhalation BAG_02 Biphenyl from transformer / generally exposure with impacted soil, soil vapor weapon powder and TNT and Research Adjacent site users and dust. Department eXplosive. Surface water course—nearby river but no sign of contamination. That Alsawary Chemical contamination: several plants Future site users if any Oral, dermal and inhalation exposure Company producing asphalt materials, aluminum with impacted soil, soil vapor and dust / BAG_03 production plants, concrete additives, rock Vegetation including crops fibers, ingestion of home-grown produce, wool production plant, calcium carbonate inhalation of vapors from groundwater plant and discontinued carbide plant Groundwater (resins production plant and oil recycling Root uptake leading to phytotoxicity plant). Surface water course. Leaching from soils / percolation to Polychlorinated Biphenyl from transformers aquifer / lateral migration of dissolved phase / NAPL There are AST and UST for asphalt materials. Runoff to surface water. Ibn Al Waleed Chemical contamination: scrap (mainly Current/future site users Oral, dermal and inhalation exposure BAG_04 vehicles), spills of hydrocarbon due to with impacted soil, soil vapor and dust / leaks in Vegetation including crops fibers, ingestion of home-grown produce, fuel tanks inhalation of vapors from groundwater Adjacent site users Root uptake leading to phytotoxicity Groundwater Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Al Harith Chemical contamination: Current / future site users Oral, dermal and inhalation exposure Factory The presence of clear contamination with Vegetation - agricultural areas with impacted soil, soil vapor and dust / BAG_06 asbestos in the destroyed buildings. (palms, fruit trees and seasonal fibers, ingestion of home-grown produce, crops) natural plant cover. inhalation of vapors from groundwater Very large quantities of factory scrap, in Groundwater: Water well present and / or NAPL addition to large quantities of military on site. Notes from site walkover if present equipment scrap. indicate that groundwater may be Water contaminated with chemicals inside close to the surface. Root uptake leading to phytotoxicity a buried underground tank. Oily pollution in two tanks. Surface water course: Tigris River Leaching from soils / percolation to along the eastern side. aquifer / lateral migration of dissolved Traces of pollution resulting from the Ecological receptors: Existence phase / NAPL. discharge of water from the treatment of agricultural and fish and unit into the river (blackish color with the livestock breeding. smell of organic substances). 87 Conflict Pollution in Iraq Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Baghdad Baghdad Lead Chemical contamination: heavy metals, Current / future site users Oral, dermal and inhalation exposure with Extraction asbestos, Poly Chlorinated Biphenyl, tar, Adjacent site users impacted soil, soil vapor and dust / fibers, Facility and hydrocarbons. Groundwater. inhalation of vapors from groundwater and / BAG_08 or NAPL if present Root uptake leading to phytotoxicity Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Babil Al Furat Chemical contamination including Current / future site users: Oral, dermal and inhalation exposure with Company sulfur, chlorine, carbon disulphide, operational impacted soil, soil vapor and dust / fibers, BAB_01 asbestos, and Polychlorinated Biphenyl ingestion of contaminates through food from transformer. Adjacent site users Vegetation including crops Root uptake leading to phytotoxicity Groundwater Leaching from soils and percolation to groundwater. Surface water course: Main drainage channels of farms 50 m east of the station Baghdad Diyala Chemical contamination: hydrocarbons Current / future site users Oral, dermal and inhalation exposure Electrical with impacted soil, soil vapor and dust / Industries Heavy metals, leakage oil Adjacent site users fibers, ingestion of contaminated produce, Company from transformers inhalation of vapors from groundwater and / DIY_01 Sheen present in groundwater samples Groundwater or NAPL if present indicating contamination Leaching from soils / percolation to The ground around diesel tanks, oil aquifer / lateral migration of dissolved barrels, and transformers phase / NAPL. was contaminated. Al Harith Chemical contamination: Current / future site users Oral, dermal and inhalation exposure with Factory The presence of clear contamination with Vegetation - agricultural areas impacted soil, soil vapor and dust / fibers, BAG_06 asbestos in the destroyed buildings. (palms, fruit trees and seasonal ingestion of home-grown produce, inhalation Very large quantities of factory scrap, in crops) natural plant cover. of vapors from groundwater and / or NAPL addition to large quantities of military Groundwater: Water well if present equipment scrap. present on site. Notes from site walkover indicate that Root uptake leading to phytotoxicity Water contaminated with chemicals groundwater may be close to inside a buried underground tank. the surface. Leaching from soils / percolation to Oily pollution in two tanks. aquifer / lateral migration of dissolved phase Surface water course: Tigris / NAPL. Traces of pollution resulting from the River along the eastern side. discharge of water from the treatment Ecological receptors: Existence unit into the river (blackish color with of agricultural and fish and the smell of organic substances). livestock breeding. Baghdad Lead Chemical contamination: heavy metals, Current / future site users Oral, dermal and inhalation exposure with Extraction asbestos, Poly Chlorinated Biphenyl, tar, Adjacent site users Groundwater. impacted soil, soil vapor and dust / fibers, Facility and hydrocarbons. inhalation of vapors from groundwater and / BAG_08 or NAPL if present Root uptake leading to phytotoxicity Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Babil Al Furat Chemical contamination including sulfur, Current / future site users: Oral, dermal and inhalation exposure Company chlorine, carbon disulphide, asbestos, and operational with impacted soil, soil vapor BAB_01 Polychlorinated Biphenyl from transformer. and dust / fibers, ingestion of Adjacent site users contaminates through food Vegetation including crops Root uptake leading to phytotoxicity Groundwater Leaching from soils and percolation to groundwater. Surface water course: Main drainage channels of farms 50 m east of the station Diyala Diyala Electrical Chemical contamination: hydrocarbons Current / future site users Oral, dermal and inhalation exposure Industries with impacted soil, soil vapor Company Heavy metals, leakage oil Adjacent site users and dust / fibers, ingestion of DIY_01 from transformers contaminated produce, inhalation of Groundwater vapors from groundwater and / or Sheen present in groundwater samples NAPL if present indicating contamination Leaching from soils / percolation The ground around diesel tanks, oil barrels, to aquifer / lateral migration of and transformers was contaminated. dissolved phase / NAPL. Al Anbar State Company Chemical contamination: explosives, Future site users Oral, dermal and inhalation exposure for Phosphate in chemicals. with impacted soil, soil vapor Al-Qaaim City Adjacent site users. and dust / fibers, ingestion of ANB_01 Metal scrap. contaminated produce, inhalation of vapors from groundwater and / or NAPL if present. Alamer factory Chemical contamination Future site users Oral, dermal and inhalation exposure ANB_03 chemicals. with dust / fibers, ingestion and Adjacent site users. inhalation of contaminated materials. Future site users Adjacent site users. Haditha Oil Oil spill: hydrocarbons. Current / future site users Oral, dermal and inhalation exposure Refinery with impacted soil, soil vapor ANB_04 It is understood based on information from Adjacent site users and dust / fibers, ingestion of the Ministry of Environment that the site is contaminated produce, inhalation of generally well managed and in a good state Vegetation vapors from groundwater and / or of repair. While hydrocarbon contamination NAPL if present has been identified within an oil pit, this is Groundwater understood to be located away from the Leaching from soils / percolation most sensitive receptors. Oil within such Surface water course: to aquifer / lateral migration of pits tends to be highly weathered, pond with visual sign of dissolved phase / NAPL longer-chain hydrocarbons with a high contamination viscosity, so reducing the risk of these Runoff to surface water. hydrocarbons leaching into the surrounding Ecological receptors. soil and/or groundwater. 