Corection Protocol v.3 Iunie 2010

1
Correction Protocol for version 3

of application and supporting documents for Extension and Rehabilitation of Water Supply
and Wastewater Systems in Mure County

TA Number : Technical Assistance for project preparation in the drinking water and wastewater infrastructure in Mure County
ISPA Measure No 2005 RO 16 P PA 001-03

Project : Extension and Rehabilitation of Water Supply and Wastewater Systems in Mure County

Task : Revised version of application and supporting documents for Extension and Rehabilitation of Water Supply
and Wastewater Systems in Mure County

Consultants : Eptisa Romnia/ MVV Energie AG/RODECO

Status date : June 29, 2010

This protocol represent the additions and corrections requested from the Ministry of Environment to complete the documentation needed for the
submission of the application for EC grant for the above indicated project under the Cohesion Fund.

Application Form To be fill in by the Consultant
Req. No.
Chapter
/Annex
Page/
Para.
Addition/Correction Requested
Chapter
/Page
Comments
1.

General
comment
- Please make sure various documents (AF, FS, annexes, etc)
which are part of the Financing Application have the same
project title. The main concerns are raised by the local
decisions for FS approval, land availability and EIA
documents. It is not acceptable to have different titles for the
same project.

2.

B.2.4.1
B.2.5
3 Please fill in the corresponding percentages for the specified
codes.

3. General 5 By only comparing the cost of component 9 (Band-Panet)
2

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
remark and 10 (Niraj valley), respectively 2.8 and 4.7 million, and
the length of the trunks to be constructed, respectively 25 km
and 33.1 km, and considering the topography of the two
areas (fairly hilly for the former, flat for the latter), the cost of
the second scheme seems high compared with the first one:
+70% (while only 1/3 longer).
4.

General
remark
7 We would advise to provide 3 separate maps for the trunk
component of the application in order to make the
application more readable and to be able to easily identify the
localities benefiting from the CF project (the Application
indicates that the area covered by the project concern 41
localities, on top of the main municipalities and cities). The
map provide in the AF p 7 is hardly readable.

5.

Chapter B 17/
Table
B.4.1.8
The treatment capacity of the WWTP Sighisoara after
completion of the project (2014) is ensured for 37.440 p.e.,
while, for the year 2014, it is provided a loading in the
WWTP for 42.561 p.e. and, for the year 2018, for 41.913 p.e.
This WWTP is undersized. Please explain.
The treatment capacity of the WWTP Tarnaveni after
completion of the project (2014) is ensured for 42.312 p.e.
while, for the year 2014, it is provided a loading in the
WWTP for 30.291 p.e. and, for the year 2018, for 29.713 p.e.
This WWTP is oversized. Please explain.

6. Technical
aspects
18 As all agglomerations subject to this project have more than 10,000
p.e.. (see Iernut agglomeration)
Please revise the text.

7.

22 The extension and rehabilitation of the networks in Targu
Mures include some 35 Km of pipes in total. Assuming an
average pace of works of 30 m/day (which is normally
achievable for this type of works) this result in some 1167
working days, which is a lot. As the works are subject to a
single contract, please clarify whether they will be tendered

3

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
on lots, or otherwise it will be extremely difficult, if not
impossible, to observe the implementation period.
The specific indicator investment costs per losses avoided
should be compared to the cost of supplying of 1 m
3
of
water, in order to substantiate the rehabilitation efficiency.
The same comment is also valid for the indicator investment
cost per infiltration avoided, which should be compared to
the cost of the collection and treatment of 1 m
3
of
wastewater. This is applicable to all water supply
zones/agglomerations, otherwise, if the indicators are not
benchmarked, they have no relevance.
8.

AF, B.4.2 22-29 Please having in mind that when carrying out sludge disposal,
the provisions of art. 7 of GD 349/2005 must be complied
with

9.

Component 3
and
Component 7
25 It is stated that Sighisoara and Cristuru Secuiesc agglomerations
have more than 10.000 p.e. Therefore, the reduction of the
nutrients in WWTPs /tertiary treatment is necessary. Please
add the performance of this ongoing projects financed by
BDCE.

10.

Component 6 30 It is stated that Iernut agglomeration has less than 10.000 p.e.
Therefore, the reduction of the nutrients in the WWTP is not
necessary.
At the same time, the new process must include an advanced biological
treatment, where the nutrients are reduced below the required limits, and
an improved sludge processing process.
Please revise the text.

11.

32

Rehabilitation of the trunk main Vorniceni-Sarmasu includes
41.6 km of pipes (entirely?), plus 3 pumping stations, plus 4
reservoirs. According to Consultants estimate (see table 1 on
page 5 of the AF), these would cost 9.8 M . This results in
an average of 235 /m, including everything. We estimate
that this cost would cover 1 linear metre of 400 mm HDPE

4

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
pipe.
It would be useful to know the (range of) diameter(s) of the
trunk main and what does the rehabilitation of the pumping
stations and reservoir consist of. It is also recommended to
have an indication (or reference) on unitary costs of each
component subject to rehabilitation, as the indicator
investment cost/losses avoided is high. Please clarify.
12.

