“action plan to improve the air quality and health of la...

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Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content is under technical evaluation. 1 “Action Plan to Improve the Air Quality and Health of La Oroya” March 1, 2006 version La Oroya Zonal Air GESTA Proposal for information and public consultation pursuant to SD.074-2001-PCM and RP 022-2002-CONAM/PCD

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Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

1

“Action Plan to Improve the Air Quality and Health of La Oroya”

March 1, 2006 version

La Oroya Zonal Air GESTA Proposal for information and public consultation pursuant to SD.074-2001-PCM

and RP 022-2002-CONAM/PCD

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

2

ContentsExecutive Summary. 4Introduction. 51. General information on the Priority Attention Zone. 6 Geography and Climate. 6 Transportation and Industry. 8 Population and Urban Development. 92. Identification of the Problem. 9 Sources of Contamination. 9 State of the Air Quality. 10 Social and Health Impact. 113. Goals and Objectives. 11 General Objective. 12 Specific Goals and Objectives. 134. Measures for the Comprehensive Management of Air Quality. 15 Measures to establish the Air Quality and Health Monitoring Program. 15 Air Quality Monitoring System. 15 Health Impacts Monitoring System. 16 Citizen Information System. 18 Measures to Improve the Air Quality and to Prevent Its Deterioration. 19 Program to Strengthen the Comprehensive Management of Air Quality. 19 Emissions Monitoring Program. 20 Cleanup, Remediation, Organization, and Planning of the Atmospheric Basin Program. 21 Measures to Apply During States of Alert. 225. Financing 236. Evaluation and Follow-Up. 24Graphics 25Tables 26Annex 1 28Annex 2 31

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

3

ABBREVIATIONS AND ACRONYMS CONAM National Board of the EnvironmentDIGESA General Department of Environmental HealthDIRESA Regional Department of HealthDESA Executive Department of ECA Air Quality StandardsFONAM National Fund for the EnvironmentGESTA Environmental Air Quality Technical Studies GroupUNCED United Nations Conference on EnvironmentSENAMHI National Weather and Hydrology ServiceSENATI National Industrial Labor Training ServiceDRP Doe Run Peru SRL CMP Centromín Perú SLGA Local Environmental Management SystemPM10 Particles with a diameter of less than 10 micronsPM2.5 Particles with a diameter of less than 2.5 micronsNO2 Nitrogen Dioxide SO2 Sulfur Dioxide O3 Ozone VOCs Volatile Organic CompoundsWHO World Health OrganizationWTO World Trade Organization CO Carbon monoxide GNV Vehicular Natural GasPTS Total suspended particlesdl Deciliter µg Microgram

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

4

Action Plan for the Improvement of the Air Quality and the Health of La Oroya

Executive Summary

The city of La Oroya, considered a priority attention zone in the country, faces the challenge of seeking an adequate relationship among health, the environment, and development. An expression of that is this “Action Plan for the Improvement of the Air Quality and the Health of La Oroya,” whose purpose is to establish in a concerted and participatory fashion the strategies, policies, and measures needed to achieve primary air-quality standards within a specific time frame and also to implement effective measures to protect the population by reducing its exposure to pollution. The Action Plan is based on international political and legal antecedents and international, regional, and local programs and on the multidisciplinary and multi-sectorial work that was performed around the Zonal Air GESTA. The Baseline Diagnostic precedes the Plan and constitutes the principal source for its design. The air pollution problem in the City of La Oroya is associated with sulfur dioxide, particles under 10 microns {{and 2.5 microns}}, lead, other heavy metals and gases. The conclusions of the Baseline Diagnostic in relation to the air quality monitoring performed determined that sulfur dioxide (SO2) pollution and particles under 10 microns (PM10) exceed the transitional values established in Annex No. 2 of the National Environmental Air Quality Standards Regulation, air pollution with lead (Pb) exceeds the values of the national standard established in Annex No. 1 of that selfsame Regulation. The objective of the Plan is to protect the health of people and the environment principally by reducing net emissions from stacks and fugitive emissions from the metallurgical complex, as well as by controlling environmental liabilities according to the responsibilities that belong to Doe Run Peru and Centromín Perú, respectively. Supplemental health and environmental measures will also be adopted to mitigate the effects on the health of people, especially the most vulnerable population, while ECA values are achieved for particles under 10 microns (PM10) the year 2007 [sic]; for lead (Pb) ECA values by the year 2007; and for sulfur dioxide (SO2) ECA values for the year {2008-2010}. To that end activities have been established aimed at reducing emissions of pollutants by modernizing the metallurgical complex, PAMA projects and such supplemental projects as are necessary to comply with the environmental commitments assumed with the Peruvian State by the operator of the metallurgical complex, and also to reduce exposure by children to contamination by promoting healthy educational and family alternatives, facilitate the adoption of hygiene habits among the population, the necessary epidemiological and environmental monitoring and strengthen the organization and planning of the atmospheric basin. CONAM will coordinate the performance, evaluation, and public reporting of the Action Plan with the competent authorities, as well as the corresponding auditing, within the Local Environmental Management System, without prejudice to those that belong to the National Control System. The actions have been groups into several programs which as a whole require financing in the order of {US$ 6,700,000 dollars or approximately S/. 23,175,000 sols over a 5-year horizon}.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

5

Introduction The relationship that exists among health, the environment, and development is evident and the efforts that are undertaken internationally, regionally, and nationally to integrate them are significant. On the international plan for the protection and promoting of human health, the reduction in the risks to health derived from pollution and environmental hazards is one of the principle program areas of Agenda 21.1 The general objective consists of reducing risks to the minimum and maintaining the environment at a level such that human health and safety are not affected or jeopardized, and that development continues to be promoted. Within the local context, the city of La Oroya, considered a priority attention zone in the country,2 is fully facing this challenge, this “Action Plan to improve the air quality,” whose purpose is to establish the strategy, policies, and measures necessary to achieve the primary air-quality standards within a specific time frame, being an expression of that. However, considering that there are high levels of contamination at La Oroya, and that achievement of the ECA’s will be a gradual process, it becomes necessary to implement effective measures to prevent the deterioration of the air quality, as well, and, above all, to protect the vulnerable population by preventing health risks and avoiding excessive exposure to contaminants that might damage health.3 This is also the purpose of the additional actions and management instruments instituted in recent years by the authorities and operators, among them: a) the MINSA-DRP4 agreement “to slowly reduce the levels of lead in the blood of the population at greatest risk of exposure and most susceptible”; b) the precept that enables the extension of the performance of the environmental projects established in the PAMAs5 which include, among other things, an “analytical study of health risks”; c) the priority projects for immediate environmental mitigation instituted by the owner of the metallurgical complex6 as a result of the risk study; and d) the health protection measures and other provisions related thereto given by the sectorial authority.7 In that same sense the recent General Environment Act,8 which is the act that organizes national environmental management, specifies that the purpose of environmental management and its instruments is to ensure the full effectiveness of the inalienable right to live in a healthy, balanced, and adequate environment for the full development of life; which is guided by the principles of prevention, precaution, internalization of costs, and environmental responsibility, among others. In relation to the air quality, in order to promote development in accordance with health and environmental criteria, our country has also defined9 national air quality standards and strategic guidelines for achieving them progressively, which are already being implemented in a participatory and concerted fashion.

1 Report of the United Nations Conference on Environmental and Development (UNCED). Rio de Janeiro, June 3 to 14, 1992.

Volume I: Resolutions approved by the Conference. Program 21 (Agenda 21). Chapter 6: Protecting and promoting human health.

2 SD. No. 074-2001-PCM. National Environmental Air Quality Standards Regulation. Art. 20. 3 SD. No. 074-2001-PCM. National Environmental Air Quality Standards Regulation. Arts. 16 and 23. 4 Cooperation Agreement 008-2003-MINSA between the Ministry of Health and Doe Run Perú SRL. (07.04.03). 5 SD. No. 046-2004-EM. Provisions for the exceptional extension of time frames for the performance of specific environmental

projects contemplated in environmental adjustment programs, PAMA. (12.29.04). 6 Request for an exceptional extension for the performance period of the sulfuric acid project. Pages 62 et seq. (Dec. 2005). 7 Directorial Resolution – Report 732-2002-EM-DGM-DFM/MA (09.11.2002), confirmed and supplemented with Directorial

Order 157-2006-MEM/AAM (02.17.2006). 8 General Environment Act No. 28611 (10.15.2005). Preliminary Title and Articles 13 and 16. 9 SD. No. 074-2001-PCM. National Environmental Air Quality Standards Regulation. Art. 2.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

6

This objective is confirmed at the regional level by the program guidance given by the Regional Government of Junín10 in the Central Andean Regional Environmental Agenda 2004-2005, whose Goal 15 stipulated as a regional priority the preparation of the Clean the Air Plans of the cities of Huancayo and La Oroya, and in its Goal 9 the “coordinated implementation of a suite of environmental management instruments: decontamination plan, to clean the air plan, contingency plan for states of alert, lead health intervention plan in the city of La Oroya.” Thus the City of La Oroya’s “Clean the Air” Plan is based on the stated political, legal, administrative, and program antecedents and on the multi-sectorial and multidisciplinary dialog which was undertaken at the local level in relation to the Environmental Technical Studies Group – Zonal Air GESTA of La Oroya between December 2001 and February 2006.