89 Conflict Pollution in Iraq Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Al Anbar Pesticides Factory Chemical contamination: chemicals Current / future site users: factory Oral, dermal and inhalation exposure Al-Falluja City used for pesticides and herbicides. still in operation at reduced output with impacted soil, soil vapor and dust ANB_05 due to bomb damage / fibers, ingestion of contaminated Asbestos and Polychlorinated produce, inhalation of vapors from Biphenyl from transformer. Buildings and services groundwater and / or NAPL if present Existing/ future vegetation Leaching from soils / percolation to Groundwater: one groundwater aquifer / lateral migration of dissolved extraction well on-site and used phase / NAPL. for domestic purposes Surface water course Ecological receptors. Al Shahid Chemical contamination: Current/ future site users: Oral, dermal and inhalation exposure Company storage of chemicals on site. operational factory. with impacted soil, soil vapor ANB_06 Poor storage noted. and dust / fibers, ingestion of contaminated produce, inhalation of vapors from groundwater and / or NAPL if present. Kirkuk Sarolo Station Work of Kar company: hydrocarbons Current/ future site users Oral, dermal and inhalation exposure KIR_01, KIR_04 with impacted soil, soil vapor and KIR_05 Spill inside the station due to Groundwater and dust / fibers, ingestion of overload, lack of maintenance, and contaminated produce, inhalation of leaks but no historical record for the Surface water course: need to vapors from groundwater and / or environmental incidents in place determine distance to Zab river. NAPL if present Old (pipes, flanges, valves, and tanks) Leaching from soils / percolation to aquifer / lateral migration of Visible oil spills at surface. dissolved phase / NAPL. Sarolo Station Evaporation pit / Kar company: Current/ future site users Oral, dermal and inhalation exposure KIR_02 hydrocarbons, leakage from old with impacted soil, soil vapor pipes, valves, and old transformers, Vegetation, including agricultural and dust / fibers, ingestion of several spills in different locations. crops contaminated produce, inhalation of vapors from groundwater and / or The site also contains asbestos Groundwater. NAPL if present roofing. Root uptake leading to phytotoxicity Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Sarolo Station Work of Kar company: a large Current and future site users Oral, dermal and inhalation exposure KIR_03 leak of crude oil as a result of with impacted soil, soil vapor maintenance work and broken pipes, Vegetation and dust / fibers, ingestion of pollution outside the station fence. contaminated produce, inhalation of Groundwater: hydrocarbon vapors from groundwater and / or Obvious contamination of crude oil. observed at surface in NAPL if present unlined pits. It was noted by the site team Root uptake leading to phytotoxicity that there had been frequent Surface water course: A large environmental incidents. stream heading towards the little Leaching from soils / percolation Zab river overflows during the to aquifer / lateral migration of winter season. dissolved phase / naphthalene are flares to burn gas. Land Remediation for Livelihoods Restoration 90 Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Kirkuk Dawood Station for Oil waste: hydrocarbon pollution. Current / future site users Oral, dermal and inhalation exposure Oil Refining Oily water not treated. Unlined pit. with impacted soil, soil vapor and dust KIR_06 Adjacent site users / fibers, ingestion of contaminated produce, inhalation of vapors from Vegetation groundwater and / or NAPL if present Groundwater Root uptake leading to phytotoxicity Surface water course. Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Bai Hassan North Ruptured pipeline: hydrocarbon Current site users Oral, dermal and inhalation exposure Degassing Station pollution. with impacted soil, soil vapor KIR_07 Groundwater. and dust / fibers, ingestion of Blackish ground due to spills. contaminated produce, inhalation of Free phase hydrocarbons visible at vapors from groundwater and / or the surface. NAPL if present Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Bai Hassan North Ruptured pipeline: hydrocarbon Current site users Oral, dermal and inhalation exposure Degassing Station pollution. with impacted soil, soil vapor KIR_08 Groundwater. and dust / fibers, ingestion of contaminated produce, inhalation of vapors from groundwater and / or NAPL if present Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Bai Hassan North Pit near hydrocarbon waste tank. Current site users Oral, dermal and inhalation exposure Degassing Station with impacted soil, soil vapor KIR_09 Groundwater. and dust / fibers, ingestion of contaminated produce, inhalation of vapors from groundwater and / or NAPL if present Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Bai Hassan North Evaporation pool in API station. Current / future site users Oral, dermal and inhalation exposure Degassing Station with impacted soil, soil vapor KIR_10 Vegetation and dust / fibers, ingestion of contaminated produce, inhalation of Groundwater. vapors from groundwater and / or NAPL if present Root uptake leading to phytotoxicity Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. 91 Conflict Pollution in Iraq Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Kirkuk Bai Hassan Evaporation pool in API station. Current / future site users Oral, dermal and inhalation exposure North Degassing with impacted soil, soil vapor and dust Station Vegetation / fibers, ingestion of contaminated KIR_10 produce, inhalation of vapors from Groundwater. groundwater and / or NAPL if present Root uptake leading to phytotoxicity Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Bai Hassan Testing tank pit. Current / future site users Oral, dermal and inhalation exposure North Degassing with impacted soil, soil vapor and dust Station Vegetation / fibers, ingestion of contaminated KIR_12 produce, inhalation of vapors from Groundwater. groundwater and / or NAPL if present Root uptake leading to phytotoxicity Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Bai Hassan Evaporation pool in API station. Current / future site users Oral, dermal and inhalation exposure North Degassing with impacted soil, soil vapor and dust Station Vegetation / fibers, ingestion of contaminated KIR_13 produce, inhalation of vapors from Groundwater. groundwater and / or NAPL if present Root uptake leading to phytotoxicity Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Baba Gurgur Maintenance work and cleaning: Current / future site users Oral, dermal and inhalation exposure Station hydrocarbons with impacted soil, soil vapor and dust KIR_14 Adjacent site users / fibers, ingestion of contaminated 2,500 m and it spreads to the produce, inhalation of vapors from south about 8 km. Significant Vegetation groundwater and / or NAPL if present area of contamination. Groundwater Root uptake leading to phytotoxicity Surface water. Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL There are flares. Baba Gurgur Discharging works: hydrocarbon, Current / future site users Oral, dermal and inhalation exposure Station spills, using uncovered pit for with impacted soil, soil vapor and dust KIR_19 waste oil, asbestos used as Groundwater. / fibers, ingestion of contaminated pipe isolation. produce, inhalation of vapors from groundwater and / or NAPL if present Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Land Remediation for Livelihoods Restoration 92 Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Al Anbar Bai Hassan Oil waste flaring Current/ future site users: site is operational Oral, dermal and inhalation exposure with South Oilfield pit for hot flares: impacted soil, soil vapor and dust / fibers, KIR_15, KIR_17 Hydrocarbons Adjacent site users: flaring noted to be in ingestion of contaminated produce, inhalation and KIR_23 direction of residential of vapors from groundwater and / or NAPL if 40 drums x 200 L present demulsifier Vegetation Root uptake leading to phytotoxicity Electrical Groundwater transformers Leaching from soils / percolation to aquifer / existed, flaring. Surface water course lateral migration of dissolved phase / NAPL Ecological receptors. Windblown dust / hydrocarbons. Serbach Station Work of Kar Current / future site users Oral, dermal and inhalation exposure with KIR_16 company: impacted soil, soil vapor and dust / fibers, hydrocarbons and Vegetation: strategic agricultural area ingestion of contaminated produce, inhalation asbestos found in of vapors from groundwater and / or NAPL if roofing over the Groundwater. present carpark. Root uptake leading to phytotoxicity Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Haljira Gas Leakage of crumbling Current / future site users: operational Oral, dermal and inhalation exposure with Isolation Station pipes, hydrocarbons site impacted soil, soil vapor and dust / fibers, KIR_18 and 10 x 2 m, and some ingestion of contaminated produce, inhalation KIR_20 old transformers. Groundwater of vapors from groundwater and / or NAPL if present Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Showraw Maintenance work Current / future site users Oral, dermal and inhalation exposure with Station and Kat and cleaning above- impacted soil, soil vapor and dust / fibers, Factory ground tank, number Groundwater: there are five water wells ingestion of contaminated produce, inhalation KIR_24 29, containing with a depth of 200 m. of vapors from groundwater and / or NAPL if raw materials and present product. Surface water course: in the southwest One new there is a large stormwater drain. Leaching from soils / percolation to aquifer / transformer. lateral migration of dissolved phase / NAPL. Chemicals Hawija Chemical Current / future site users Oral, dermal and inhalation exposure with Pesticides Stores contamination: impacted soil, soil vapor and dust / fibers, KIR_25 sulfuric acid, urea, Groundwater. ingestion of contaminated produce, inhalation of and pesticide. vapors from groundwater. Mulla Abdulla Oil leakage: 2,500 m Current / future site users Oral, dermal and inhalation exposure with Station (IT1) and it spreads to the impacted soil, soil vapor and dust / fibers, KIR_26 south about 8 km. Adjacent site users ingestion of contaminated produce, inhalation of vapors from groundwater and / or NAPL if Vegetation present Groundwater Root uptake leading to phytotoxicity Surface water course. Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. 93 Conflict Pollution in Iraq Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Al Anbar Qutan Gas Oil leakage: hydrocarbon pollution resulting from Current / future site users Oral, dermal and inhalation exposure Isolation the oil waste collection effluents with impacted soil, soil vapor and dust Station - Adjacent site users / fibers, ingestion of contaminated Babakkar A pit with a diameter produce, inhalation of vapors from Oilfield of 25 m. Groundwater groundwater and / or NAPL if present KIR_28 Vegetation: agricultural land. Root uptake leading to phytotoxicity Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL Gas flaring. Gas and Oil Hydrocarbons: 1,500 m2 and it spreads to the Current / future site users Oral, dermal and inhalation exposure Separation south about 8 km with impacted soil, soil vapor and dust Plant in Adjacent site users / fibers, ingestion of contaminated Jabal Bur Unlined oily pits produce, inhalation of vapors from KIR_30 Groundwater. groundwater and / or NAPL if present The ground near the source is contaminated (oil separators) Leaching from soils / percolation to aquifer / lateral migration of dissolved 4 transformers, production date is 1984. phase / NAPL Gas flaring. Khabaz Gas Hydrocarbons: 2,500 m2 Current / future site users Oral, dermal and inhalation exposure Station with impacted soil, soil vapor and dust KIR_31 Electrical transformers existed. Agricultural and grazing / fibers, ingestion of contaminated areas produce, inhalation of vapors from groundwater and / or NAPL if present Groundwater Root uptake leading to phytotoxicity There are flares in village direction. Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Salah Al Din Ajil Oil Field Oil leakage: hydrocarbon. Multiple leaks some Current / future site users Oral, dermal and inhalation exposure SAL_001_H, extending over significant areas (multiple with impacted soil, soil vapor and dust SAL_011_H, hectares). Adjacent site users / fibers, ingestion of contaminated SAL_012 produce, inhalation of vapors from Vegetation groundwater and / or NAPL if present Groundwater Root uptake leading to phytotoxicity Surface water course: Tigris Leaching from soils / percolation to river (agricultural land is aquifer / lateral migration of dissolved separating between the river phase / NAPL. and the field) Ecological receptors There are flares. Alass Oil Oil leakage: historical contamination (hydrocarbons) Groundwater Leaching from soils / percolation to Field aquifer / lateral migration of dissolved SAL_002_H 2,500 m2 oil pit for taking oil out and selling Ecological receptors phase / NAPL. Land Remediation for Livelihoods Restoration 94 Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Salah Al Din Northern Damage to tanks: Future site users Leaching from soils / percolation to Fertilizers fertilizers units’ products aquifer / lateral migration of dissolved Company destroyed because of the Groundwater phase / NAPL. SAL_003_H war with ISIS. Radioactive element: co-60 AL Mansour The discolored ground near Future site users Oral, dermal and inhalation exposure Factories for the broken transformer with impacted soil, soil vapor and dust / Vegetable Oils Groundwater. fibers, ingestion of home-grown produce, SAL_004_H Old waste stream and inhalation of vapors from groundwater near an oil tank and / or NAPL if present All locations have been Leaching from soils / percolation to sampled. aquifer / lateral migration of dissolved phase / NAPL. Baiji Power Plant Oil leakage: historical Current / future site users Oral, dermal and inhalation exposure SAL_005_H contamination with impacted soil, soil vapor and dust / (hydrocarbons) Vegetation fibers, ingestion of home-grown produce, inhalation of vapors from groundwater 2,500 m2 Groundwater and / or NAPL if present Oil spill due to bombing. Surface water course Leaching from soils / percolation to aquifer / lateral migration of dissolved Ecological receptors phase / NAPL. Salah Al- Only maintenance work Future site users Leaching from soils / percolation to Din - SAL_06, and cleaning taking place aquifer / lateral migration of dissolved SAL_006_H at the site. Groundwater. phase / NAPL. Historical contamination: hydrocarbons Source not unknown 600 m2. Al Seenia Oil Oil leakage: unlined pit Current / future site users Oral, dermal and inhalation exposure Refinery Hydrocarbons with impacted soil, soil vapor and dust / SAL_007_H Asbestos Adjacent site users fibers, ingestion of home-grown produce, 50 x 50 m2 inhalation of vapors from groundwater Vegetation and / or NAPL if present Caustic soda Anti corrosive Groundwater: agriculture well. Root uptake leading to phytotoxicity Dispersed Trisodium phosphate Leaching from soils / percolation to Oil pumps aquifer / lateral migration of dissolved Motor oil. phase / NAPL There are flares. 95 Conflict Pollution in Iraq Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Salah Al Din Baiji Refinery Several large areas of Current / future site users Oral, dermal and inhalation exposure SAL_009_C hydrocarbon with impacted soil, soil vapor and dust / contamination have Adjacent site users fibers, ingestion of home-grown produce, been identified. inhalation of vapors from groundwater Vegetation: The water generated from and / or NAPL if present 50 x 50 m2 (nearby the treatment unit is drained into the al- storage tanks) Nouri canal. Root uptake leading to phytotoxicity 750 x 35 m2 (area to Al-Nouri canal: A spring water stream Leaching from soils / percolation to collect the oil waste connected to the Tigris river, used by the aquifer / lateral migration of dissolved and rainwater) people to irrigate crops and livestock, with a phase / NAPL. direct impact on the Tigris River 100 x 1,500 m2 (volume approximate = Groundwater: NAPL appeared in manhole 203,000 m3). due to leakage in the destroyed tanks. Surface water course: Tigris River adjacent to the refinery Ecological receptors. Salah Al-Din Chemical contamination: Future site users Leaching from soils / percolation to SAL_10, historical contamination aquifer / lateral migration of dissolved SAL_010_IC (hydrocarbons) and the Groundwater. phase / NAPL. source not unknown 600 m2. K2 Station Hydrocarbons: Current / future site users Buildings Oral, dermal and inhalation exposure SAL_013 30 x 30 m2. and services Existing / future vegetation with impacted soil, soil vapor and dust / Groundwater Surface water course fibers, ingestion of home-grown produce, Ecological receptors. inhalation of vapors from groundwater and / or NAPL if present Root uptake leading to phytotoxicity Leaching from soils / percolation to aquifer / lateral migration of dissolved phase / NAPL. Salah Only maintenance work Future site users Leaching from soils / percolation to Al-Din - SAL_06, and cleaning taking place aquifer / lateral migration of dissolved SAL_006_H at the site. Groundwater. phase / NAPL. Historical contamination: hydrocarbons Source not unknown 600 m2. Land Remediation for Livelihoods Restoration 96 Table D1: Source, pathway, and receptor for pollutants across hotspots (continued) Site name and Potential source Potential receptor Possible pathway hotspot ID Salah Al Din General Company Chemicals: 2,500 m2 Current / future site users Oral, dermal and inhalation exposure for Communication with impacted soil, soil vapor and Equipment and Power The chemical store Adjacent site users dust / fibers, ingestion of home-grown SAL_014_C contains quantities of produce, inhalation of vapors from damaged and dangerous Vegetation groundwater and / or NAPL if present chemicals: Sodium and potassium Groundwater: three Root uptake leading to phytotoxicity cyanide about 700 kg. ground water wells used Data gap (no cyanide to water plants. Leaching from soils / percolation to testing completed) aquifer / lateral migration of dissolved Sodium hydroxide phase / NAPL. Copper sulphate Nickel chloride. Al Fatha Historical contamination: Vegetation Leaching from soils / percolation SAL_015_H hydrocarbons. to aquifer / lateral migration of Groundwater dissolved phase / NAPL Source unknown. Surface water course: Runoff into surface water and 600 m2 or more. Open area, next to Tigris impact to ecological receptors. river Ecological receptors. Al Sahl Valley Historical contamination: Groundwater Leaching from soils / percolation SAL_016_H hydrocarbons to aquifer / lateral migration of Surface water course dissolved phase / NAPL Source unknown Ecological receptors Leaching from soils / percolation 600 m2 or more. to aquifer / lateral migration of dissolved phase / NAPL. Source: Site Assessment by MoE and RSK Environment LLC 2022. 97 Conflict Pollution in Iraq Appendix E: Summary of preliminary assessment of Health, Economic, Agriculture and Livelihood impacts of hotspots (Table on following page) © Adobe Stock Land Remediation for Livelihoods Restoration 98 Table E1: Estimate of burden of disease due to hotspots Relative risk: Relative risk: Mortality impact Morbidity impact Mortality valuation Morbidity valuation mortality morbidity Direct Indirect Direct Indirect Total area area population population Chem: Sulfuric Chem: Sulfuric Direct Indirect Direct Indirect Direct Indirect Direct Indirect Acid-Carcinogens Acid-Carcinogens Pop population population population population population population population Oil: PAH-Lead Oil: PAH-Lead Typology Low Years Low High Lived High death death with YLD ha ha # # # # YLD Lost YLD Lost US$ US$ US$ US$ US$ per per Disability per 100,000 100,000 (YLD) 100,000 per 100,000 Al Anbar Chemical 501 22 3,260 79 ,00 0.0025 0.42 0.031 1.31 0.01 0.00 0.04 0.02 5,709 824 216 124 6,872 Oil 1 3 1,000 10,000 0.03 8.63 0.0073 49.19 0.09 0.00 0.49 0.00 35,985 1,251 2,483 4 39,722 Babil Chemical 6 13 1,080 10,000 0.0025 0.42 0.031 1.31 0.00 0.00 0.01 0.00 1 891 104 71 16 2,083 Oil 0.03 8.63 0.0073 49.19 - - - - - - - - - Baghdad Chemical 27 53 10,430 75,000 0.0025 0.42 0.031 1.31 0.04 0.00 0.14 0.02 18 266 782 690 117 19 855 Oil 1 3 500 3 500 0.03 8.63 0.0073 49.19 0.04 0.00 0.25 0.00 17 992 438 1 242 1 19 673 Diyala Chemical 0 3 1,200 10,000 0.003 0.42 0.031 1.31 0.01 0.00 0.02 0.00 2,102 104 79 16 2,301 Oil 0.030 8.63 0.0073 49.19 - - - - - - - - - Table E1: Estimate of burden of disease due to hotspots (continued) Relative risk: Relative risk: Mortality impact Morbidity impact Mortality valuation Morbidity valuation mortality morbidity Direct Indirect Direct Indirect Total area area population population Chem: Sulfuric Chem: Sulfuric Direct Indirect Direct Indirect Direct Indirect Direct Indirect Acid-Carcinogens Acid-Carcinogens Pop population population population population population population population Oil: PAH-Lead Oil: PAH-Lead Typology Low Years Low High Lived High death death with YLD ha ha # # # # YLD Lost YLD Lost US$ US$ US$ US$ US$ per per Disability per 100,000 100,000 (YLD) 100,000 per 100,000 Kirkuk Chemical 0 3 31 500 0.003 0.42 0.031 1.31 0.00 0.00 0.00 0.00 54 5 2 1 62 Oil 33 91 2,629 1,100,400 0.030 8.63 0.0073 49.19 0.23 0.33 1.29 0.08 94,604 137,651 6,528 406 239,188 Ninevah Chemical 259 44 6,700 56,000 0.0025 0.42 0.031 1.31 0.03 0.00 0.09 0.02 11,734 584 443 88 12,848 Oil 17 38 18,870 125,500 0.03 8.63 0.0073 49.19 1.63 0.04 9.28 0.01 679,030 