Component 9 34 It is stated that both cities have already built complete
distribution systems What is the overall condition of
those? Do they fit to the design parameters of the
infrastructure proposed in the CF project (i.e. flows, heads)?
Are the materials suitable? Such information is necessary, as
the risk that the newly created infrastructure will not operate
in good condition, if the distribution network performance is
poor, cannot be ignored.
The per capita cost of this investment is 470 . This is
considerably high, therefore the affordability of this
investment component is questionable, especially bearing in
mind that the generated wastewater will have to be collected
and treated, and the related investments will put an additional
burden on the customers. Please clarify.

13.

Component
10
35 The Consultant raised the issue of the pollution of the zone,
especially of the Niraj river. This statement induces few
problems: (1) is anything envisaged in relation with the
control of this pollution? (2) what is the impact of such
pollution on the quality of the envisaged water source for the
proposed treatment works, and (3) the wastewater collection
and treatment should be an immediate priority.
Another matter of concern is that the system will depend on
a single source, and as neither storage facilities, nor inter-
connection to another system seem to have been envisaged, it
is not clear what is going to happen in the case of an
accidental pollution or failure of the intake/DWTP. Please

5

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
clarify.
14.

Component
10
35 Niraj Valley is one of the most densely populated areas in
Transylvania[...].Please indicate the figure corresponding to
this population density (per km2).
Although no information is reported in this respect, do
distribution networks already exist in localities in the Valley?
Whats about wastewater? Chapter 4 (current situation and
projections) is silent in this respect and information in annex
29 and annex X limited and not self explanatory (e.g. tables).
Also, please explain on which basis were the different
localities composing Niraj valley component chosen?

15.

Component
10
35 Please provide a breakdown for the population within the
different localities included in component 10 as it is not clear
what 18.275 inhabitants (2014) refers to.
Please note that only 12 localities are mentioned in Annex 10,
which reference is made to, with a total population not
exceeding 8,500 inhabitants.
Also please explain why the AF presents 30 localities instead?

16.

B.4.2 37 Main physical indicators table there are still some
inconsistencies of the figures in the table with those provided
in previous section (project component description):
- Catchment rehabilitation no mention about this
investment in project description;
- New trunk main the correct value is 52,885 km
(19,670 Band Panet + 33,125 Valea Nirajului), not
52,380 km, as mentioned in the table;
- New and rehabilitated pumping stations there are at
least 7 new DWPS (3 in Sighisoara, 1 in Ludus, 2 in
Band Panet and 1 in Valea Nirajului) and 3
rehabilitated (Voiniceni, Campenita, Pogaceaua)
please revise the figures in the table; as well, please
clarify the number of pumping stations (new and/or

6

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
rehabilitated) in Targu Mures (it is stated revamping
of pumping stations, not being clear how many);
- SCADA system no SCADA system was mentioned
in the description of project components;
- New/rehabilitated waste water pumping stations
there are 17 new and 8 rehabilitated, according to the
project component section, and not 22 new and 3
rehabilitated, as mentioned in the indicators table;
please clarify which figure is correct;
- Please clarify what connection
extended/rehabilitated network means; no mention
about this investment in the project description;
- Discharge pipe no mention was done about this
type of investment; please clarify!
As well, please ensure correlation of the whole list of
indicators with those provided in other chapters of the AF
(i.e. tables B.5.1.1 - B.5.1.9) or other documents (Feasibility
Study, various annexes, local decisions for FS approval).
17.

B.4.2

and
Chapter 1
and
Chapter 9
page
37-38
and
page 11
and
page 19
Please correlate data from these chapters concerning the
pumping stations for Tg.Mures.
The Northern II + III area pumping station located on 4 Verii St. is
an over ground construction, the pumps being placed ( chap.9), this
clearly states one construction for 2 PS.

18.

B.5.1. Current
infrastructure
endowment
and impact of
the project
39 Although it is mentioned that one of the project objectives
will - Reducing of the water losses in the project area by
distribution network rehabilitation from a percentage 38% in
2008 to 26% in 2014. why do the water losses in the CBA
increase in the second half of the projection period up to
reach high level of losses: 50% in Reghin, 51% in Ludus
notably? Please clarify.

19.

B.5.1 61 and
following
Table B.5.1 23 Performance indicators water supply:
7

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
s - 2.4.7 (length of transmission main) please clarify
which is the correct value before and after the
project;
20.

Water
abstraction
83 It is stated that the water abstraction shall be entirely done
through surface intake. This statement is not correct in the
case of the water supply systems which are further analysed,
as in certain options, some systems are considered to be
served by (a) new well field(s). Please clarify.

21.

AF, section E 90 -91 This referred to provision of GD 349/2005 concerning the
industrial waste landfills which have complied in terms of
activity until July 16
th
2009.
The landfills listed in the Sludge Management Option are
non-compliant municipal landfills which, in accordance with
Annex 5 of GD 349/2009, have ceased their activity within
the envisaged deadlines. Furthermore, the non-compliant
landfill at Tarnaveni is under closure procedure.
Please revise Sludge Management Option considering all of
the above.