1. General information on the Priority Attention Zone. 1.1 Geography and Climate. The geographical environment11 of the La Oroya Atmospheric Basin includes part of the districts of La Oroya, Paccha, Huayhuay, Chacapalpa, and all of the district of Santa Rosa and Sacco in the province of Yauli, La Oroya. It is located at an average of between 3,775 to 5,020 meters above sea level in altitude, its coordinates are 8740000 N, 380000E; 8740000 N, 423000E; 8695000N, 380000E; 8695000N, 423000E, and it is bordered along the north by the territories of the district of Paccha; by the south with territories of the district of Huayhuay, and the province of Juaja; along the east by the province of Tarma; and along the west with territories of the districts of Yauli and Morococha. The size of the Atmospheric Basin is 85,322.71 Ha., of which 2,467.35 Ha correspond to the urban attention area. See Chart No. 1. In the area of the basin, as well as throughout the central mountain range of the country, the start of the greatest rainfall occurs in the months of October and November, and it becomes more intense between February and March, known as the rainy season; it descends in the months from June to August, the dry season. According to the weather station located in the district of Santa Rosa de Sacco (SENAMHI) in the year 2003, the maximum precipitation reached an approximate value of 800 mm in the Chacapalpa area and lower precipitation to the north of Paccha and La Oroya with values of 450 to 500 mm. The average relative humidity is 76% with a minimum of 65% and a maximum of 82%. As a general characteristic, the climate is dry and cold, the average temperature being 12° C. The temperature behaves almost inversely proportional to the rainfall. The greatest temperature is recorded in the rainy months (October – April) where the maximum temperature ascends to 22.5° C. In the months of May to July the minimum temperatures descend to below 0° C. From the information analyzed corresponding to the daily information from 07:00AM, 01:00PM, and 07:00PM during the year 2003, it can be seen that the predominant direction during the hours from 07:00AM to 07:00PM is from the south to the north with a wind speed of 1.5 to 3 m/s. However, at 01:00PM the wind blows from the north to the south and from the northeast to the southeast, with an average wind speed of 3.0 to 4.5 m/s.

10 Regional Ordinance 005-2003-GRJ/CR approved at the proposal of the Regional Environmental Commission – CAR. 11 Base information from satellite images (Landsat, scale 1:50000, combination of bands 4, 5, and 7) of plant coverage and areas

were contamination is present (degrees: high, medium, and low) was used to delimit the geography area of the La Oroya atmospheric basin, likewise information was used from the National Chart at a scale of 1:100000 to delimit the area using contour lines (4200) and by rivers and streams.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

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Considering the base of La Oroya with an altitude of zero, in relation to the vertical structure of the atmosphere, it can be stated that the top layer is between 700 and 800 meters high, according to observations made with DRP’s Remtech SODAR; however, this vertical structure is varied during the day and night, likewise between the moist and dry periods. Below this top layer a natural phenomenon occurs known as a temperature inversion, which also varies by these factors, whose impact is greater on the air quality in the dry period, where the temperature inversion generally occurs frequently at the end of the day between 06:00PM and 07:00PM, extending until 09:00AM and 10:00AM the next day, presenting maximums at dawn, under these stable conditions the impacts on air quality from emissions are more critical. Then in the afternoon hours it becomes unstable because of the increase in the intensity of the air, and therefore the impact on air quality diminishes. The geographic environment of the atmospheric basin includes the Yauli River, which runs through the urban centers of the districts of Santa Rosa de Sacco and La Oroya. It has a yellow-orange coloration due to the contamination caused by the mining / metallurgical operations at the minimum units located in the districts of Morococha and Yauli, U.E.A. Its waters are also contaminated by urban solid waste and wastewater, derived from the nearby towns, mentioned as part of the mining operations, there is also [the?] Cut Off lime Pit, next to San Miguel, Yauli Poblado, Curipata, Huaynacancha, Santa Rosa de Sacco, and La Oroya Nueva (residential zone). The Andaychagua-Huari River forms a narrow valley with a microclimate suitable to perform agricultural and livestock operations, but its development is limited due to the contamination of its waters and soil caused by mining and metallurgical operations, as well as the ruggedness of its topography in certain zones. The Andaychagua River is known by different names along its course, so in the town of Huayhuay it is known as the Huayhuay River, when it reaches the town of Huari it is called the Huari River. Its waters are contaminated by mining and metallurgical discharges coming from the Andaychagua mining unit owned by Volcan Cía. Minera S.A.A.; however, when it joins the Suitucancha River with its large volumes of water, its quality improves before joining with the Mantaro River at the town of Huari. Its waters are also contaminated from urban solid waste and wastewater, coming from the nearby towns, Suitucancha, Huayhuay, Colpa, and Huari. The Mantaro River starts at the Upamayo dam, it receives solid waste from Santa Bárbara de Carhuacayan, the Mal Paso Hydroelectric Plant, the HIDRO-OROYA (ELECTROANDES) hydroelectric Plan, district of Paccha and La Oroya, it crosses the geographic area of the atmospheric basin from the North to the South running through the district of Paccha and La Oroya. The Mantaro River receives the waters of the Yaulí River at the Jorge Basadre bridge (Km. 175 of the central highway) in the city of La Oroya and the Andaychagua-Huari River in the town of Huari. Its waters show pollution generated mainly by the mining metallurgical operations in the zone, they are also contaminated by urban solid waste and wastewater, coming from the nearby towns. With respect to land use, until the year 2002 the main use was pastures, with 87.26%; protection areas with 11.34%; clean farming with only 1.03%; permanent farming with 0.04%; and woodlands 0.33%.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

8

1.2 Transportation and Industry. La Oroya is the main urban center of the Study Zone and it is located in the strategic center where the main roads in the center of the country meet. The roads connect: to the west to the coast and Lima; to the south with the Mantaro Valley, also Huancavelica and Ayacucho and the entire south of the country; to the north with Cerro de Pasco, Huánuco and Pucallpa, with a branch to Tarma and the Central Jungle. The intersection of those roads is a critical point of traffic jams, which situation is aggravated by the railroad crossing. The rail12 system is used exclusively for cargo, between Cerro de Pasco, La Oroya, and Lima; and occasionally passengers from Lima to the city of Huancayo. Urban and interurban transportation is regulated and controlled by the Provincial Municipality of Yauli, La Oroya; interprovincial transportation by the district municipality of Santa Rosa de Sacco, because the terminals that are in the process of regularization are located within its jurisdiction. Urban transportation is undertaken through the urban conurbation: La Oroya, Santa Rosa de Sacco, Curipata, and on the other side Paccha, with longitudinal routes, along the axis of the central highway. Service is provided by local companies, in general the motor vehicle fleet is old, carbon monoxide emissions are frequent, increasing pollution. The lines that operate are registered with the municipality and they meet the following requirements: insurance policy; annual technical review; traffic permit. Most of the urban and interurban service units leave from La Oroya Antigua, specifically from the municipal terminal which is very small in size and is completely saturated, and therefore the units must use the streets near the terminal. The concentration of public transport units is greater because La Oroya is an interconnection point to other cities. There are currently 4 terminals in the Santa Rosa de Sacco district of units that are generally automobiles headed to Huancayo, Tarma, Lima, Cerro de Pasco among other destinations. In the central highway, which is the main roadway of the conurbation, there simultaneously exist public and private local transportation flows, interurban, interprovincial, and regional flows that have generated some areas of conflict for traffic, above all on the railway crossings and in road intersections. The Motor vehicle fleet of the city is comprised of: interurban vehicles, with an approximate total of 1163 units, of which 502 are urban and interurban public transportation vehicles and 92 from the company Doe Run Peru, which in general consume 84-octane gasoline fuel at 37% and diesel oil at 35%; and interprovincial vehicles which in total amount to approximately 3,164 units with an average age of 10 years and consumption of diesel fuel at 85%, followed by 90-octane gasoline at 15% of units. With respect to industry, La Oroya showed economic and population growth, based on the development of large mining and metallurgical industry, once the foundry started to operate in 1922. Doe Run Peru is considered a metallurgical industry company that processes polymetallic concentrates of lead and copper with high silver and gold content, as well as zinc concentrations. The company currently has a total of 3,152 workers. The La Oroya metallurgical complex produces 11 metals, 9 subproducts, and 3 Alloys. The commercial sector has 987 establishments between formal and informal. Two hundred twenty-eight (228) establishments have been recorded as formal restaurants and informal food vendors. There are 83 alcoholic beverage distilleries followed in importance by furniture manufacturing and bakeries. In the service sector there are 29 mechanical workshops and factories dedicated to providing services to carriers. Inasmuch as La Oroya is a mandatory point of passage to the center, Andean south, and the central jungle, there are several passenger transportation service companies, both for buses and automobiles, and cargo transportation. A regional tourism distribution