15,699 46,856 46 741,631 Salah Al-Din Chemical 17 35 3,800 37,000 0.0025 0.42 0.031 1.31 0.02 0.00 0.05 0.01 6,655 386 251 58 7,350 Oil 120 44 5,550 194,677 0.03 8.63 0.0073 49.19 0.48 0.06 2.73 0.01 199,715 24,352 13,781 72 237,920 Total 1,329,505 Chemical - - - - 51,370 Oil 1,278,134 Note: The Value of Statistical Life for Iraq (US$416,971) is used for premature mortality and the Gross Domestic Product (US$5,048) per capita is used for the Years Lived with Disability (YLD) lost in 2021 prices. Table E2: Estimate of economic impacts (loss of industrial production) Cost of Annual production Price per ton Annual turnover Industry production lost (tons per year) (2021)* (US$ million) (US$ million per year) 1. Alhukama Pharmaceuticals, Ninevah** Not available 11.58# 11.58 2. Ninevah Pharmaceuticals** Not available 11.57# 11.57 3.General Phosphate Company, Al Anbar 1,500,000 767.00 1,150.50 1,150.50 4. Al-Mansour Vegetable Oils 1,200 1,876.25 2.25 2.25 Total cost of lost industrial production 1,175.90 * Acid Plant Database 2023.67 # Kadhim et al. 2022. ** Directory of Pharmaceutical and Medicine Manufacturing Companies in Iraq 2023.68 Source: Analysis by ASA team. Table E3: Estimate of loss of agriculture yield (wheat) Governorate Agriculture Wheat harvest Wheat harvest 2021 wheat Forgone wheat (US$) area (ha) yield (ton per ha) opportunity (tons) harvest prices (US$/ton) Al Anbar 5.73 3.30 20 18.92 114.68 346.90 462.50 6,564 53,043 0.03 Babil 8.15 3.30 20 26.91 163.08 346.90 462.50 9,334 75,426 0.04 Baghdad 77.76 3.30 20 256.62 1,555.28 346.90 462.50 89,020 719,354 0.40 Diyala 0.81 3.30 20 2.66 16.11 346.90 462.50 922 7,451 0.00 Kirkuk 567.81 3.30 20 1,873.79 11,356.29 346.90 462.50 650,005 5,252,567 2.95 Ninevah 681.13 3.30 20 2,247.74 13,622.66 346.90 462.50 779,726 6,300,815 3.54 Salah Al-Din 227.60 3.30 20 751.09 4,552.05 346.90 462.50 260,548 2,105,436 1.18 Total 1,569.01 5,177.72 31,380.14 1,796,119 14,514,093 8.16 Source: Analysis by ASA team. 67 Acid Plant Database, DKL Engineering, Inc. (Accessed August 24, 2023), http://www.sulphuric-acid.com/sulphuric-acid-on-the-web/acid%20plants/State%20 Company%20for%20Phosphates.htm. 68 Directory of Pharmaceutical And Medicine Manufacturing Companies In Iraq, Dun & Bradstreet (Accessed August 24, 2023), https://www.dnb.com/business-directory/company-information.pharmaceutical_and_medicine_manufacturing.iq.html. 101 Conflict Pollution in Iraq Table E4: Estimate of loss of livelihood (industrial jobs) Al Anbar Babil Baghdad Diyala Kirkuk Ninevah Salah Al-Din Total Number of industrial jobs 3,260 80 12,930 200 31 4,200 10,500 31,201 Total employment days (310) 1,010,600 24,800 4,008,300 62,000 9,610 1,302,000 3,255,000 9,672,310 per year GDP per capita (2021) (US$) 5,048 5,048 5,048 5,048 5,048 5,048 5,048 5,048 GDP per capita per day (2021) 13.83 13.83 13.83 13.83 13.83 13.83 13.83 13.83 (US$) Total expenditure per 13,976,736 342,987 55,435,338 857,468 132,908 18,006,838 45,017,096 133,769,372 year (US$) Marginal Propensity to Consume 0.30 0.30 0.30 0.30 0.30 0.30 0.30 0.30 (MPC) Multiplier, K = 1/(1-MPC) 1.43 1.43 1.43 1.43 1.43 1.43 1.43 1.43 Change in real GDP (US$) 19,966,766 489,982 79,193,340 1,224,955 189,868 25,724,055 64,310,137 191,099,103 Source: Analysis by ASA team. Land Remediation for Livelihoods Restoration 102 Table E5: Estimate of loss of livelihoods (agricultural jobs) Al Anbar Babil Baghdad Diyala Kirkuk Ninevah Salah Al-Din Total Number of agricultural jobs 5 6 62 1 452 543 181 1,250 (0.79 ha)* Total employment days (310) per 1,416 2,014 19,206 199 140,241 168,29 56,214 387,520 year GDP per capita 5,048 5,048 5,048 5,048 5,048 5,048 5,048 5,048 (2021) (US$) GDP per capita per day (2021) 13.83 13.83 13.83 13.83 13.83 13.83 13.83 13.83 (US$) Total expenditure 19,587 27,852 265,628 2,751 1,939,558 2,326,633 777,451 5,359,461 per year (US$) MPC# 0.30 0.30 0.30 0.30 0.30 0.30 0.30 0.30 Multiplier, 1.43 1.43 1.43 1.43 1.43 1.43 1.43 1.43 K = 1/(1-MPC) Change in real 27,981 39,788 379,469 3,930 2,770,798 3,323,762 1,110,645 7,656,373 GDP (US$) * Average jobs per hectare estimated from International Labour Organisation (2022).69 # Carroll et al 2017. Source: Analysis by ASA team. 69 ILO 2022. © Adobe Stock 103 Conflict Pollution in Iraq Appendix F: Risk assessment summary Table F1: Summary of risk assessment Chemical results Site name and hotspot ID Notes Risk rating Justification and conclusions Ninevah Al-Qayyarah The site used to be a well Across the entire facility, Moderate Likely: There is visible NIN_01 pad. The oil well was burned scrap metal has been evidence of hydrocarbon and concreted. Currently it is observed. However, no contamination, which located in a residential area evidence of asbestos was has been confirmed within Al-Qayyarah. found. Soil samples contain through chemical a high concentration testing. Hydrocarbons The ground comprises burnt (10x DIV) of aromatic appear highly viscous, soil / hydrocarbon and two hydrocarbons. Additionally, weathered heavy-end highly viscous hydrocarbon pits. it appears that nearby rather than more surface water contains volatile fractions. A natural tar spring elevated concentrations is about 400 m to of fluoranthene (5x DIV Medium severity: the north. for water). Chronic damage to human health. Al-Qayyarah Site sheets required NA NA NA NIN_02 for assessment currently withheld. Al-Qayyarah Damaged / burned oil well and Despite visible evidence High Highly likely: NIN_03 four pits to north trapping the of hydrocarbon There is visible evidence contamination (highly viscous contamination, the of hydrocarbon hydrocarbon). gathered soil samples contamination which has do not show any been confirmed through contamination above the chemical testing. LLD. The surface water that has been sampled Medium severity: contains chrysene Chronic damage to (100x DIV). human health. Al-Qayyarah The site is a non-lined crude The site consists of a High Highly likely: NIN_04 oil pit. large hydrocarbon pit. There is visible evidence Around this pit several of hydrocarbon The pit is about 3 m higher locations were sampled contamination. than the surrounding ground. that do not show any contamination. The surface Medium severity: water contained high Chronic damage to concentration (50x DIV) human health of SVOC. Al-Qayyarah Site comprises multiple The site consists of large Moderate Highly likely: Visible and NIN_05 and NIN_17 oil pits and oil wells within hydrocarbon pits and chemical evidence of Al Qayyarah oil field. contamination pathways. contamination. Mountainous area with valley. On several locations aromatic hydrocarbon Mild severity: contamination (10x DIVs) Pollution of non-sensitive was sampled. The surface water resources water in pools that has been sampled contains high concentrations (100x DIV) of SVOC (perylene and pyrene). Land Remediation for Livelihoods Restoration 104 Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Ninevah Al-Qayyarah NA NA Moderate Likely: Hydrocarbon contamination NIN-18 / low identified. Mild severity: Pollution of non-sensitive water resources. Ein Zalah Station Site sheets required for NA NA NA NIN_06 assessment currently withheld Potential risk likely to be the same as that at NIN_08 and NIN_09. Ein Zalah Station Site sheets required for NA NA NA NIN_07 assessment currently withheld Potential risk likely to be the same as that at NIN_08 and NIN_09. Ein Zalah Station Oil industry facility containing The location is littered Moderate Highly likely: NIN_08 and NIN_09 storage oil tanks, pumps, with asbestos. Additionally, Visible evidence of extensive heavy-duty generators and both on- and offsite high hydrocarbon contamination office buildings. concentrations (50x DIV) supported by chemical test results. of hydrocarbons can be Mountains located in the found in spills. Mild severity: north and sloped / valley Pollution of non-sensitive water towards south. resources. Alkask Refinery Industrial area including oil Close to the water Very high Highly likely: It appears that the NIN_10 tanks, offices, and oil pipes. discharge unit pits with contamination is leaking in the high concentrations river. (50x DIV) of aromatic hydrocarbons can be found Severe severity: in spills. Additionally, at Short-term risk of pollution of the riverbanks evidence of sensitive water resource used hydrocarbon pollution has by local communities as a source of been observed. domestic water. Chemical Site used to store Localized aromatic Moderate Likely: Visible evidence of localized Contaminated Site disused transformers. hydrocarbons spills from / low contamination supported by NIN_11 leaking transformers show chemical test results. very high concentrations (100x DIV). Due to the Mild severity: number of transformers on Pollution of non-sensitive site there is a significant water resources. risk of more spills as the transformers degenerate. Alhukamaa The company drains industrial The soil is slightly Low Low likelihood: No visible or olfactory Pharmaceutical water to the surrounding land contaminated with nickel evidence of contamination, but Company because there is no treatment and cadmium (1x DIV). testing did identify marginally NIN_12 unit. (The whole facility was elevated nickel and cadmium. destroyed in 2016.) Mild severity: Pollution of non-sensitive water resources. 