22.

AF,
section E
90 -91
HG 349/2005, art.26, (3) refers to non-compliant landfills not to
non-hazardous industrial waste which is art.26, (2).

23.

Options for
Niraj Valley
92 In all options, only surface catchment and the associated
treatment plants were considered. Please explain the reasons
for which underground water sources were not analysed. The
hydro geological survey is talking about reduced potential
aquifer and water quality potentially non-potable, and in our
opinion this possibility (i.e. use of drains for water
abstraction and adequate treatment depending on the raw
water quality) cannot be ignored.

24.

D.1 102 Please fill in with complete dates in the following format
dd/mm/yyyy.

8

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
25.

AF, Section
F.4.1
109
Please present in the text, as a summary, the status of the
project sites in terms of NATURA 2000, including the
distance from the each project component to the nearest
NATURA 2000 sits.

26.

E.2.2 115 Table with project benefits and costs all the figures must be
expressed with two decimal digits. The total percentage for
each of the two (benefits and costs) should be 100%. Please
correct accordingly.

27.

E.2.4 116 New jobs created please fill in the average duration of the
jobs during the operational phase (12 * number of years of
the operational phase)

28.

E.3.2 117 Sensitivity analysis- critical variables:
Please clarify which are the financial and economic indicators
which the variables tested refer to only FRR and ERR are
mentioned. FNPV and ENPV should be also specified.

29.

F.3.2.3 125 - Please attach to Application Form the Screening Decisions in a
distinct Annex.
- Please attach to Application Form the EIA Summaries in a distinct
Annex.

30.

F.5 127 - The information related to Natura 2000 sites are related to
the execution of works.

31.

F.6 128 Please complete accordingly the percentage taking into
account only the costs of the measures -additional measures apart
of those included in legislation-) taken through the project to
reduce and/or compensate negative environmental impacts
and considered in the CBA. Please make also the corresponding
link with F 5.

32.

AF, Section
F.6
128 Some of the presented measures are not mitigation measures
(for example solid waste collection and disposal or
ecological toilets during the construction period).

9

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
The mitigation measures have to be more specific and the
cost estimation has to be available.
Please revise.
33.

F.7 128 - According to the compliance with Accession Treaty, please
add the necessary information, emphasizing the reach of the
targets through the project (percentages and corresponding
years) for the agglomerations from project area, considering
both wastewater and drinking water.
- Please explain how the project is consistent with Urban
Waste Water Directive and Water Framework Directive.
Please avoid the general information related to this issue and
focus on the project components.
- Regarding the reference to the accession Treaty, should
distinguish the deadlines afferent to the treatment (2015) and
to the collection (2013) for agglomerations above 10, 000 p.e.
- Related to the special request of EC, please provide for
each agglomeration the information on whether the project is
coherent with the achievement of the environmental
objectives set in the River Basin Management Plans/WFD
(see the water permits and detail with relevant information regarding the
discharge limits for N, P and BOD).
It is not necessary to attach the included tables; please
provide only the relevant information taking into account the
above requests.

34.

I.4.3 141 Conclusions of JASPERS intervention we recommend you
to add the following paragraphs:
- The proposed project is coherent with the EU policies for
environment and the Convergence objective; the project brings an
important contribution to the Accession Treaty obligations of
Romania in the field of environment.
- The proposed project is compliant with the SOP Environment

10

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
document; social, institutional and economic contexts are well
described, project objectives are defined; relevant options
assessed.
- The Managing Authority should ensure that the co-financing
funds are available in due time in order to avoid project
bottlenecks during implementation.
35.

Appendix I - It hasnt been revised. The NATURA 2000 Declarations are
the same.

Please attach the revised Natura 2000 Declarations; each of
them must be followed by the new corresponding map.

36.

Appendix I
Are Voiniceni Sarmau and Band Pnet included in the
Declaration ?
If so, then main trunk should be also included within the
works (not title of the project)

37.

Appendix I Please replace the existing map in Appendix I with NATURA
2000 maps from Volume VI EIA.
Tirgu Mures Agglomeration: Voiniceni Sarmas Main trunk
rehabilitation seems to carry on in ROSCI0079 and
ROSCI0100 sits.
Sighisoara Agglomeration: Main trunk and water treatment
plant rehabilitation seems to carry on in or nearest
ROSPA0099 and ROSCI0186 sits.
Iernut Agglomeration: The investments seem to carry on
nearest ROSPA0041 and ROSCI0210 sits.
In these cases, the information from NATURA 2000
Declaration is not correlated with the information from map
attached. Please explain.

38.

EIA Annexes - Related to the additional EIA documents please attach
to Application Form only the following distinct annexes:

11

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
- Annex with Summary of EIA procedure: this annex
must include only the timetables for EIA procedure -
the documents named Annex 2, issued and signed by
EPAs (the original documents);
- Annex with the Screening Decisions (the original
documents).
Please clarify for Iernut if are Natura 2000 sites in the vicinity
of agglomeration; in the screening decision are not relevant
information. Please see Sighisoara for a good example.
39.