12 It is currently managed by Ferrovías Central Andina FVCA.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

9

center. Given the importance that La Oroya has acquired in recent years, different public and private institutions have been operating in it. There are 35 institutions between public and private. Among other production activities are weekly and fortnightly fairs that are held coinciding with the paydays of workers at private companies. 1.3 Population and Urban Development. The province of Yauli, La Oroya, is comprised of ten districts, the city of La Oroya being located in the district of that name, capital of the province. The province has a total population of 72,375 inhabitants and a surface area of 3,617.35 km2 which leads to a population density of 20.01 inh. / km2. Ninety percent (90.0%) of the population is comprised of inhabitants of the urban sector which is concentrated in the districts of La Oroya and Santa Rosa de Sacco Of the total population, 50.6% corresponds to male inhabitants and the remaining 49.4% to females. The district of La Oroya has a population of 33,949 inhabitants, an area of 388.42 km2, and a population density of 87.40 inh. / km2; in turn the district of Santa Rosa de Sacco has a population of 11,716 inhabitants, a surface area of 101.09 km2 and a population density of 115.90 inh. / km2. The economically active population is comprised of 6,882 people, the majority being in the population group from 30 to 44 years of age with a contribution of 2,953 people. Of the total of 18,308 people recorded in the socioeconomic study of the district of La Oroya, the greatest number 87.1% were born in the Department of Junín. The sources of external migrates are mainly: Huancayo, Tarma, Huánuco, it is important to indicate that the population of the conurbation represented almost 54.0% of the total provincial population, whereas in 1,998 [sic] it represented approximately 65.0%.

2. Identification of the Problem. The conclusions of the Baseline Diagnostic13 of the air quality in relation to the monitoring performed determine that the contamination in the city of La Oroya for sulfur dioxide (SO2) and particles less than 10 microns (PM10) exceed14 the transitional value established in Annex No. 2 of the National Environmental Air Quality Standards Regulation. Likewise, air pollution with lead (Pb) exceeds15 the values of the national standard established in Annex No. 1 of that selfsame regulation.

2.1 Sources of Contamination. According to the Baseline Diagnostic, undertaken in La Oroya based on information through 2003, the main source of contaminant emissions in the city of La Oroya is the metallurgical Complex, responsible for emissions of more than 99% of total emissions of particulate matter, sulfur dioxide and lead, which fact has led to the notification as a macro-emitter16 by CONAM by application of current standards. The main emission is SO2, which represents 97.83% of the emissions from the metallurgical Complex and 97.57% of total emissions.

13 The Baseline Diagnostic, prepared between 2002 and 2004 with information obtained through 2003, was under the

responsibility of DIGESA and supervised by the La Oroya Zonal Air GESTA, as established in Article 11 of the National Environmental Air Quality Standards Regulation, S.D. No. 074-2001-PCM.

14 Seventh Supplemental Provision of the National Environmental Air Quality Standards Regulation, S.D. No. 074-2001-PCM. 15 Sixth Supplemental Provision of the National Environmental Air Quality Standards Regulation, S.D. No. 074-2001-PCM. 16 Letter 2638-2005-CONAM/PCD (12.12.2005) pursuant to Article 8 of Supreme Decree No. 009-2003-SA. Regulation of the

National Air Pollution States of Alert Levels. Amended by Supreme Decree No. 012-2005-SA.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

10

In the city of La Oroya mobile sources emit 956.56 MT of contaminants per year, 559.14 MT / year of CO which represents 58.5% of the total; 221.84 MT / year of NO, which is 23.2%; 97.03 MT / year of VOC’s which is 10.1%; 60.93 MT / year of SO2 which is 6.4%; 17.62 MT / year of PTS which is 1.8%, of which 1.12 MT / year correspond to Pb. The most polluting vehicles are: buses with an estimated emission of 216.35 MT / year, which represents 22.6% of the total; trucks with 196.30 MT / year which is 20.5%; automobiles with 192.43 MT / year which is 20.1%; and station wagons with 171.15 MT / year, which corresponds to 17.9%. Total fixed emissions amount to 388,648.03 MT / year. Fixed area sources represent 144.582 MT / year which is 0.04% of the total; emissions from the specific fixed source which correspond to the metallurgical complex amount to 388,503.45 MT / year which is 99.96% of the total. Noteworthy among fixed area sources are poulterers, filling stations, and bakeries which represent 97.93% of total emissions, with 102.37; 23.04; and 16.18 MT / year which represent 70.80%; 15.94; and 11.19%, respectively. Fixed area sources in total contribute: 99.10 MT / year of CO which represents 68.5% of emissions of this type of source; 32.66 MT / year of VOC’s which is 22.6%; 7.75 MT / year of PTS which is 5.4%; 1.02 MT / year of SO2 which is 0.7%; and 4.05 MT / year of NOx, which is 2.8%. The specific fixed source contributes 388,503.45 MT / year of which 380,074.50 MT / year are of SO2, which means 97.83% of total emissions from this type of source; 8286.44 MT / year of PTS which is 2.13%; and 142.51 MT / year of CO which represents 0.04%. Table 1 shows emissions from all sources in the City of La Oroya. 2.2 State of the Air Quality. The results of the air quality studies performed by DIGESA17 specifically show the state of the air quality during the dry and rainy seasons. Tables 2, 3, and 4 show the results of both studies. The concentrations of sulfur dioxide, SO2, obtained during the monitoring performed by DIGESA exceeded on more than one occasion the average daily ECA for SO2, which is 365 µg / m3. According to the continuous monitoring reports that DOE RUN PERU started in the year 2000, concentrations of SO2 exceed the average annual ECA 80 µg / m3 for SO2 at all stations. The Air Quality Standard for PM10, daily average of 150 µg / m3 was exceeded twice in the evaluation of March of 2003. The Air Quality ECA for PM10 average annual 50 µg / m3 was exceeded at all stations, except in Casaracra. The air quality standard for Lead average annual 0.5 µg / m3 was exceeded broadly although there was a reduction by the year 2002. The only station that recorded levels below the ECA is the Casaracra station. Of the two tests performed by DIGESA the Reference Value for PM 2.5 of 65 µg / m3 was exceeded on March 5 and 7 of 2003.

17 For the purposes of the Diagnostic, the first study performed by DIGESA from March 5 to 11, 2003 (rainy season), the second

study was undertaken from September 3 to 9, 2003 (dry season), the air quality state in the City of La Oroya was specifically sampled in both.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

11

According to the air quality monitoring report for the atmospheric basin, besides lead, there are {{high levels of}} other toxic contaminants, such as cadmium and arsenic, not considered in the National Environmental Air Quality Standards Regulation. 2.3 Social and Health Impact. The evaluation18 of the health impact resulting from lead pollution indicates a high exposure especially among children, with an average of 34.9 µg / dL for children from 2 to 10 years of age. Table 5 shows the results of the study performed by DIGESA in 1999; and Table 6 the results of the study19 in 2005. Morbidity associated with contamination in populations grouped by ages was analyzed to evaluate the impacts of SO2 on health, which information was provided by the General Health Department of Junín. A considerable increase in IRA’s was seen in the last 4 years, where children less than 9 years of age were the most affected. A correlation was found between levels of concentration of SO2 average annual for the 5 stations located in La Oroya for the years between 1998-2001 and the total number of IRA’s recorded at health centers, which is corroborated with the general statistics from the health sector.20 The Baseline Diagnostic concludes that the impacts of the metallurgical complex on health are significant, especially in children. Other reference studies confirm this diagnostic21, demanding even emergency measures that must be undertaken in the short-term for a large part of the population, as well as comprehensive prevention solutions that will make it possible to reverse the health situation for the entire population.22

3. Goals and Objectives. The objective of the action Plan for the improvement of the air quality and health of La Oroya is to have the Priority Attention Zone23 of the City of La Oroya achieve national environmental air quality in the least amount of time technically possible and socially desirable for the priority protection of people’s health.24 The results of the Baseline Diagnostic evidence that the La Oroya atmospheric basin is effectively in an environmentally critical situation with significant levels of exposure to sulfur dioxide and particulate matter that contains heavy metals such as lead – and other related contaminants such as cadmium, arsenic, and others – on the

18 Three studies on lead in blood were used to evaluate the effect of lead on health at La Oroya, which were performed by:

DIGESA in 1999; Consorcio UNES in 1999; and DOE RUN PERU DOE RUN PERU 2001. 19 Study performed under the framework of the Ministry of Health – DIGESA and DOE RUN PERU Agreement. 20 “At La Oroya (together another two districts) the incidence of chronic pulmonary diseases is higher than in the rest of the

department.” See Integrated Plan to Control Lead Pollution in Children and Expectant Mothers in La Oroya Antigua, Peru 2004-2010” MINSA-DRP Agreement, 2004, Pg. 9.