105 Conflict Pollution in Iraq Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Ninevah Ninevah Out-of-service factory. There are many old, expired Moderate Low likelihood: no visible or olfactory Pharmaceutical The factory is almost components in the facility that / low evidence of contamination, but Industrial Company totally destroyed. may ultimately lead to spillage. testing did identify marginally NIN_14 Large quantities of The soil is slightly contaminated elevated nickel and cadmium. expired material / with nickel and cadmium (1x DIV). chemicals identified Medium severity: on site. Potential chronic damage to human health should surrounding residents come into contact with onsite contaminated material. Chemical Site is deserted and There is a lot of asbestos on the Moderate Highly likely: Visible evidence of Contaminated Site largely destroyed, with site that could lead to health risks. contamination supported by NIN_15 a lot of rubble. The soil underneath a transformer chemical test results. that is located inside is highly contaminated with aromatic Medium severity: Potential chronic hydrocarbons (50x DIV). Due to long term affects on human health. the fact that this contamination is inside a separate room, it is not expected that this contamination will spread or lead to any health risks to the community. Al Kindy General Destroyed with There are a lot of destroyed Moderate Low likelihood: No visible evidence Company remaining rubble. buildings and rubble on the site. / low of onsite contamination has NIN_16 No visible contamination can be been identified. Contamination of detected. Lab analyses show that surface water identified during the soil is not contaminated. The lab testing is thought to originate analyzed water sample, however, from offsite sources. shows severe concentrations of Indeno (1,2,3-cd) pyrene Medium severity: Long-term risk (>100x DIV). This could cause of pollution of sensitive water serious health problems if flora or resource, which local communities fauna come into direct contact use as a source of domestic water. with this water. It is also likely to There is chronic risk to human spread during rainy periods. health if they use that water. Baghdad Ibn Sina Company Production of The soil in general seems to be Moderate Likely: Asbestos building materials BAG_01 liquid fertilizer. enriched in antimony (5–10x DIV). identified on site and potentially It is unclear whether this is natural within the made ground. Antimony Four buildings were or that this is part of a substance found but source not known. destroyed in the used in this facility. 1991 uranium Medium severity: Chronic damage to enrichment plant. human health receptors. Bader Company An operational The soil samples contain an Moderate Low likelihood: Relatively BAG_02 mortar bomb facility elevated concentration (1x DIV) / low modern facility, no clear sign approximately of lead. Both groundwater and of contamination. Testing has 188,000 m2 in area. surface water nearby show no sign identified elevated levels of lead. of contamination. Relatively modern, Medium severity: no clear sign of Chronic damage to human contamination. health receptors. Land Remediation for Livelihoods Restoration 106 Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Baghdad That Alsawary Rocket fuel and chemicals The factory is scattered Moderate Likely: Hydrocarbon contamination Company supplying a battery plant. with scrap metal, debris, / low identified, although contamination BAG_03 and rubble. Locally there levels appear to be relatively Currently the factory is are spills or leakages low. Risk to offsite receptors is not working. that cause aromatic therefore considered low. hydrocarbon contamination in soil (10x DIV). The Mild severity: surface water close to the Pollution of non-sensitive water facility is not contaminated resources. above the LLD. However, one sample could not be tested due to presence of NAPL. Ibn Al Waleed Used as military base Lab results indicate Moderate Low likelihood: Levels of BAG_04 and looks relatively well elevated levels of / low contamination appear to be maintained. There are some lead (1x DIV). Despite relatively low and therefore risk to areas of scrap material. visible confirmation of offsite receptors is considered low. hydrocarbons, lab results There is some risk to the staff if did not show indication of they interact directly with the soil. a diesel spill. Groundwater is not contaminated. Medium severity: Contamination identified on site has the potential to cause chronic damage to human health receptors. Al Harith Factory Tank repair factory Despite the visible Moderate Low likelihood: Limited visible and BAG_06 observations and / low olfactory evidence of contamination. odors of chemicals and Chemical tests did not identify the contamination, neither presence of contamination in the soil nor surface water samples analyzed. show analytical evidence of contamination. Medium severity: Potential pollution of sensitive water resources, ecological receptors, and chronic damage to people both on- and offsite. Notwithstanding the above, the site is confirmed to be in good repair. Baghdad Lead Recycling depleted batteries Scrap metal, asbestos, and High Likely: Visible and olfactory Extraction Facility to lead. tar storage. evidence of contamination and high BAG_08 concentration (>100x DIV) of lead Soil samples contain a high in soil samples. concentration (>100x DIV) of lead, high concentrations Severe severity: Short-term risk of other metals (>5x DIV) of pollution of sensitive water and aromatic hydrocarbon resources, ecological receptors, contamination. and people both on and off the site. 107 Conflict Pollution in Iraq Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Babil Al Furat Company Sulfur noted on the ground Across the facility scrap Very high Highly likely: Contamination BAB_01 and the road of the station. metal, asbestos, sulfur, and identified within the made ground chlorine deposits have been include ng asbestos, sulfur, and Chlorine tank is discharged observed. chlorine deposits. The soil in directly to the channel of general seems to be contaminated wastewater treatment plant. The soil in seems to be with mercury and antimony generally contaminated (5x–10x DIV). with mercury and antimony (5x–10x DIV). Severe severity: There is the possibility of short-term acute risk to human health. Diyala Diyala Electrical The site itself is covered The soil is locally Moderate Likely: Areas of contamination Industries Company in hardstanding but areas contaminated with noted, but it is unclear if this DIY_01 of visible contamination aromatic hydrocarbons contamination will impact offsite were found away from the (>10x DIV), and antimony receptors. The nearest residential hardstanding. and molybdenum (5x DIV). receptors are 200m away. Water in the water Medium severity: Chronic damage treatment facility has very to human health receptors. high concentrations of pyrene, perylene, and other sVOC components (>100x DIV). The fact that the facility has several manholes without oil separators makes it likely that water from the treatment may spill or leak into the sewer / groundwater / irrigation water, leading to significant health risks for surrounding communities. Al Anbar State Company The factory was used The factory was completely Low Low likelihood: Based on historical for Phosphate in to produce: destroyed by due to use and current status of the Al-Qaaim City • Triple phosphate fertilizers bombing. As a result, there factory, some contamination ANB_01 • Compound fertilizers is a lot of scrap metal should be expected on the site • Urea on the site. Chemical even if none has been identified • Phosphoric acid testing of soil and water by soil testing. While there is • Sulfuric acid. samples did not identify a risk that this contamination contamination above will impact nearby residential Factory destroyed but old tanks the LLD. communities, the distance (1km) and infrastructure visible. makes this risk unlikely. Medium severity: There is a risk of chronic damage to human health. Land Remediation for Livelihoods Restoration 108 Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Al Anbar Alamer factory Alamer Factory is located in Onsite chemical storage Low Low likelihood: Based on historical ANB_03 an area of arid desert where warehouses had poor use and current status of the there is no vegetation cover storage practices and factory, some contamination surrounding the site except visible contamination should be expected on the site for some desert plants. on the flooring. Some even if not identified by chemical This company specializes in chemicals were testing. While there is a risk of military heavy production unidentifiable. Chemical this contamination impacting (military equipment). Indoor testing of soil and water current site users and residential / chemical storage areas show samples did not identify farming communities, the distance signs of contamination contamination above the (700m) makes this risk unlikely. on flooring. LLD, with the exception of silver within a single soil Medium severity: There is a risk of sample (>1x DIV). chronic damage to human health. Haditha Oil Refinery Oil pit without liner Despite observations Moderate Likely: Evidence of hydrocarbon ANB_04 (discharged directly to of hydrocarbon contamination including presence the ground). contamination, the of VOC in surface waters. analyses do not show However, the samples and Water treatment unit evidence that the soil contamination are located within designed to treat TPHs 2,000 is contaminated. an oil pit away from the most ppm now receives 8,000 ppm sensitive receptors. and discharges to the ground Testing of water from the directly too. water treatment indicated Medium severity: Long-term chronic very high concentrations impact to human health likely to Oil refinery receives crude oil of pyrene, perylene, and residence nearby, especially those to use to produce naphtha, other sVOC components within the refinery boundary. kerosene, and fuel. (50–100x DIV). Pesticides Factory Al-Falluja City Pesticide Despite the odor of Moderate Likely: Contamination due to Al-Falluja City factory. pesticides, the soil sample / low historical use. ANB_05 and water samples tested show contaminants below Mild severity: Pollution of LLD. The investigation did non-sensitive water resources. not test for the most likely COPC including herbicides, pesticides, asbestos, and Polychlorinated Biphenyl. Al Shahid Company This company works in metal Locally the soil is Moderate Likely: Contamination due to ANB_06 smelting and forming (copper slightly enriched with / low historical use. Poor storage and brass mainly). It operates copper (1x DIV). No other of chemicals on site with the six smelters that run on contaminants were potential for future release. liquid fuel. The company also detected by the soil contains an electroplating