AF-Annex 2 59/
Table 33
and
189/
Table
137
Table 33: Total investment the value of 110,876,128 euro,
as in table 137 Total investment 110,875,965 euro.
Please correct.

40.

Annex III - Done but please reintroduce in the Annex III the documents
regulating the activity (Notificare).

Volume II : FS written part To be fill in by the Consultant
Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
41.

Project
Summary

16/
Band -Panet
trunk main

We draw attention again that a description of the actual
status of the distribution systems in the villages is
required.
Option 3 has been eliminated, as only RO and membrane
technologies were considered,, without any further
explanation for this decision. In the absence of some raw
water quality data, it is difficult to decide whether no other
technologies could have been considered, i.e. activated
carbon filtration, for odour, taste and chlorine removal.

12

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
Please clarify.
42.

Project
Summary

17/
Table 4
If only the investment cost/capita for the drinking water
related investments reaches 430 /capita, if we consider in
addition the impact of the wastewater collection and
treatment (as we understand that the local authorities
undertook the responsibility of full compliance by 2013),
we would expect that the overall investments will induce
an affordability issue at the level of the local authorities.
Please clarify.

43.

Project
Summary

23/
New
treatment
plant and
trunk main
Miercurea
Nirajului-
Gheorghe
Doja
From table 14, it results that there are a number of water
supply and wastewater projects, which, if we understand
correctly, are under preparation/ implementation (the
Consultant to confirm). In this case, which are the water
sources for certain localities, like Roteni, Acatari,
Magherani, Vargata, Vadu, etc? Is it really correct that
underground water cannot be used? On the other hand,
which are the basis of the design for the for the WWTPs
under these projects? Is the agglomeration concept
observed? Are the design parameters in line with the
design parameters in line with the design parameters in the
CF project?
The other problem is that the beneficiary population of
the CF project is significantly reduced, if we take in
consideration these projects. In this case, the per capita
cost of the CF project will increase. Please clarify.

44.
s
Project
Summary

28

It is stated by the Consultant that the Niraj river presents
a set of negative characteristics, as risk of flooding and for
attenuate it at County Council level a lot of reparative
measures were taken, as the erecting a dam This raises
a concern with regard to the technical solution proposed
by the Consultant, as:
The flood risk seem to exist, therefore a flood risk
survey should be prepared, for the intake and the

13

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
DWTP;
As this seems to be flood scheme, it is not clear
whether the necessary flow will be ensured at all
times, for the water supply;
Data on raw water quality from Niraj river should be
provided, and also a brief description of the
proposed processes in the DWTP.
These aspects need to be clarified in every detail.
45.

Project
Summary
Chap.1.5.1
and the
following...
and
Annex B1
Please correlate the tables from chapter 1.5.1 and the
following with the Annex B1 Estimated population

46.

Project
Summary

77

Which system is analysed? In any case, it is unclear why
the percent of NRW is going to sharply increase by 2014.
Please clarify.

47.

Project
Summary

107/
Table 80
It is not clear what the measurement units are. What is the
meaning of residual water volume? Please clarify.

48.

Project
Summary

109/
Table 83
The volume is at 35% D.S. content? If yes, the density of
the sludge should be something like 1.15 tonnes/m
3
,
therefore the mass should be 16,307 tonnes, in the case of
Targu Mures for 2014, for example. The D.S. content will
be some 5,708 tonnes/year. Please clarify and check all the
figures, as well as the others relevant tables in section
1.8.5.

49.

Project
Summary

Page 134/
Table 110
Given the results of the sludge disposal option analysis,
we do not understand the need to reach 92% D.S. content
in the case of Targu Mures. Please clarify.

50.

Project
Summary
Page 156/
Table 116
Is it coorect that in the case of Ludus the investment
cost/length is less than 18 /m and in the case of Iernut is

14

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
45 /m? If the answer is yes, a justification for such low
unit costs is necessary. The same comment is also valid for
the similar indicators in table 119, for Sighisoara, Ludus,
Iernut and Cristuru Secuiesc.
51.

Project
Summary

162/
Table 125
It is difficult to understand why the unitary costs for
Band-Panet are higher than those for Miercurea Nirajului,
as in the case of Band-Panet the diameters are larger (with
the highest proportion of 125 mm and 225 mm) and in
the case of Miercurea Nirajului, the diameters vary
between 110 and 225 mm, with a higher proportion of
225 mm, indeed. Is it due to the more difficult ground
conditions and limited space for the pipe routes? Please
clarify.

52.

Analysis of
current
situation and
forecasts
109-/
Table 117
By dividing the domestic component of the wastewater
volume by the domestic component of the water demand,
we have calculated a return ration to the sewerage of only
50%. Is this due to the rural nature of the Ludus
agglomeration and low percentage of connection at
present? Please clarify, as for an urban area (even for a
rural one) this return ration is quite low. The same
question is also valid for Iernut (60%).

53.

Analysis of
current
situation and
forecasts
227-232 Please consider providing additional information on
Voiniceni-Samas, and-Panet and Niraj Valley components
in respect of the existing situation of the water supply
systems: despite the presence of sub-chapters in the table
of content, there is no information for the last two
components. And nothing is mentioned aid about
wastewater.
Please indicate, in particular, the current state of the
situation in respect of existing water distribution network
(and possible wastewater networks), existing customer
connections and other relevant data.