21 There is “a correlation between uncontrolled atmospheric emissions from smelting operations and high levels of lead in blood in populations that live near the foundry’s operations.” See Development of an Integrated Intervention Plan to Reduce Exposure to Lead and Other Contaminants in the Mining Center of La Oroya, Peru” report. CDC – USA, 2005, Pg. 20.

22 See Study on environmental contamination in the homes of La Oroya and Concepción and its effects on the health of its residents. University of Saint Louis – Archdiocese of Huancayo, Pg. 40.

23 Articles 9 and 20 of the National Environmental Air Quality Standards Regulation. SD. No. 074-2001-PCM. 24 Article 2 and Remark 83 of Directorial Order 157-2006-MEM/AAM (02.17.2006).

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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part of the vulnerable population, which faces probabilities of acute and chronic effects on their health.25 However, the knowledge and perception of important sectors of the population on the risk to health generated by contamination by gases and heavy metals is still limited given that “there is no evidence of a clear relationship between the environmental problem identified and its impact on people’s health,” and there is also “significant ignorance on what lead intoxication is,” requiring, as a result thereof, a training, education, and communication program for the population.26 The fact that there is a significant economic relationship of one sector of the population to the metallurgical complex likewise influences the perception of risk and the necessary actions to protect health:27 15.59% of the economically active population works in metallurgical operations, whereas another 16.9% in formal and informal commerce and 12% in services, both strongly dependent on the income generated from the mining and metallurgical activity predominant in the zone. The design and implementation of epidemiological and environmental monitoring by DIGESA and other competent authorities at MINSA, as well as mechanisms to protect the vulnerable population28 and states of alert29 are necessary to supplement the decontamination actions. The actions that are established in the Plan contemplate immediate measures to be adopted related to the health and environmental situation of the atmospheric basin. Such actions include reducing emissions from the metallurgical complex, the reduction in exposure of people and the evaluation of additional risks present in the basin, as well as such as must be performed with a view toward the medium- and long-terms. In that context the objectives of the Action Plan are: 3.1 GENERAL OBJECTIVE.

Protect the health of people and the quality of the environment by implementing concerted and participatory strategies, policies, and action measures to control environmental contamination, drastically reducing net emissions from stacks and fugitive emissions from the metallurgical complex and others, according to the responsibilities that belong to the generators according to their specific contribution to the contamination, also adopting supplemental health and environmental measures to mitigate the effects on the health of the population of La Oroya, especially the most vulnerable population, while the environmental quality and health goals established in the specific objectives are met. The reduction in the contamination will contribute to the sustainable development of La Oroya, which objective is shared both by the population and the workers to protect their health and by the company and local economy in order to ensure the sustainability of the metallurgical operations in light of current national and international standards and commitments and future environmental instructions that will be imposed by world trade.

25 “Children still can experience long-term adverse health effects” according to the Development of an Integrated Intervention

Plan to Reduce Exposure to Lead and Other Contaminants in the Mining Center of La Oroya, Peru” report. CDC – USA, 2005, Pg. 18.

26 “Consulting report on the opinion survey on the environment and lead contamination” performed on 300 people in the city of La Oroya by the sociologist Diana Bazán and the communications expert Magda Carrera by commission from Cooperacción. (December 2003.)

27 INEI, DRP, MINSA “Socioeconomic Study of the La Oroya District” (2002). 28 Article 16 of the National Environmental Air Quality Standards Regulation. SD. No. 074-2001-PCM. 29 Articles 23 of the National Environmental Air Quality Standards Regulation. SD. No. 074-2001-PCM.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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3.2 SPECIFIC GOALS AND OBJECTIVES. The achievement of these goals and objectives requires the support, commitment, and performance of the shared but different responsibilities on the part of pollution generators, but also the supplemental measures to implemented by all sectors (public and private institutions, the organizations of society and the population as a whole) in order for the city of La Oroya to be sustainable and healthy. 3.2.1 Specific Goals and Objectives to Reduce Emissions Doe Run Peru will undertake such actions to modernize the metallurgical complex, PAMA projects and supplemental projects as are necessary to reduce emissions from the metallurgical operations, giving priority to sulfur dioxide emissions (SO2), particles less than 10 microns (PM10), and lead (Pb) to reach the following goals:30 a. sulfur dioxide (SO2) reach ECA values from the year {2008 – 2010}; b. particles less than 10 microns (PM10) reach ECA values from the year 2007; c. lead (Pb), reach ECA values from the year 2007. d. {particles less than 2.5 microns (PM2.5) reach reference values established in Annex 3 of the 074

[sic] from the year 2007 … or apply provisions of Article 12 of the 074}; Centromín Perú will contribute to reaching these ECA goals with such actions as appertain to it for the control of environmental liabilities that negatively impact air quality through the ground and dust with a metallic content that is re-suspended. These remediation actions will be undertaken starting in 2007 within the framework of the PAMA commitment of the state company (Project 4) or such terms as are determined by the authority as a function of health protection. Other fixed and mobile sources shall also perform the actions necessary to reach these ECA objectives. 3.2.2 Specific goals and objectives to reduce exposure to contamination As an indicator of environmental quality, reduce and control exposure to lead in the vulnerable population31 with priority given to the La Oroya Antigua zone, in order to achieve average weighted values of lead in blood in the range of 15-20 µg / dL in the year 2008 and by the year 2010 reach the protection values recommended by the World Health Organization of 10 µg / dL.32 The supplemental health and environmental measures to mitigate the effects on the health of the vulnerable population, while the objectives established are being reached, prioritize the reduction in exposure to lead33 through preventive measures for the entire population and promotion measures appropriate to each age and risk level;

30 Objectives of Section I.1 of Report 040-2006-MEM/AAM/LS/FV/AL/HS/EA/PR/AV/FQ/CC/AA, ordered by Article 2 of

Directorial Order 157-2006-MEM-AAM. 31 Children under 16 years of age (which in principle are those up to the regular basic education level), as well as expectant

mothers {and the elderly}. 32 Objectives to prevent and reduce health risks to people of Section I.2 of Report 040-2006-

MEM/AAM/LS/FV/AL/HS/EA/PR/AV/FQ/CC/AA, ordered by Article 2 of Directorial Order 157-2006-MEM-AAM. 33 Children’s exposure to lead is associated with the particles deposited around them. Absorption is through the digestive tract.

Hygiene measures, such as hand-washing and a reduction in hand-mouth type behavior reduce exposure to lead because the oral ingestion of it is substantially reduced.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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This objective implies performance of the “National Plan for Social Participation and multi-sectorial commitment to strengthen environmental management and reduce morbidity and mortality from contamination by lead and other heavy metals.” 3.2.3 Specific goals and objectives for epidemiological and environmental monitoring Develop a supplemental epidemiological and environmental monitoring program34 to prevent risks to the population, with the participation of and financing by the corresponding public and private institutions, which includes 100% of the vulnerable population of the city of La Oroya35 and consists in epidemiological follow-up to prevent diseases or medical care programs if there are people affected by air pollution. 3.2.4 Specific goals and objectives for air quality monitoring Adequately implement by the year 2006, within the atmospheric basin environment, an air quality monitoring and health impacts system, including a pertinent citizen information system, {prediction / dispersion} models, an air-quality monitoring system, continuous updating of the inventory of emissions and periodic epidemiological studies. The system shall be the responsibility of the competent public institutions with the contribution of instructions of recognized technical and scientific quality, and it includes the necessary information quality management measures. Information reliability, its adequate administration, and its timely dissemination will make it possible to strengthen the environmental awareness of the entire population, expressed as a better perception of health risks and the adoption of responsible attitudes and conduct. 3.2.5 Specific goals and objectives on healthy environments and the healthy local education

project Promote Health Environments36 and implement a Healthy Local Education Project37 with the contribution of educational agents and allies38 in order to reduce children’s exposure to immission zones (contaminated environment), where they currently spend long periods of time.