analyses. Minor severity: Site staff identified unit for copper plates. The as receptor. Non-permanent company was operating during The water sample taken human health effects easily the time of the visit. shows no evidence of prevented by use of personal contamination. One water protective clothing. sample was not tested due to presence of NAPL. 109 Conflict Pollution in Iraq Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Kirkuk Sarolo Station Wet oil unit In several locations, Moderate Likely: There is evidence of KIR_01, Sarolo evidence of hydrocarbon hydrocarbon contamination on the Station KIR_04, spills can be identified. site (>10x DIV). The hydrocarbon and KIR_05 The soil that was sampled leaks are noted to be confined to is contaminated with natural storage pits. aromatic hydrocarbons (>10x DIV). Medium severity: Chronic damage to human health for the small number of site staff. Sarolo Station Degassing station and There is a spill of High Highly likely: There is a hydrocarbon KIR_02 oil product. approximately 20 m² spill of approximately 20 m². where the soil is severely contaminated with Medium severity: aromatic hydrocarbons, Significant damage to the although this has not been ecosystem, crops, and pollution identified in the chemical of non-sensitive water resources. test results. However, unlikely to be a direct threat to human health due to the Testing indicates that remote nature of the site. the soil is enriched in silver (>5x DIV) though this is interpreted to be naturally occurring. Sarolo Station An industrial site that Evidence of hydrocarbon Moderate Highly likely: There is KIR_03 includes gas compression spills is visible in several visible evidence of and isolation units, as well as locations. However, lab hydrocarbon contamination. wet oil treatment units. The results show there is surrounding land is polluted. exceedance of the LLD, Mild severity: Pollution of The surrounding land is except for silver. non-sensitive water resources, polluted industrial sites, which but direct threat to human health includes isolation and gas unlikely due to the remote nature compression units, in addition of the site. to wet oil treatment units. Dawood Station for Degassing station The soil is locally severely Moderate Low likelihood: Contamination Oil Refining KIR_06 Dawood oilfield. contaminated with identified. Contamination stored aromatic hydrocarbons in unlined pit, therefore there is Two-phase separators and (>100x DIV). a chance it will leach into the tanks for oil storage. underlying groundwater and affect The well water was offsite receptors. Previous oil spills were analyzed and is caused by broken tankers contaminated with Medium severity: Chronic damage and pipelines. benzene, toluene, to human health. xylene, and aromatic Spills are handled by Health, hydrocarbons. Due to the Safety and the Environment fact that residents and Division (North Oil Company). agricultural lands are close by there might be a risk to their health. Land Remediation for Livelihoods Restoration 110 Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Kirkuk Bai Hassan North The station has the following The soil is locally severely High Highly likely: Degassing Station units: contaminated with Hydrocarbon contamination KIR_07 • Degassing unit aromatic hydrocarbons identified and proven through • Wet oil unit (10x to >100x DIV). chemical testing. • Gas compressor unit • 40 production wells There are somewhat Medium severity: Pollution of • 7 injection wells. higher concentrations of non-sensitive water resources arsenic in the soil (1x DIV) connected to sensitive water The total production is which might be a natural resources such as the Zab river. 40,000 barrels per day. occurrence. The current production is 31,000 barrels per day. Bai Hassan North Soil sample taken. High Highly likely: Hydrocarbon Degassing Station However, lab testing contamination identified and KIR_08 could not be undertaken proven through chemical testing. due to presence of free phase hydrocarbons. Medium severity: Pollution of non-sensitive water resources connected to sensitive water resources such as the Zab river. Bai Hassan North The soil is locally highly High Highly likely: Hydrocarbon Degassing Station contaminated with contamination identified and KIR_09 aromatic hydrocarbons proven through chemical testing. (50x DIV). Medium severity: Pollution of There are somewhat non-sensitive water resources higher concentrations of connected to sensitive water arsenic in the soil (1x DIV), resources such as the Zab river. which might be a natural occurrence. No groundwater data available. Bai Hassan North Despite visible evidence High Highly likely: Hydrocarbon Degassing Station of contamination, contamination identified and KIR_10 the soil sampled does proven through chemical testing. not show evidence of being contaminated. Medium severity: Pollution of However, there are higher non-sensitive water resources concentrations of arsenic connected to sensitive water in the soil (1x DIV), resources such as the Zab river. which might be a natural occurrence. The groundwater from a farm well used for irrigating crops shows high concentrations of various SVOC such as Indeno (1,2,3-cd)pyrene (>50x DIV). 111 Conflict Pollution in Iraq Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Kirkuk Bai Hassan North The soil is locally severely High Highly likely: Degassing Station contaminated with Hydrocarbon contamination KIR_12 aromatic hydrocarbons identified and proven through (10x to >100x DIV). chemical testing. There are somewhat higher Medium severity: Pollution of concentrations of arsenic non-sensitive water resources and barium in the soil (>1x connected to sensitive water DIV), which might be a resources such as the Zab river. natural occurrence. Bai Hassan North The soil is locally severely High Likely: Hydrocarbon contamination Degassing Station contaminated with identified and proven through KIR_13 aromatic hydrocarbons chemical testing. (10x to >100x DIV). Mild: Pollution of non-sensitive There are somewhat higher water resources. concentrations of arsenic and barium in the soil (>1x DIV), which might be a natural occurrence. Baba Gurgur Station Degassing station, wet oil A spill originating from High Highly likely: Hydrocarbon KIR_14 proccing, and gas compressor the factory is spreading contamination over a significant with gas drying units. down the slope. The soil is area is likely to come into contact severely contaminated with with a number of receptors. aromatic hydrocarbons (>100x DIV) and TPH Medium severity: (>5x DIV). Due to the Such contamination has the sloping terrain, the spill has potential to cause chronic damage spread approximately 8 km to human health and significant to the south, most likely environmental impacts. passing villages, agricultural lands, and surface water that may risk exposure to the contamination. Despite the visible evidence and odor of hydrocarbons, surface water only shows contamination of hexachlorobenzene (>5x DIV), which is often used as pesticide. Baba Gurgur Station Wet oil treatment plant. The soil is, in certain Moderate Likely: There is visible evidence KIR_19 places, contaminated with / low of hydrocarbon contamination aromatic hydrocarbons that has been confirmed through (>10x DIV). chemical testing. Mild severity: Pollution of non-sensitive water resources. Land Remediation for Livelihoods Restoration 112 Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Kirkuk Bai Hassan South Degassing station, wet A pathway of oil is High Highly likely: Oilfield KIR_15, oil processing, and gas spreading outside the There is visible evidence of KIR_17, and KIR_23 compressor with gas facility. The soil in close hydrocarbon contamination that drying units. proximity of this location is has been confirmed through severely contaminated with chemical testing. Oil visible at surface in pit aromatic hydrocarbons and drainage ditches. (10x–>100x DIV). Medium severity: Such contamination has the There are somewhat potential to cause chronic damage higher concentrations of to human health and significant arsenic in the soil (1x DIV). environmental impacts. which might be a natural occurrence. The contaminations are spreading through a manmade pathway and may contaminate surface water and residential areas (within 500 m). Serbach Station Gas isolation station. The soil is severely Moderate Highly likely: There is visible evidence KIR_16 Pipeline leakage. contaminated with of hydrocarbon contamination, aromatic hydrocarbons which has been confirmed through (>100x DIV). In some chemical testing. locations old spills have been covered up with clean Mild severity: Significant damage soil. No water has been to crops and pollution of sampled or identified. non-sensitive water resources are possible. Haljira Gas Isolation Hanjira gas isolation station. There are locations Moderate Highly likely: There is visible Station KIR_18 and that show clear visual evidence of hydrocarbon KIR_20 evidence of hydrocarbon contamination, which has contamination. been confirmed through The sampled soil shows chemical testing. elevated aromatic hydrocarbon concentrations Mild severity: Pollution of (> 100x DIV). non-sensitive water resources. Showraw Station & This is an asphalt production Based on the sampled Low Low likelihood: No visible or Kat Factory KIR_24 plant that includes several soil and the sampled olfactory sign of contamination. departments. water from a well used for reverse osmosis. there is Mild severity: Pollution of No contamination was no contamination above non-sensitive water resources observed on the site, which the adopted DIV with the including stream and water appears to be well maintained exception of silver in abstraction wells (used for including lined ponds. soil samples. reverse osmosis). Hawija Pesticides Yellow corn plant, seed Based on the sampled soil Moderate Likely: Visible and olfactory signs Stores KIR_25 purification, and storage. and the sampled water / low of contamination identified on site. from the well, there is no The factory was damaged contamination on this Mild severity: Pollution of by bombing. site. However, fieldworkers non-sensitive water resources. noted seeing and smelling chemicals. 