15

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
54.

Sludge
Management
General
request
In case of each WWTP from the project area it is
necessary to detail the related proposed facilities for
dewatering (including for 35%DS), disinfection and
the necessary temporary storage capacities
- To prove the availability for the landfilling, please
correlate the data related to the capacity of the
available landfills, including the temporary storage
facilities (drying beds and the project facilities), and
the total quantities (m
3
) of sludge from the
corresponding relevant WWTPs estimated per year.
- In the sludge strategy must be included also
information related to the management of residues
from WWTP (sewage cleaning, grease, sand
washing) quantifying the corresponding volumes
and loads.
- The relevant sludge treatment and disposal costs
(including the operation cost, the treatment for the
pathogens, dewatering and temporary storage or
transport, etc). Please consider that the costs related
to the Sludge Strategy must be included in CBA and
summarise accordingly in the table 54, considering
the selected option no. 4 (without incineration).
- It is necessary to send to EC a sound decision
related to sludge disposal. This Decision, based on
Sludge Strategy, should be approved by ROC and
IDA.
See the MoE models for agreements of relevant
authorities and sanitation operator, and also for
Beneficiary Decision.

16

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
Acord Principiu -
Silvic.pdf
ACIDAVA.doc
SALUBRIS.doc
Decizie Olt -
semnata.pdf

For the final version of Sludge Disposal Strategy must consult EPA
to include specific information in the relevant documents from EIA
procedure.
55.

Sludge
Management
17/
Table 8
Which are the measurement units in the table? What does
it mean residual water volume is it the inlet flow in the
WWTP? Please clarify. Same comment is also valid form
table 12 on page 20-83.

56.

Sludge
Management
19/
6.6.2. Future
sludge
quantities
Please be more specific related to the temporary storage facilities.
Please mention what kind of additional storage facilities
are envisaged for each WWTP and their capacity (m
3
).
It is necessary also to specify the capacity (m
3
) of the
existing drying beds.
For the total storage capacity of each WWTP from the project, please
correlate the production of the sludge with the available capacities.

57.

Sludge
Management
21/
6.7.2.
Landfilling
According to HG 349/2005, art.26, (3) refers to non-
compliant landfills not to non-hazardous industrial waste
which is art.26, (2).

- Please clarify the relevance of the following
statement:
In accordance with the provisions of HG 349/2005 "the existing
non-hazardous industrial waste landfills that comply until July
16, 2009 continues to operate until depletion of designed capacity."
Please review GO 349/2005, taking into consideration the
article no.26:

17

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
(3)Depozitele existente neconforme prevzute n
anexa nr. 5 sisteaz activitatea conform calendarului
de sistare a activitii prevzut n anex i aplic
prevederile legale de operare i monitorizare n
vederea nchiderii sau aplic prevederile legale n
vederea nchiderii i urmririi postnchidere.

- Please detail in the text the information for the new
ecological landfill from Sanpaul, mentioning the real
capacity and the real life period for disposal. Please contact
the Consultant who prepared this project (the information from MP
is not relevant; see also the page 28).
- The interruption year for Sighisoara is 2019 or 2017?
Please clarify with the same Consultant.
It is necessary to be revised the information
presented for the landfilling having in view the
specific conditions of this County and also the
provisions of the legislation. Sound conclusion
related this alternative should be assumed into the
sludge strategy according to the responsibility of the
Consultant.
In this respect it is necessary to delete the following
considerations: Management of sludge from the WWTPs for the
period 2010-2013, will respect the decisions of local authorities and
regional operator. In case that this short-term strategy (2010 -
2013) is not accepted by the AM, we are waiting instructions, to
complete the strategy in a subsequent review of the documentation
58.

Sludge
Management
23/
6.7.4.2
Reuse in
forestry
Please consult the territorial Forestry Directorate to obtain
the official and updated information related to the total
area of the forestry.

18

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
(reforestatio
n)
59.

Sludge
Management
32-83/
Table 24
Please note that the table contains the quantities of sludge
produced after the WWTPs rehabilitation, and not before.

60.

Sludge
Management
25/
6.8. Strategic
sludge
disposal
alternatives
Please include for the appropriate alternatives a clear
conclusion related to the disposal of the sludge from the
WWTPs from the project area, having in view the entire
horizon of the strategy: short, medium and long term
periods.

61.

Sludge
Management
28/
6.8.4.
Investigatio
n of the
Disposal at
Landfill
Please contact the Consultant who prepared this project
related to the site of a new landfill at Sanpaul (the
information from MP is not relevant).

62.

Sludge
Management
28/
6.9.Strategy
proposed
for Sludge
Storage
- Table 19: Please clarify the included information for
Cristuru 35% DS before project and 25% after project.
The information from the water company is not
convincing; please take into consideration the real
situation and revise accordingly.
- Table 26: Regarding the sludge from WTPs please
consult EPA related to the selected 2 solutions for
disposal: landfill and sewerage network, having in view the
content of this type of sludge.