34 Assumed by DIGESA. Article 15 of the National Environmental Air Quality Standards Regulation. SD. No. 074-2001-PCM.

Also as a general strategy through the Joint Regional Health Plan Junín Region 2005-2012. Pg. 35. 35 The Development of an Integrated Intervention Plan to Reduce Exposure to Lead and Other Contaminants in the Mining

Center of La Oroya, Peru” report, CDC – USA, 2005, Pg. 16 recommends: “virtually the entire childhood population—should be evaluated.”

36 This implies the sustainable development of the atmospheric basin and measures for self-care of health and improvement of the quality of life in health promotion educational institutions (healthy schools), healthy municipalities, healthy families, and healthy workplaces.

37 {This includes a curriculum structure in accordance with the local environmental reality (which involves greater knowledge of health and environmental problems and risks caused by economic activities in general and the metallurgical complex in particular), the organizational strengthening of the local education system, on-the-job training of teachers (train them and perform follow-up to see its application in hygiene habits, reduction in exposure to risk, improvement of the local environment, etc.) among other actions.}

38 This includes teaches, students, parents, companies, public authorities and institutions, civil society organizations (base organizations, NGO’s, health promoters, etc.).

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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4. Measures for the Comprehensive Management of Air Quality.

Comprehensive management of the air quality in the La Oroya atmospheric basin depends to a large degree on sectorial management from the Ministry of Energy and Mines and the efforts that Doe Run Peru, Centromín Perú and other polluting agents undertake in a shared but differentiated fashion to reduce emission – contamination levels and to meet the environmental commitments established in the PAMA; this will be supplemented with measures aimed at the reduction of the effects of the contaminants that are in the local healthiness plan and household hygiene, as well as the improvement of personal hygiene. In the medium- and long-term it also contemplates urban and rural planning as a suitable measure, which includes the development of sustainable and healthy environments. Within that context, the priority measures to achieve the objectives established are: 4.1 MEASURES TO ESTABLISH THE AIR QUALITY AND HEALTH MONITORING

PROGRAM. Meaning contamination will make it possible to determine the level of health risk that people are exposed to, as well as the efficiency of the measures adopted in the Plan, achieving control at the workplace level and effective self-control at the company level. Monitoring of the air quality and the impacts on health has a high social and economic value, it allows for modulation of the participation of the different agents in society, increasing their concern for the protection of health and the environment and facilitating follow-up on the decisions taken to channel appropriate actions. The following are the measures adopted in relation to this item: 4.1.1 Air Quality Monitoring System. In order to evaluate the efficacy of the measures taken, air quality management requires the development of a monitoring system that includes: an air quality monitoring network and an inventory of emissions, which are capable of offering results that then allow for epidemiological studies to be performed aimed at preventing adverse effects on the population. According to this standard,39 responsibility for the system will lie with the Ministry of Health through DIGESA, which must be designed and executed in a participatory manner. a. Monitoring network. The network will offer real-time information, thus becoming information useful for immediate decision-making and for the timely prevention of risks. In order to better protect people’s health, the implementation of the network will start in the year 2006. The monitoring network will be implemented as a function of the air quality monitoring studies and weather monitoring performed in the scope of work, from which the competent authority will define, technically and with participation, the location of the points where

39 Articles 12 and 13 of the National Environmental Air Quality Standards Regulation. SD. No. 074-2001-PCM.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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the stations will be installed, the selection of the necessary equipment and the design of liaison and information reporting mechanisms. While the network is being implemented, the Ministry of Health, though DIGESA, must already have the daily air quality monitoring, weather, and emissions report generated by Doe Run Peru’s monitoring network,40 and act accordingly. b. Inventory of emissions. The inventory of fixed-source emissions, including environmental liabilities, and from mobile sources, will be developed as one of the principal activities for the prevention of contamination. In order to ensure its permanent updating and improve its reliability, mechanisms will be developed to maintain universal coverage of the records of sources of fixed and mobile emissions, public and private, as well as its automation and referencing to a geographic information system that is available to the public. Taking 2004 as the base year, emissions will be estimated annually within the scope of work, in the following sequence: emission source recording mechanism, continuous updating of information on the vehicle fleet; speciation of contaminants; assignment of responsibilities and focusing of measures; quality assurance and data validation mechanism; and forecasts of emissions, considering different scenarios. Emissions currently called “fugitive” will be reduced progressively until they are controlled toward the year 2007. 4.1.2 Health Impacts Monitoring System The formulation of public health policies, environmental regulations, and cost-effective decision-making, requires an information generation and management system that makes it possible to determine the magnitude of environmental contamination and the risk factors or determinants that contribute to maintaining a permanent environmental risk situation.41 In our country public health monitoring constitutes one of the most important strategies for the timely ascertainment of damage or events that damage people’s health, allowing for the control, elimination, and/or eradication of risk factors. Epidemiological / environmental monitoring will make it possible to permanently evaluate the efficacy of prevention and control actions related to contamination or environmental contamination risk factors, allowing for the control, elimination, and/or eradication of risk factors. Epidemiological / environmental monitoring will make it possible to evaluate the efficacy of contamination or environmental contamination risk factor prevention and control actions on an ongoing basis, for the actions to be sustainable and to give priority to the healthcare of people, as a responsibility shared by the state, companies, civil society, and families. According to the standard,42 responsibility for the system will lie with the Ministry of Health, which will be monitored with a system of health effects indicators.

40 Art. 10 of SD 009-2003-SA and its amendment SD.012-2005-SA, in effect from the notification of the status as macro-emitter

given to Doe Run Peru by the National Board of the Environment, through notification 2638-2005-CONAM/PCD of December 12, 2005, pursuant to Art. 9 of that selfsame regulation.

41 Evaluation and use of epidemiological evidence for environmental health risk assessment. Guidebook. WHO – Regional Office for Europe. European Centre for the Environment and Health. Bilthoven Division. 2000.

42 Articles 14 and 15 of the National Environmental Air Quality Standards Regulation. SD. No. 074-2001-PCM.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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4.1.2.1 Epidemiological monitoring and Epidemiological studies. The system will be based on periodic environmental epidemiological studies and their follow-up43, which make it possible:

To determine the relationship between air pollution and the occurrence of respiratory, cardiovascular, and other diseases.

To evaluate the effect of prevention and control intervention measures implemented to reduce or control air pollution.

To implement new measures to protect people’s health. These studies take into account from the descriptors (analysis of morbidity and mortality, demand for hospital services both outpatient and emergency due to problems related to air pollution) {sic}. The frequency of studies will depend on the need for knowledge to improve interventions, it may be annual or when there are emergency environmental episodes or in those in which the health situation so requires, which make it possible to have better evidence on the risk that the population is exposed to. An active and passive system to monitor injuries or illnesses related to the air pollutants identified in the city of La Oroya will be developed based on the epidemiological studies. Epidemiological monitoring {will confirm indicators} and be assured with a reliable and valid information system that allows for timely decision-making. 4.1.2.2 Health programs. Healthcare being a responsibility shared by the state, civil society, families and companies, the following strategies or measures are proposed:

Promote healthy environments as the most important central axis for healthcare and to achieve a reduction in the risks of contamination by people, for that strategies will be implemented for: health promotion educational institutions (healthy schools), healthy municipalities, healthy families, and healthy workplaces.

The development of healthy environments implies among other measures that the Local

Educational Management Unit incorporate environmental prevention of contamination at all educational levels.

Promoting healthy environments must include a reduction in the exposure of children to

the contaminated environment, immission zones, where they currently spend a lot of time.

An epidemiological monitoring system will be implemented:

* For diseases related to air pollution and it will be continuous with a greater emphasis when there is greater environmental risk.

43 The epidemiological studies will preferably be: “Randomized epidemiological tests” which are the ones that provide the

greatest degree of evidence to confirm the cause / effect relationship between exposure and the event under study. Hernandez-Avila, M.; Garrido-Latorre, F.; Lopez-Moreno, S. Design of epidemiological studies, Mexican Journal of Public Health, vol. 42, no. 2 March – April 2000, pg. 144.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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* Environmental quality monitoring: air, water, ground, flora and fauna.

The ability to respond and the level of complexity of the La Oroya Health Center will be strengthened, through an improvement in infrastructure, equipment, and human resources, as well as coordination of the capacities of MINSA, ESSALUD, and the private sector.