113 Conflict Pollution in Iraq Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Kirkuk Mulla Abdulla The first station of the The soil samples collected Very high Highly likely: Significant area of Station (IT1)KIR_26 Iraqi-Turkish oil line. The indicate exceedance of hydrocarbon contamination likely station stores and pumps 1x DIV for arsenic and to impact multiple receptors. oil received from the TPH, though there is a 10x concentration station, which exceedance relating to Severe: There is a possibility is located adjacent to Mulla total aromatics. of short-term acute risk to Abdulla Station. human health. The date of establishment is 1975. Qutan Gas Isolation Qokan gas isolation station / The contamination on High Highly likely: Hydrocarbon pollution Station—Babakkar Babakkar oilfield this hotspot exists from is present, with evidence of historic Oilfield KIR_28 a single pit of aromatic surface runoff increasing likelihood hydrocarbon spill. of direct contact with residents. The soil close to this Medium severity: storage pit exceeds the DIV Chronic damage to human health at least 10 times. The site posed to nearby residents. is littered with old pipes and insulation. Gas and Oil Degassing station since 1956, A spill that originates from High Highly likely: Hydrocarbon Separation Plant in destroyed in 1991 and 2003. the factory is spreading contamination over a significant Jabal Bur The plant’s production is down the slope. The soil area is likely to come into contact KIR_30 12,000 barrels per day. is contaminated with with a number of receptors. aromatic hydrocarbons The total number of producing (>10x DIV). Medium severity: wells is 41 and the number of Such contamination has the operating during the visit is potential to cause chronic damage 6 wells. to human health and significant environmental impacts. Plant sends gas to a gas compressor station in North Oil Company. Waste oil is sent to two unlined pits outside the fence of the station. Showraw Station & This is an asphalt production Based on the sampled Low Low likelihood: No visible or Kat Factory KIR_24 plant that includes several soil and the sampled olfactory sign of contamination. departments. water from a well used for reverse osmosis. there is Mild severity: Pollution of No contamination was no contamination above non-sensitive water resources observed on the site, which the adopted DIV with the including stream and water appears to be well maintained exception of silver in abstraction wells (used for including lined ponds. soil samples. reverse osmosis). Khabaz Gas Station Gas isolation plant that Contamination and oil Moderate Likely: Hydrocarbon contamination KIR_31 produces 26,000 barrels spills found at several / low identified and confirmed through per day. locations, and soil severely chemical testing. contaminated with Wet oil unit to separate water aromatic hydrocarbons Mild: Pollution of non-sensitive from oil so that the oil is (5x–>100x DIV). water resources. Significant ready for export. damage to crops Analyzed surface water A unit to compress the gas is severely contaminated and send it to the North Gas. with SVOC (perylene, pyrene; 100x DIV) and hexachlorobenzene (1x–5x DIV). Table F1: Summary of risk assessment (continued) Site name Chemical results Risk and hotspot Notes Justification and conclusions rating ID Kirkuk Ajil Oil Field Ajil oil field produces Soil samples show evidence Moderate Highly likely: SAL_001_H, 10,000–15,000 barrels per day, of aromatic hydrocarbon Visible hydrocarbon contamination SAL_011_H, which includes production in the Alas contamination (>50x DIVs). at surface confirmed by chemical SAL_012 field. test results. Satellite imagery Sampled groundwater indicates extensive contamination. The total number of wells: 90 wells, from wells in agricultural including a field (Ajil, Alas, and Al- land show dangerously high Medium severity: Nakhila). concentrations of SVOC Pollution of sensitive water (chrysene, Indeno(1,2,3-cd) resources. Significant damage CPF to separate the associated pyrene; 100x DIV). to crops. gas and send it to the North Oil Company at a rate of 70–100 cubic Other SVOCs are found in meters per day. lower concentrations. Alass Oil Field 83 oil wells, of which eight Samples show evidence Moderate Highly likely: Visible contamination SAL_002_H are productive. of aromatic hydrocarbon confirmed by laboratory testing. contamination (>50x Opportunity for site visits were DIVs) in the soil close to Mild severity: Pollution of limited because the area is unsafe an isolated oil pit. The non-sensitive water resources. (ISIS and UXO). pit is located in between mountains on an isolated spot, so there are no residents or staff in this area to be exposed to this contamination. Northern Company established in 1990, in The soil is enriched in lead Moderate Likely: Visible contamination Fertilizers operation until 2014, when it was and other metals (5x DIV). confirmed by laboratory testing. Company destroyed in an ISIS attack. The SAL_003_H site is littered with scrap metal and Earlier research claimed the Mild severity: Pollution of rubble. presence of two radioactive non-sensitive water resources. reactors, of which only one Main location: Salah al-Din is still present. Governorate, Baiji District. The site is abandoned, Produces nitrogen (urea-based) there are no residential fertilizers and petrochemical areas nearby, and there is products. no contact with surface water, so there is no health A report from the national security or spreading risks for these says there is a radioactive element contaminations. in a reactor device ((301D) high pressure reactor (co 60) Intensity (mbq) 400–2000). The second reactor was not found in its place (high pressure stripper). AL Mansour AL Mansour Factories for Vegetable Aromatic hydrocarbons Moderate Highly likely: There is evidence of Factories for Oils was destroyed in the war leaked out of a transformer groundwater contamination based Vegetable Oils with ISIS. (> 100x DIV). on chemical test results. SAL_004_H Sampled groundwater from Mild severity: Pollution of non- wells at the site shows sensitive water resources. high concentrations SVOC (chrysene, Indeno(1,2,3-cd) pyrene; 50x DIVs). Other SVOCs are present in lower concentrations. 115 Conflict Pollution in Iraq Table F1: Summary of risk assessment (continued) Site name Chemical results Risk and hotspot Notes Justification and conclusions rating ID Kirkuk Baiji Power The plant was destroyed by bombing. The soil is contaminated Moderate Likely: Historical spills caused Plant with aromatic / low by bombing. SAL_005_H The station has six units with a hydrocarbons (>10x DIV). capacity of 169 megawatts per unit, Mild severity: Pollution of and a total capacity of about non-sensitive water resources. 1,000 megawatts. Salah Al-Din This site is located in an open The soil is contaminated Moderate Likely: Visible evidence of SAL_06, area between the North Fertilizers with aromatic / low groundwater contamination SAL_006_H Company and Baiji Oil Refinery. hydrocarbons (>10x DIV). supported by chemical testing. The site is not surrounded by any Mild severity: Pollution of buildings, infrastructure or factories. non-sensitive water resources. It has been sampled because it is an historical contamination without a known cause. Al Seenia The refinery was built in 1976 and The sampled soil shows Moderate Likely: Multiple sources of Oil Refinery consists of several units capable of evidence of aromatic contamination observed on site SAL_007_H producing fuel oil, gas oil, naphtha, hydrocarbon contamination and proven by chemical testing. kerosene, and other chemicals. (>100x DIVs). However, nearby residents are Production capacity is 30,000 Sampled groundwater from upgradient of the site, reducing barrels per day. Only three units are an agricultural well close by the likelihood that contamination operation and a (waste disposal point) will migrate in this direction. show dangerously high Oil spills, bombed oil storage tanks concentrations of SVOC Medium severity: There is potential during war, and leakage from old (chrysene, Indeno(1,2,3-cd) for long-term chronic damage to pipelines were observed. pyrene; 100x DIVs). human health. Other SVOCs are present in lower concentrations. Baiji Refinery The refinery consists of several The sampled soil locally Very high Highly likely: Multiple sources / North Oil production units producing different shows evidence of aromatic of contamination identified, Company kinds of fuel and chemicals. hydrocarbon contamination observed on site, and proven by SAL_009_C (>100x DIVs) in the soil. chemical testing. 