63.

Sludge
Management
34-83/
Table 27
Please note that if in the first row of the table the figures
represent the D.S. content of the sludge, then the data is
wrong, as the whole amount of sludge will have to be
landfilled, not only its 35% D.S. content. Please check and
revise accordingly. The same comment is also valid for the
others disposal options.

64. Sludge 35/ Please correlate the figures with those mentioned in
19

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
Management Option
Agriculture
use
chapter 6.8.1
65.

Sludge
Management
42/
6.9.3.
Selected
option
- Having in view that for the 2014-2039 all the sludge
production from Targu Mures WWTP will be disposed at
Sanpaul landfill, please revise the Table 27 considering the
real capacity of the landfill (not from MP). Please be aware
that the dewatering process in order to obtain minimum
35% DS requested for landfilling must be precisely
proved.
Please be aware that the dewatering process in order
to obtain minimum 35% DS requested for landfilling
must be precisely proved.

- Please detail the following information related to selected
option (no. 4): Short term period 2010 2013 the sludge
is stored in current storage facilities. Please explain for
each WWTP what type of storage facilities are currently
available for the corresponding quantities.

66.

Sludge
Management
50/ 6.10.1.
Action plan
for selected
option
implementat
ion
Please correlate all the included information with those
mentioned in Chapter 6.9.3 and 6.10.

67.

Option
analysis
15/
Voiniceni-
Sarmasu
trunk main
The option analysis for the trunk main rehabilitation does
not make any sense, as it is obvious that an additional
pumping station will induce additional costs, for both,
investment and O&M. We would have expected to see a
comparison between do nothing option and the
rehabilitation of the trunk main and existing pumping
stations. Please consider.

20

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
68.

Option
analysis
15/
Panet-Band
trunk main
Again, the option analysis is artificial. It is necessary to
have an option analysis between the use of Targu Mures
source, against local underground water sources, starting
from a sound identification of the underground water
potential yield and quality parameters and the associated
costs for abstraction and treatment.

69.

Option
analysis
16/ Water
treatment
plant and
trunk
main for
Valea
Nirajului
It is stated that the only source of water for water supply
in localities in the region Niraj Valley is the river Niraj.
On the other hand, in the Project Summary section (Page
23-2-7 table 14) it is noticed that there are a number of
water supply projects, probably based on other sources.
Please clarify.

70.

Option
analysis
85/ WWTP
rehabilitatio
n sludge
line
As long as a 35% D.S. content of the sludge is required by
the legislation in force for landfilling, we do not
understand why the chemical conditioning of the sludge
(lime use, Kemi-Cond, etc) was totally ignored in the
option analysis. The use of chemicals to condition sludge
for dewatering is economical because of the increased
yields and greater flexibility obtained. On the other hand,
the use of heat drying induces fire and explosion hazards.
The prevention measures associated to this (venting
systems, nitrogen padding, etc) are quite costly. Another
problem is the air pollution (by fly ash) and odour control,
which must be carefully considered. The Consultant must
confirm whether these aspects have been taken in
consideration in the Option Analysis and in the CBA.
Please clarify, as from the brief description of Option 2,
this does not seem to be the case.

71.

Project
presentation
9.1.1.1
Targu Mures
water supply
zone
We have noticed that the new distribution pipes (see
figure 1 on page 18-303) are of a branch type, in most of
the cases. We draw attention that in a branch type
network, only one path of supply reaching a demand node

21

Req. No.
Chapter
/Annex
Page/
Para.
Chapter
/Page
Comments
may cost less, but at the same time, will have low
reliability. In such a case, if any of the pipelines fail, the
subsequent demand node will not receive any water.
However, in a loop type water distribution network, as the
number of paths increases, the cost as well as the
reliability increases. The comment is also valid for others
supply zones, where applicable.

Volume III : FS - Annexes To be fill in by the Consultant
Req. Nr.
Chapter/
Annex
Page/
Para.
Chapter/
Annex
Page/Para.
Comments
72.

Hydro -
geological
Study
8.2 Reference is made to some hydro-geological studies, performed
by different entities. We would have expected to see some yield
and quality related information from these studies. It is also
important to know when such studies were performed.

73.

Vol.II-
Annex A
Annex
A.2.7
Regarding the General Cost Breakdown for TAUs (Annex
A2.7) and the General Cost Breakdown in constant prices
(Annex A2.4), the columns with/without TVA in RON and
the official exchange rate published by the Romanian National
Bank on the date when the estimate has been made must be
added.

Annexes not presented as in the FS Guide.

Volume IV: Cost Benefit Analysis To be fill in by the Consultant
22

Req. Nr.
Chapter/
Annex
Page/
Para.
Chapter/
Annex
Page/Para.
Comments
74.

General
As previously requested, please provide us with all the different
files attached to the main model (Mures CBA.xlsx) that give
detailed information on input data used in the main model
(Afordabilitate Mures.xlsx has not been provided for instance).

75.

General

Please explain why affordability limits, for the lowest deciles, are
already exceeding the 4% threshold before the project starts:
4.23% as of 2009?