A program to care for the vulnerable population with high levels of Lead or other contaminants who show health risks will be established, the care will be given by the Ministry of Health and financed by DOE RUN PERU for that, among other options, the current agreement between the company and local health authorities could be strengthened. The design of the program must result from all of the scientific evidence that currently exists.

4.1.3 Citizen Information System. Timely notification of the community of risks represents the most effective strategy to protect the health of people, given that it allows the individual to assume self-care, adopt safe conduct and progressively develop healthy lifestyles. Notification, to be effective, must be based on an automated information system that offers real-time information on the air quality in the city. The citizen air quality information system is part of the Local Environmental Management System and it is coordinated with the National Environmental Information System44 and the Regional Environmental Information System.45 The information system must offer information to citizens from 2007, its implementation will be undertaken taking into account the design of a database that includes, without being restrictive: a. Estimates of emissions. b. Air quality measurements that have been made and their relationship to the ECAs and states of

national alert levels, and c. The data gathered by the health impact estimate program that the sector will develop. d. The data gathered by the environmental impact estimation program. There will be multi-sectorial coordination and information will be linked to the inventory of emissions and pubic information. Forms and informational normalization and liaison systems will be designed. Modelling will be one of the principal functions of the system, for that it is necessary to systematize information which will consist in the design and standardization of forms of gathering information and processing data. The initial modeling is planned to result from a process that consists in the preparation of terms of reference, co-opting the necessary technical personnel, preparing the model and validation. The first models must be available by 2006 for their validation during 2007. The management of the modeling will be the responsibility of an Air Quality Management Technical Group,46 which will be proposed by the Municipal Environmental Commission – CAM and will be formed taking as a reference the Zonal Air GESTA.

44 Supreme Decree No. 008-2005-PCM. Regulation. Environmental management system framework act. Article 68. 45 Regional Ordinance 029-2005-GRJ/CR. Regional Environmental Management System of Junín Articles 35 et seq. 46 Supreme Decree No. 008-2005-PCM. Regulation. Environmental management system framework act. Articles 33 and 50.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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4.2 MEASURES TO IMPROVE THE AIR QUALITY AND TO PREVENT ITS

DETERIORATION. The modification of unsustainable patters and conduct of production and consumption is necessary to deal with the increase in contamination; that involves development and promotion actions, environmental education and training, control and audit, and organization of the city, among other things. The following are the measures adopted in relation to this: 4.2.1 Program to Strengthen the Comprehensive Management of Air Quality. The decisions made to improve the air quality require the joint action of the different public and private institutions committed to environmental health. Strengthening of institutional capacities, the development of clean technologies, and health education are keys for the success of the action. Within this context, the lines of action of this program are: a. Strengthening of the competent authorities. This is an indispensable requirement for the competent authorities, especially the Provincial Municipalities, to be able to lead the change processes that will enable the Plan’s objectives to be met. Constant training of human resources, the development of standards, guidelines, and technical protocols and fluid communications, will allow institutions to perform better. It is proposed that by the year 2006, the “Framework Environmental Management Ordinance of the Province of Yauli – La Oroya”47 be brought into compliance with the terms stipulated by the National Environmental Management System Act, using the Municipal Environmental Commission48 for coordination and agreement purposes, whose principal function is following up on the actions that fall under the responsibility of the local entities in this Action Plan, as well as to support the supervision of the performance of the plan for which CONAM is responsible,49 for which the citizen participation mechanisms established in environmental law shall be applied.50 b. Technological development and innovation. The application of clean technologies is one of the principal strategies to prevent contamination. The specific actions that Doe Run Peru must undertake, will ensure achievement of the maximum allowable limits established by the competent authority or authorities, as well as the national air quality standard target values on the dates proposed in this Plan51 (((supplement note with directorial Order))). CONAM and the other competent institutions will establish any additional measures that might be necessary. Emissions control constitutes the main contamination prevention and control policy. In the city of La Oroya technological innovation consists in the modernization of the metallurgical complex and it is the responsibility of Doe Run Peru.

47 Created by Municipal Ordinance 005-2004-CM/MPYO of January 28, 2004. 48 Supreme Decree No. 008-2005-PCM. Regulation. Framework environmental management system act. Article 49. 49 Supreme decree No. 074-2001-PCM. Article 24. Part “e”. 50 Supreme Decree No. 008-2005-PCM. Regulation. Framework environmental management system act. Chapter IX. 51 Minutes of meeting 56 of the Air GESTA dated 01.25.2006 and communication VPAA-046-06 from the Corporate Vice

President for Environmental Affairs of Doe Run Peru of 02.06.2006.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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And they must additionally comply with the commitments assumed in the PAMA and other supplemental or specific provisions established by the authorities. Likewise control of sources of emissions derived from environmental liabilities is the responsibility of Centromín Perú, for which it must meet the commitments assumed in the PAMA and other supplemental or specific provisions established by the authorities. c. Strengthening of capacities. To ensure the efficient execution of all the actions designed in the Plan and to achieve the objectives proposed there must be aware and trained groups of humans at all levels including at the population level. The media has a proactive role in relation to the assimilation and empowerment of the Plan at the population level. Education centers at different levels of teaching also have a primordial mission to be able to achieve sustainable production and consumption methods. Within this context annual actions are proposed in the field of education and training, the tasks starting in the year 2006 with awareness and education programs aimed at students of different grades, consumers, and the general population, emitters, professional decision-makers, and functionaries. Risk notification and information programs for communications experts, journalists, and opinion leaders that allow active participation by the written, radio, and television press. Mass campaigns that foster environmental awareness; and citizen participation mechanisms. Capacity strengthening will be a responsibility of the Local Environmental Management System.52 4.2.2 Emissions Monitoring Program. To reinforce and support the efforts aimed at reducing emission modern monitoring techniques must be developed for the control measures adopted. This program will be the responsibility of the Municipality through its environmental unit. The Emissions monitoring system will consist in the performance of onsite activities. For the vehicle fleet, experimental periodic emissions measurements started in the second half of 2005 with the application of “symbolic fines” for awareness. By 2006 monitoring actions will be implemented through a Municipal Ordinance that impose an effective fine on violators. The priority parameters will be PTS, PM10, PM2.5, CO and Pb. For the other economic activities, especially production, with the exception of the macro-emitter, the statement of emissions to the Provincial Municipality is proposed from the year 2006, which at the start will be voluntary but from 2007 will be mandatory and will constitute the principal mechanism to update the emissions inventory, in coordination with the competent sectorial authorities. In the case of emissions from the metallurgical complex, the competent authorities, with the contribution of the La Oroya Air Quality Management Steering Committee, will perform emissions control and measurement, with especial attention on the elimination into the environment of fugitive emissions.

52 Supreme Decree No. 008-2005-PCM. Regulation. Framework environmental management system act. Articles 45 and 68.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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4.2.3 Cleanup, Remediation, Organization, and Planning of the Atmospheric Basin Program The program will be the responsibility of the Local Environmental Management System and will consist primarily of the following actions: a. Cleanup and remediation. The daily sedimentation and re-suspension of particles in the city of La Oroya, especially of lead and other heavy metals in homes, schools, and on public roads constitutes one of the main risks to people’s health. However, the daily cleaning actions of homes, schools, and public roads will not be fully effective unless atmospheric emissions on the part of the owner of the operations are first reduced, and remediation is performed on the soil by the owner of the environmental liability.53 Even so, with a preventive view, it is believed that the daily cleaning of homes and schools should be part of the programs to promote healthy environments and the local healthy educational project to be implemented under coordination of the competent authorities, the support of public institutions and the material contribution of the emissions generators. Thus the city must consolidate the cleaning experience in order to keep the streets permanently free of particles. The environmental liabilities54 present in the basin that are the responsibilities of Centromín Perú especially those related to settled particles, constitute a permanent danger to the population, increasing the risk because of their environmental mobility, principally by water and the food chain, and made more acute by the weak health education of the population and the scarcity of technology that they have for sanitation and remediation. Without being restrictive, the performance of bioremediation projects could be a good alternative. Their performance can be consolidated with the participation of universities and technical cooperation from international institutions. FONAM might finance those projects from their formulation phase. The country has great potential associated with the gene bank that it has for such purposes. b. Road organization Through a Municipal Ordinance, starting in the year 2006, a road development plan should be developed for the city, which includes the construction of alternative routes and beltways. Also starting in the year 2006, through a Municipal Ordinance, adjust the cities Road Plan and Organization, to define travel times in restricted areas, formal stops, interprovincial ground terminals and traffic signals in order for the main road to be optimized and adequately travelled. The local government will proceed to grant an environmental certification to vehicles whose emissions are within the LMPs.