70% of the refinery, including two refineries with a capacity of 10,000 Sampled water on site Sever severity: Nearby residents at barrels per day and 9 storage tanks, show dangerously high risk from contamination that has were destroyed by war. concentrations of SVOC migrated off site. VOCs present an (chrysene, Indeno(1,2,3-cd) acute risk to human health. Four storage tanks were partially pyrene; >100x DIVs). destroyed and are currently under construction. Other SVOCs are present in lower concentrations, as is aromatic hydrocarbon contamination. Salah Al-Din The site is an open area not The soil is contaminated Moderate Low likelihood: Visible evidence SAL_10, surrounded by any buildings, with aromatic / low of groundwater contamination SAL_010_IC infrastructure or factories. It has hydrocarbons (>100x DIV). supported by chemical testing. been sampled because it is an historical contamination without a Mild severity: Pollution of known cause. non-sensitive water resources. Land Remediation for Livelihoods Restoration 116 Table F1: Summary of risk assessment (continued) Site name and Chemical results Risk Notes Justification hotspot ID and conclusions rating Kirkuk K2 Station Land between K2 and K3 pumping The site contains small Low Likely: Surface oil spills identified SAL_013 station. The refinery was established spills that show visible on site but extent is limited. in 1966. evidence of aromatic hydrocarbon contamination. Minor severity: Site staff The sampled soil, however, identified as the most likely is not contaminated. It receptors. is likely that the spills are small and local and pose no immediate risk to surrounding communities or staff (if not directly contacted). A General The factory was established in 1980 The site contains factories High Highly likely: There are a number Company for and includes: with multiple occupations. of contaminating land uses. Communication • A digital meter factory A strong chemical odor Chemical testing has identified Equipment was detected near an old high levels of metals in the soil. and Power • An electrical transformer paint-production facility. SAL_014_C repair factory The soil here was severely Medium severity: The most • A paint factory (currently out contaminated with metals relevant receptor is considered to of service) such as copper, silver (100x be residential in close proximity • Storage for chemicals DIV), antimony (50x DIV), to the site. Chronic damage to lead and chromium human health is a possibility. • A treatment unit of a paint (> 10x DIV). factory • Metal columns and towers factory. Al Fatha Historical contamination and the Visible areas show leaks Very high Highly likely: Visible evidence SAL_015_H source not unknown. An oil pipe in the pipes over the of hydrocarbon contamination crosses over the Tigris River. river, contaminating the supported by chemical testing of riverbanks and most likely soil and water samples. the river itself. Severe severity: Short-term Samples are severely risk of pollution of sensitive contaminated by aromatic water resources. hydrocarbons (>100x DIVs). River water shows contaminations with chrysene (>10x DIV) and perylene (> 50x DIV) close to the riverbanks. Al Sahl Valley Al Sahl is a valley where oil pipelines Visible areas show ongoing High Likely: Visible evidence of SAL_016_H are in a mountainous area that leaks from oil pipelines that hydrocarbon contamination slopes down approximately 2 km to make their way down to supported by chemical the Tigris river. Here, hydrocarbon the river. testing of soil and water waste accumulates as a result samples. Attempts to stop the of leakage in the pipelines from Samples are contaminated contamination have been made maintenance operations and with high concentrations but do not appear to have been terrorist attacks. of aromatic hydrocarbons effective. There is a possibility (>50x DIV). contamination will reach the The potential source is Biji Refinery. Tigris river. Water samples show contaminations with Severe severity: Short-term chrysene (>10x DIV) and risk of pollution of sensitive perylene (>100x DIV). water resources. Source: Site Assessment and Analysis by MoE and RSK Environment LLC 2022. 117 Conflict Pollution in Iraq Appendix G: Participants of stakeholder consultations Stakeholder no. Name Position and organization Consultations in Baghdad (March 19, 2023) 1 Mohammed Amjad Ahmed Baghdad Environment Department 2 Jasim Ali Nawar Ministry of Environment – Technical Department 3 Hanan Mahmood Sulyman Falowja Environment Department 4 Ahmed Kamil Dawood Anbar Environment Department 5 Ihab Moayed Shihab Haditha Refinery 6 Abdul Ghafoor Md Abdul Ghafoor Ministry of Oil 7 Ahmed Khalaf Khamees Ministry of Oil 8 Mostafa Salim Rasheed Ministry of Environment 9 Waleed Ali Hussein Ministry of Environment 10 Abdul Rahman Majeed Abdul Jalil Ministry of Environment 11 Monther Noaaman Thabet Haditha Sub-District office 12 Husham Ahmed Hashim Aby Ghraib Sub-District Office 13 Dhafer Hobi Abdullah North Refinery Company – Haditha Refinery 14 Raad Faisal Abbas Mayor of Al Taji District – Baghdad Governorate 15 Raed Mohammed Khalaf Mayor of Al Tarmiya District – Baghdad Governorate 16 Ammar Al Aaraji Mayor of Al Rasheed District – Baghdad Governorate 17 Ahmed Ali World Bank Representative 18 Nada Mohammed Ibraheem Iraqi Organisation for Women And Future 19 Israa Gareen Qasim Al Israa for Human Rights Care 20 Ikhlas Abdullah Khalaf Al Israa for Human Rights Care 21 Sameem Salam Jali Soqya Foundation – Anbar 22 Omar Fadhil Salih Al Haq Foundation For Human Rights – Anbar 23 Dhuha Alaa Al Falahi Al Aghsan Foundation – Anbar 24 Anas Ibraheem Hamad Dream Organisation – Baghdad 25 Waleed Ali Hussein Ministry of Environment – Technical Department 26 Mustafa Salim Rasheed Ministry of Environment – Technical Department 27 Mais Bahri Sabbar Baadna B Khair Organisation – Anbar Consultations in Kirkuk (March 12, 2023) 1 Dr. Mohammed Khodir Mohammed Kirkuk Environment Department 2 Nishtiman Fattah Ammeen Kirkuk Governor Office 3 Hasan Abid Lateef Al Dibis District Mayor Land Remediation for Livelihoods Restoration 118 Appendix G: Participants of stakeholder consultations (continued) Stakeholder no. Name Position and organization 4 Montasir Naji Abdullah Salah Al-Din Environment Directorate 5 Ammar Saleem Mahjoob Ninewa Environment Directorate 6 Alyaa Sarmad Abid Alwahab Ministry of Environment – Minister Office 7 Waleed Ali Hussein Ministry of Environment – Minister Office 8 Laith Mohammed Khalaf Baiji Refinery 9 Dhafer Howayesh Abdullah Baiji Refinery 10 Colonel Jazey Sameer Mahmood Kirkuk Environment Protection Police 11 Monther Md Abid Alkareem Kirkuk Environment Protection Police 12 Mohammed Jabbar Khudhair Kirkuk Environment Protection Police 13 Mohammed Ahmed Najim Addin Northern Environment Department 14 Ribwar Mohammed Ismaeel Intelligence Department 15 Husam Abid Al Mutalib Ministry of Environment – Technical Affairs Dept. 16 Mohammed Salman Hasan North Oil Company – Operation Department 17 Talib Hussein Khalil North Oil Company – Operation Department 18 Riyadh Adham Abdullah North Oil Company, HSE Department – Environment 19 Najdat Khalid Shafeeq North Oil Company – Operation Department 20 Tahseen Yaseen Tawfeeq North Oil Company, HSE Department – Environment 21 Mazin Faiq Mahmood Kirkuk Environment Department 22 Salih Jasim Mohammed Head of Farmers Associations in Al Dibis District 23 Rokan Awad Khaleel North Oil Company – Oil Pipes Section 24 Ali Abdul Malik Kirkuk National Security Department 25 Karbaesh Majeed Aswad North Oil Company – Environment Department 26 Shkoofa Mohamed Ubaid Green Kurdistan Organisation 27 Hawary Hashim Sayed Kokar Foundation 28 Mohammeed Habib Najeeb Kokar Foundation 29 Husam Abid Almutalib Hashim Ministry of Environment – Technical Affair Dept. 30 Waleed Ali Hussein Ministry of Environment – Minister Office 31 Saad Salih Mahdi Nahno Al Salam for Voluntary Work Organisation 32 Yaseen Faraj Yaseen Ta’alo Nasna’a Al Farah Organisation 33 Omar Qusai Khairullah Ta’alo Nasna’a Al Farah Organisation 34 Omar Hamid Mohammed Ta’alo Nasna’a Al Farah Organisation 35 Mokhtar Hashim Mohammed Nahno Al Salam for Voluntary Work Organisation 36 Halo Ali Hama Kokar Foundation 119 Conflict Pollution in Iraq Appendix H: GoI Project team Stakeholder Name Position and organization no. Ministry of Environment, Government of Iraq 1 Waleed Ali Hussein Senior Chief Engineer, Technical Director, Air Quality and Noise Monitoring and Assessment Department 2 Hussam Abdel Muttalib Hashim Chief Engineer, Oil Pollution Division 3 Emad Ali Saleh Senior Chief Engineer, Industrial and service activities monitoring Department 4 Amer Abdel Karim Nasser Chief Chemist, Contaminated Sites Division 5 Ali Sami Khashan Associate Chief Biologist, Contaminated Sites Division 6 Mustafa Salem Rashid Chief Engineer Assistant, Carcinogenic Factors Division 7 Rasha Raad Salman Chief Engineer Assistant, Carcinogenic Factors Division 8 Rafal Adel Nasser Senior Engineer, Carcinogenic Factors Division 9 Mahmoud Khaled Mahmoud Chief Chemist, Hazard Waste Division 10 Aliaa Sarmad Abdel Wahab Chief Engineer Assistant, Industrial and service activities monitoring Department 11 Mohammed Adel Assaf Chief Chemist, Following Department 12 Mohamed Ahmed Najmuddin Senior Chief Engineer, Technical Department, Directorate of Environmental Protection and Improvement in the Northern Region 13 Ammar Selim Mahjoub Chief Chemist, Technical Department, Ninevah Environment Directorate 14 Sabah Muhammed Salim Senior Chief Chemist, Contaminated Sites Division, Ninevah Environment Directorate 15 Mazen Faeq Mahmoud Engineer, Contaminated Sites Division, Kirkuk Environment Directorate 16 Miqdam Adel Mahmoud Chemist, Contaminated Sites Division, Salah al-Din Environment Directorate 17 Jassim Ali Nawar Senior Chemist, Technical Department, Directorate of Environmental Protection and Improvement in the Central Region 18 Mohamed Amjad Ahmed Engineer, Contaminated Sites Division, Baghdad Environment Directorate 19 Ahmed Kamel Daoud Assistant Chief Chemist, Contaminated Sites Division, Anbar Environment Directorate 20 Salem Jassim Dahesh Assistant Chief Chemist, Contaminated Sites Division, Diyala Environment Directorate 21 Harith Jalil Razzouqi Senior Chief Chemist, Contaminated Sites Division, Diyala Environment Directorate 22 Adnan Yas Khudair Senior Chief Engineer, Contaminated Sites Division, Babil Environment Directorate 23 Moath Walid Ibrahim Engineer, Contaminated Sites Division, Babil Environment Directorate Other organizations 24 Tahseen Yassin Tawfik Senior Chief Engineer, Health Safety Environment Department, North Oil Company (external to MoE) 25 Muhammad Mukhlif Aswad Technical, Health Safety Environment Department, Ninevah Fields Authority 26 Dhafer Howish Abdullah Associate Chief Biologist, Health Safety Environment Department, North Refineries Company 27 Laith Hamad Khalaf Associate Chief Biologist, Health Safety Environment Department, North Refineries Company 28 Hussam Thabet Nofan Technical Manager, Following Department, Haditha Refinery 29 Hisham Abdel Nabi Khalifa Chief Engineer, Health Safety Environment Department, Haditha Refinery Land Remediation for Livelihoods Restoration 120 References Carroll C, Slacalek J, Tokuoka K, and White MN. 2017. “The Distribution of Wealth and the Marginal Propensity to Consume.” Quantitative Economics 8: 977–1020. https://doi.org/10.3982/QE694. 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