76.

General

As far as the specific water consumption is concerned, all the
WSZ are supposed to average 80-85 lcd until 2019 (Niraj and
Iernut below 70 lcd).
Are there any explanations for these relatively low level of
consumptions? If not, we believe that such levels could lead to
some underestimations and ill design infrastructures.
The value calculated should be checked and if confirmed some
explanations provided to substantiate this unusual situation
(compared with other Counties in Romania).

77.

Model

What does the WSA in the Sales NOPro/Pro worksheet refer
to?

78.

Model

The connection profile does not seem realistic, not matching the
technical part of the FS and procurement strategy. The
treatment of Niraj, in particular, within the model is very
unclear:
around 1,300 new water connections are mentioned for
the year 2012 (from none in 2011, those connections
being out of the current CF application) and more than
6,000 additional connections (in connection with the
current application) are forecasted in the following year.
How realistic are these figures in terms of works required? How
are these new connections supposed to be financed?
Please explain and clarify.

79.

Model

In relation with the above, some questions need to be clarified
in relation with the Demand analysis component. Although we

23

present specific questions related to the Niraj valley component
in the following, similar questions and remarks can be raised for
most of the WSZ and Agglomerations:
1. Why does the per capita per day consumption in Niraj
remain below 70 lcd, before (low waste watercoverage)
and after project (100% wastewater coverage)? Once
wastewater services are in place, shouldnt we expect an
increase in per capita consumption? Please explain and
clarify.
2. Why should the non-domestic consumption follow the
same growth pattern as the domestic one? Arent
institutions or companies, by and large, already
supplied with water? Please explain.
3. Why should the non revenue water jump to 35% from
6% with the construction of new network? And why
should there be a big jump in 2015 (from 25% to36%)
in non revenue water? Please clarify.
4. While the number of consumers will be higher thanks
to the project, the total billed volume of water in the
Nopro scenario is often higher (while the current litre
per capita consumption that is already quite low,
around 70-80 lcd in most of the WSZ). Please clarify.
The level of non-revenue water taken into consideration does
not seem consistent with the technical part of the FS and within
the CBA itself: in all WSZ important increases have been
projected in the second half of the projection period (up to 50%
and 51% for Reghin and Ludus respectively). Please clarify
and/or correct
80.

Model

In Targu Mures, why does the CBA model project a level of
losses going down to 19% in 2014, keeping this level for the
following 14 years, and then report increases reaching, at the end
of the project period 27%(2039)? Please clarify and correlate
with the FS.

81.

7.4.5
Supportabi
lity
107 This revised version of the CBA presents an affordability
analysis and by doing so present a new situation far less
problematic than in the previous one:

24

Analysis - affordability limits are slightly exceeding 4% until 2019, but the
magnitude of the affordability problem is less obvious compared
with the previous version in which it ran until 2021, with some
affordability peaks above or close to 6% between 2011-2014.

However, the main reason that explains this change is debatable.
It is indeed based on the calculation of new per capita daily
consumptions. While 75 lcd was previously used, as
recommended by the CBA Guidelines, the Consultant has used
a figure corresponding to 68% of the average county
consumption level (75/110 lcd for 68%).

Unless such change is explained and substantiated by specific
conditions or circumstances, we are of the opinion that this
recalculation is not correct. The 75 lcd consumption level should
be considered as a basic allowance: a minimum level of water
enabling the satisfaction of basic needs under normal conditions
(presence of both water and sewerage services). Indeed, in
absence of running water, the United Nations reports that daily
consumption levels of 20-50 litres are very common in most of
the developing countries. Therefore, it is rather unlikely that
individual consumption in Romania will fall below a level of 75
lcd and close to 60. This does not mean that this will never
happen. There might be situations indeed in which the presence
of alternative source of water for instance may lower the
consumption from public network. But unless clear evidences
are provided to explain such consumption low consumption
levels, we recommend the use of 75 lcd.

The affordability analysis should be revised.
82.

7.5.3 the
Financial
indicators
of the
project
110 The return of the project is supposed to worsen after the
Community assistance: FRR/C -4.75% while -5.14% FRR/K.
Please explain and/or check.

83.
Demand The excel file showing demand data is missing and therefore the
25

analysis demand analysis couldnt be properly checked.
84.

Eligible/
ineligible
costs
Please see the comments presented above on the Application
Form section regarding the calculation of an ineligible part of
the price adjustments, the total ineligible costs and the
correlation between the tables reported in the Application form.

Volume V: Institutional Analysis To be fill in by the Consultant
Req No
Chapter/
Annex
Page/
Para.
Chapter/Annex
Page/Para.
Comments
85.

Vol I
Cap 11
14/11.4.2 RoC s shareholders table. Review Targu Mures s shares
6.191.700 RON, the total value of the capital and the
percentages of each shareholder

86.

Vol I
Cap 11
16/11.5.1. RoC s shareholders table. Review the total value of the capital.

87.

Vol I
Cap 11
20-24
/11.5.2
Please update tables 7 15 with recent dates

88.

Volume V 25/4.2.2 Review RoC s shareholders table

89.