53 “Without reduction of air emissions and remediation of soil, home hygiene and clean neighborhood campaigns are of little

value in decreasing the risks,” according to the Development of an Integrated Intervention Plan to Reduce Exposure to Lead and Other Contaminants in the Mining Center of La Oroya, Peru” report. CDC – USA, 2005, Pg. 23.

54 Law No. 28271, which regulates the Environmental Liabilities of Mining Operations.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

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c. Basin planning The different current and future economic activities in the atmospheric basin must not only meet the economic expectations of development, but also social needs, especial health and environment needs, that allow the basin to transition to sustainable development. Within this context it is necessary to strengthen and support planning actions associated with production processes such as industrial parks, commercial axes: with the areas assigned for environmental cleanup especially sanitary landfills and hazardous waste landfills, oxidation ponds or effluent treatment plants, among others; with the development of mitigation and dampening areas such as green areas or ecological belts or environments; and infrastructure and tourism development programs for the basin[.] Of all of these alternatives the Plan prioritizes the increase in urban green areas at a rate of 10% per year of the current difference between the existing areas and the standards established by the WHO for green areas per inhabitant for cities; the development of an ecological belt around the city that is consolidated from the year 2007; and support for the adequate disposal of solid waste of the city, and for the management of wastewater, pursuant to the Comprehensive Basic Sanitation Plan for the city. The initiatives for urban / regional planning must be fostered and in this sense, the Clean the Air Plan implies the implementation of the Urban Development Plan for La Oroya {note of Municipal Ordinance 000-2005-MPYO/CP approved in the year 2005}. 4.3 Measures to Apply During States of Alert. As established in SD 09-2003 SA, DIGESA will be the one to activate the contingency plan by ordering states of care, danger, and emergency. The measures will be based among other things on: Alert systems that organize preventive actions taking into account as a basis the information provided by the automated air quality and weather permanent monitoring network, by establishing actions such as: implementing a system of visual and sound signals; giving operational capabilities to brigades responsible for the signaling system; and establishing communications mechanisms between the monitoring and forecast network and the media. Information dissemination systems, key for ensuring access to information on the measures for the population to take. It requires the following actions: inform the population through the media, of the implementation of the states of alert; prepare content for dissemination campaigns; produce and disseminate informational material for the population; and prepare panels and murals. Training System, the reduction of the effects of air pollution on the general population giving special interest to vulnerable groups, it requires [prioritized?] follow-up, therefore the educational actions must be aimed at these groups to provide training to the media and liaisons who work with vulnerable groups and involve the members of vulnerable groups in the implementation of campaigns. Inter-institutional action System, both informational and educational activities require the joint work of the institutions that perform actions within the framework of the Clean the Air Plan and others that are directly related to vulnerable groups. The following activities will be performed: sensitize and commit the authorities and staff of local institutions to adopt policies and measures in relation to the

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

23

implementation of actions under the Plan; sign inter-institutional agreements; monitor and follow up on the activities of the La Oroya Clean the Air Plan.

5. Financing The environmental and health situation of La Oroya warrants priority attention on the part of the State and the private sector and civil society, which must be expressed in the Joint Development Plans of provincial and regional scope. In this sense, the State, at all its levels of government, will manage and finance the activities stipulated in this Plan according to its functions and competencies.55 The role of the private sector in the financing will in general be subject to the provisions of current environmental law56 and of the specific responsibilities derived from the status as a macro-emitter already reported to Doe Run Peru.57 Civil society and international cooperation organizations will also contribute to such voluntary commitments or projects as become necessary at the request of the Municipal Environmental Commission of La Oroya and coordination with the competent authority. For financing purposes, the Plan does not include the budget for the actions that Doe Run Peru must perform within its facilities in accordance with the sectorial commitments undertaken with the State, expressed principally in the PAMA and its amendments within the framework of current precepts.58 The Ministry of energy and Mines must ensure the effective performance of the measures that the company implements to reduce emissions. Modernization of the plant is a commitment also assumed by the Company and its financing is not included in this Plan. Nor for the purposes of financing does it include the obligations of Centromin Perú to perform its PAMA, Project 4 “Remediation of areas affected by fumes” or such terms as are determined by the authority. Some financing mechanisms that have been identified to undertaken the lines of action in this Plan, in general terms are related to: exchange of debt for environment, exchange value funds, international sustainable development funds, technical and financial cooperation funds, donations and others to protect the environment; public treasury, optimization of the existing budget through shared actions that will make it possible to meet part of the economic demands of the Plan; special regional and municipal development funds, the use of funds for regional and municipal development may be prioritized in favor of the Plan, once the priorities are established; funds that are returned from the ones obtained from the application of the Plan’s implementation measures. Monitoring, audit, and promotion activities have been prioritized in order to reduce emissions of pollutants and to protect the health of people, those activities have been grouped I three lines of action: to establish the air quality and health monitoring program; to improve the air quality and prevent its deterioration; and to apply during states of alert [sic]. {In total the Plan as a whole requires financing on the order of US$ 7,130,769 (NS/. 23,175,000).59} {Table 7 presents the estimated budget to perform the Plan. Annex 1 presents the components to establish the air quality and health monitoring program, which amount to US$ 4,500,000 (NS/. 14,625,000). Annex 2 presents the components to improve the air quality and prevent its deterioration, which amount to US$ 2,721,875

55 Law 28611. General Environment Act Art. 38. 56 Law 28611. General Environment Act Art. 40. 57 Articles 9 and 10 of Supreme Decree No. 009-2003-SA. Regulation of the National Air Pollution States of Alert Levels.

Amended by Supreme Decree No. 012-2005-SA. 58 SD 016-93-EM Environmental protection regulation for mining and metallurgical operations and amendments; SD 046-2004-

EM Provisions for the exceptional extension of time frames for the performance of specific environmental projects contemplated in environmental adjustment programs, PAMA. (12.29.04).

59 Exchange rate US$ 1 = NS/. 3.25

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

24

(NS/. 8,387,500). The actions to be performed to apply during states of alert have a special treatment and will be detailed in the respective Contingency Plan.60 Agreement for the corporate work will be one of the main tasks to be undertaken by the committed institutions in order to make the performance of Plan feasible, its unanimous approval will facilitate that path.

6. Evaluation and Follow-Up. CONAM, in application of the provisions of the General Environment Act,61 will coordinate the execution, evaluation, and public reporting of the Action Plan with the competent authorities, as well as the corresponding audit with the participation of the Municipal Environmental Commission of La Oroya within the Local Environmental Management System, without prejudice to such as must be performed by the Comptroller General of the Republic within the National Control System. To this end the performance of the following is specifically proposed: a) monthly follow-up of performance of the activities according to responsibilities; b) a semiannual evaluation of the impact of the measures established in the Plan; c) semiannual public action reports; d) an annual review and update of the Plan’s measures; e) others established by Law.

60 Supreme Decree No. 009-2003-SA and its amendment SD 012-2005-SA Regulation of the National Air Pollution States of

Alert Levels. DCD 015-2005-CONAM/CD Directive for the application of the Regulation of the National Air Pollution States of Alert Levels.

61 Law 28611. General Environment Act Art. 34 and 130. Supreme Decree No. 074-2001-PCM Art. 24 part e).

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

25

Charts

Atmospheric Basin Urban Area River and Stream District Boundary District Capital Population Center CONSORTIUM {illegible} ATMOSPHERIC BASIN Zonal Air GESTA – La Oroya Date – March {illegible} | Location – Province of Yauli – La Oroya Scale: 1 : {illegible} | Source {illegible} | National Chart (MON)

Chart 1: Delimitation of the Atmospheric Basin of the City of La Oroya confirmed by SENAMHI.

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

26

Tables

Table 1: Results of the emissions estimate.

Totals PTS SO2 NOx CO COV Total

MT / year MT / year MT / year MT / year MT / year MT / year

Total Mobile Sources 17.62 60.93 221.84 559.14 97.03 956.56

Total Fixed Sources 8 294.19 380 175.52 4.05 241.61 32.66 388 648.03 Specific fixed source 8 286.44 380 074.50 N.D. 142.51 N.D. 388 503.45

Area fixed source 7.75 1.02 4.050 99.1 32.66 144.58

In the atmospheric basin 8 311.81 380 136.45 225.89 800.75 129.69 389 604.59Percentage 2.13 % 97.57 % 0.06 % 0.21 % 0.03 % 100.00 %

Of the total PTS: 846.856 MT / year correspond to Lead 845.74 MT / year to fixed sources; and: 1.12 MT / year to mobile sources.

Table 2: DIGESA. Results of the first measurement. March of 2003.