Volume V 44-48
/4.3.7.1-3
Please update tables 15-25 with recent dates

Volume VI: EIA To be fill in by the Consultant
Req No
Chapter/
Annex
Page/
Para.
Chapter/Annex
Page/Para.
Comments
26

90.

General
request
- Please include for each agglomerations only the following
documents: the annexes 1 and 2 issued by EPA, all
documents mentioned in the Annex 2 (signed by EPA) in
the same order from this Annex, and also the revised
Natura 2000 Declarations and the corresponding maps.
The title of the major project is missing for all EIA
documents!

Note: Please verify the status of the documents submitted in the table bellow.

Analiza Institutionala
Document Evaluat Corectie
/Conformare
Observatii
Statut/Act Constitutiv ADI DA Conform POS
HCL/HCJ infiintare/modificare Statut/Act Constitutiv ADI DA/Lipsa Conform POS Trebuie transmise si HCL/HCJ de modificare a Statutului si a
Actului Constitutiv Adaugat Act modificare Act Constitutiv ADI in
Anexa 7
Se vor transmite si HCL de modificare din noiembrie 2008
Certificat inregistrare ADI DA Conform POS
Act Constitutiv Operator Regional (OR) DA Conform POS
HCL/HCJ infiintare/modificare Act Constitutiv OR DA/Lipsa Conform POS Trebuie transmise si HCL/HCJ de modificare a Actului
Constitutiv Adaugat act modificare OR in Anexa 7
Va rog sa indicati paginile
Certificat inregistrare OR DA Conform POS
Contractul Unic de Delegare a Gestiunii Serviciilor (CDMS) DA Conform POS/
Neconform
Contractul este semnat si de UAT care nu sunt membre ale ADI -
Bagaciu, Saulia, Petelea, Fanatnele, Apold, Craiesti, Avramesti,
Silivasu de Campie, Urmenis se impune introducerea lor in ADI -
Adaugat Act modificare Act Constitutiv ADI in Anexa 7
HCL/HCJ aprobare CDMS DA Conform POS/
Neconforme
1.HCL neconforme Craciunesti, Corunca, Ernei, Livezeni, Madaras,
Zau de Campie nu aproba si delegarea gestiunii
2. HCL Ibanesti neconforma art 5 eliminat
27

Analiza Institutionala
Document Evaluat Corectie
/Conformare
Observatii
3. Este necesara si punerea la dispozitie a HCL Targu Mures
nr.98/2009
Adaugat CDMS actualizat din 05.03.2010 in Anexa 7
Au fost transmise doar HCJ Mures si Reghin
HCJ privind aprobarea Master Planului i a listei de investiii DA Neconforma nu este aprobata si lista de investitii
HCJ privind aprobarea Studiului de fezabilitate i a indicatorilor
tehnico-economici ai proiectului
Lipsa Document ce va fi inaintat dupa aprobarea variantei draft a Aplicatiei.
Avizul Adunrii Generale a Asociailor ADI privind aprobarea
Studiului de fezabilitate i a indicatorilor tehnico-economici ai
proiectului
Avizul CTE al OR privind aprobarea Studiului de fezabilitate i a
indicatorilor tehnico-economici ai proiectului
HCJ/HCL-uri privind aprobarea cofinanrii proiectului (cheltuieli
eligibile i neeligibile)
Lipsa Documente ce vor fi puse la dispozitie de catre beneficiar.
Planul anual de evoluie a tarifelor (conform rezultatelor Analizei
Cost-Beneficiu) aprobat de ADI
Lipsa Documente ce vor fi puse la dispozitie de catre beneficiar.
Dovezi privind privind proprietatea/posesia autoritilor locale asupra
terenurilor sau accesibilitatea acestora i privind punerea terenurilor la
dispoziia proiectului - HCL
DA Conforme S-au inaintat HCL emise doar de Cristuru Secuiesc, Ludus,
Sighisoara, Panet, CJ Mures, Miercurea Nirajului, Pasareni.
Se va verifica daca sunt pentru toate investitiile care se vor realiza
Lipsa Tg Mures, Reghin, Tarnaveni, Iernut
Adeverin prin care se menioneaz faptul c nu au fost depuse cereri
de retrocedare, n conformitate cu legislaia n vigoare i c nu exist
litigii cu privire la stabilirea i delimitarea proprietii
Da/Lipsa Conforme/
Neconforme
S-au inaintat adeverinte emise doar de Cristuru Secuiesc, Ludus,
Sighisoara, Panet care nu se coreleaza cu HCL in ceea ce priveste
investitiile care vor fi efectuate
Pasareni si Iernut.
Declaraie de Angajament a Beneficiarului (aprobat i de ADI) Lipsa Documente ce vor fi puse la dispozitie de catre beneficiar.
Declaraie de Eligibilitate a Beneficiarului Lipsa Documente ce vor fi puse la dispozitie de catre beneficiar.
Scrisori de intenie de la bnci comerciale/de investiii privind
interesul acestora de a cofinana proiectul, dac este cazul
DA Conform POS
Constituire UIP DA Conform POS
28

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Correction Protocol for version 3

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