District Station SO2 NO2 PTS PM 2.5 Pb

µg/m3 µg/m3 µg/m3 µg/m3 µg/m3

Oroya Antigua E-1 Colegio Encinas. 344.41 10.93 119.95 79.04 6.995Town of Paccha E-2 Town of Paccha. 303.81 11.30 26.74 20.05 0.613

Santa Rosa de Sacco E-3 Santa Rosa de Sacco. 379.82 31.62 111.83 33.52 1.211

Huaynacancha Oroya Nueva

E-4 P.S. Huaynacancha. 303.62 17.40 37.09 26.68 0.737

Table 3: DIGESA. Results of the second measurement. September of 2003.

District Station SO2 NO2 PTS PM 2.5 Pb

µg/m3 µg/m3 µg/m3 µg/m3 µg/m3

Oroya Antigua E-1 Colegio Encinas. 191.38 26.58 67.64 32.53 1.404

Town of Paccha E-2 Town of Paccha. 8.45 27.33 55.59 20.09 <LDD

Santa Rosa de Sacco E-3 Santa Rosa de Sacco. 79.88 50.96 108.78 40.69 0.679

Huaynacancha Oroya Nueva

E-4 P.S. Huaynacancha. 66.93 26.30 73.70 26.15 0.267

<LDD: lower than the detection limit of lead (Pb) which is 0.163 µg/m3

Table 4: DIGESA. Air quality March of 2003 for PM10 in µgr/m3. Day 05 06 07 08 09 10 11 12

Average 120.05 146.07 75.34 193.18 56.38 112.88 183.85 85.88

Table 5: DIGESA. Levels of lead in the blood of the population of La Oroya. 1999.

Ages Average µg/dl 2 to 4 years 38.6 4 to 6 years 34.1

6 to 8 years 36.3

8 to 10 years 30.6

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

27

Table 6: DIGESA. Levels of lead in the blood of the population of La Oroya. 2005.

Ranges µg/dl Number of children Percentage 70 and above. 5 0.6

45 to 69.9 66 8.4

20 to 44.9 646 82.0

10 to 19.9 70 8.9 1 to 9.9 1 0.1

788 100.0

{Table 7: Estimated Budget for the Action Plan}

Measures Cost NS/.

To establish the air quality and health monitoring program. 14 625 0001. Air quality monitoring system 1 950 000

Monitoring network, 5 stations. 975 000 Network operation and maintenance. 3 years. 650 000

Inventory of Emissions 325 000

2. Health impact monitoring system 10 000 000Annual epidemiological studies. 5 annual studies.

Healthy environment and contaminant prevention programs. Service 5 years.

Epidemiological Monitoring System. Service 5 years. Investment project to improve the La Oroya CS response capacity and coordinate MINSA-ESSALUD-private sector capabilities. Prevention and promotion 5 years.

3. Citizen Information System 650 000Database. Design and operation for 4 years. 162 500

Modeling. 2 years 487 500

To improve the air quality and prevent its deterioration. 8 387 500

4. Program to strengthen comprehensive management of the air quality. 1 950 000Strengthening of the Competent Authorities. 487 500 Development of technological innovation. Only projects. 975 000

Strengthening of capabilities. 5 years. 487 500

5. Emission monitoring and control program. 1 625 000Control of the motor vehicle fleet. 5 years. 650 000

Control of production processes. 5 years. 487 500

Auditing system. 5 years. 487 500

6. Atmospheric basin organization and planning program 4 812 500Cleanup. 5 years. 900 000 Remediation. Only projects. 500 000

Road organization. 5 years. 1 137 500

Planning of the basin. 2 275 000

To apply during states of alert. 162 500

7. Contingency plan. 162 500Design of atmospheric contingency actions. 162 500

Total cost 21 150 000

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

28

Annex No. 1

{Measures to strengthen the air quality and health monitoring program}

Name of the component: 1. Air quality monitoring system.

Justification for the component: The air quality monitoring system allows for an evaluation of the efficacy of the measures adopted in the “To Clean the Air” Plan it requests the development of an air quality monitoring system and an emissions inventory, which are capable of offering results that subsequently allow epidemiological studies to be performed aimed at preventing adverse effects on the population.

Objectives of the component: To quantitatively determine the level of risk associated with air pollution through a monitoring network and emissions inventory.

Expected results: Periodic reports on:

1. Air pollution levels by contaminants prioritized in the Plan.2. Inventory from fixed and mobile sources of emission.3. Estimation of emission volumes of contaminants within the scope of this Plan4. Speciation studies on contaminants, including environmental liabilities.

Schedule: 1. Implementation of an automatic station. 2. Design of the monitoring network. 3. Implementation of the monitoring network. 4. Operation and maintenance of the monitoring network.5. Interaction between monitoring networks de DOE RUN PERU and that of the Ministry of Health - DIGESA. 6. Inventory and recording of emissions from fixed and mobile sources.7. Calculation of emissions volumes. 8. Speciation studies.

Schedule:

Activities Months

1 2 3 4 5 6 7 8 9 10 11 12 13-24 25-36 37-48 49-60 1 Installation of an automatic station.

2 Design of the monitoring network.

3 Implementation of the network. 4 Operation and maintenance of the network.

5 Interaction between monitoring networks.

6 Inventory and recording of emissions. 7 Calculation of emissions volumes.

8 Speciation studies.

Budgets and responsible institutions.

Activities NS/. (*) Responsible institutions 1 Installation of an automatic station. 97 500 DIGESA. DIRESA.2 Design of the monitoring network. 65 000 DIGESA. DIRESA. CONAM.

3 Implementation of the network. 812 500 DIGESA. DIRESA. CONAM.

4 Operation and maintenance of the network. 585 000 DIGESA. DIRESA. 5 Interaction of the monitoring networks. 65 000 DIGESA. DIRESA. CONAM.

6 Inventory and recording of emissions. 195 000 DIGESA. DIRESA.

7 Calculation of emissions volumes. 32 500 DIGESA. DIRESA. 8 Speciation studies. 97 500 DIGESA. DIRESA. CONAM.

Measurement of success: Monthly and annual environmental monitoring reports on emissions from 2007.

Additional comments: The financing must include the provisions of the Ninth Supplemental Provision of the Environmental Air Quality Standards Regulation, approved by Supreme Decree No. 074-2001-PCM.

(*) Exchange rate US$ 1 = NS/ 3.25

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

29

{Measures to strengthen the air quality and health monitoring program} Name of the component: 2. Interventions preventions and control of the effects on health Justification for the component: The formulation of health policies, environmental regulations and making cost-effective decisions requires scientific evidence that makes it possible to determine the magnitude of environmental contamination and the risk factors or determinants that contribute to maintaining a permanent environmental risk situation. In our country public health monitoring constitutes one of the most important strategies that makes it possible to determine on a timely basis the damage or events that damage the health of people, and it has allowed for the control, elimination, and/or eradication of transmissible diseases. Objectives of the component: Promote healthy environments for healthcare, and reduce the risks of contamination in the exposed population. Expected results: 1. Healthy environments: IEPS, Municipalities, Workplaces, and Families 2. Epidemiological monitoring systems for related diseases. 3. Strengthening of the response capability and complexity of the La Oroya Health Center and coordination of MINSA-ESSALUD-Private

Sector capabilities. 4. Curative healthcare programs for children with high levels of Pb or another contaminant, which evidences a risk to health. Schedule: 1. Design of epidemiological studies 2. Design of healthy environment and pollution prevention programs. 3. Design of an epidemiological monitoring system. 4. Prepare an investment project to improve the La Oroya CS response capacity and coordinate MINSA-ESSALUD-private sector capabilities. Schedule:

Activities Months

1 2 3 4 5 6 7 8 9 10 11 12 13-24 25-36 37-4849-601 Design of epidemiological studies.

2 Design of healthy environment and pollution prevention programs

3 Design of Design of an epidemiological monitoring system.

4 Investment project to improve the La Oroya CS response capacity and coordinate MINSA-ESSALUD-private sector capabilities.

Budgets and responsible institutions. Activities NS/. (*) Responsible institutions

1 Design of epidemiological studies. OGE. DIGESA.

2 Design of healthy environment and pollution prevention programs.

OGE. DIGESA.

3 Design of an epidemiological monitoring system. MINSA

4 Investment project to improve the La Oroya CS response capacity and coordinate MINSA-ESSALUD-private sector capabilities.

MINSA- ESSALUD-private sector

Measurement of success: Adoption of timely measures based on epidemiological evidence. Preventive healthcare of 100% of the vulnerable population. Additional comments: MINSA will continue to take charge of the execution of specific healthcare programs; however it must expand them and make them compatible with the contents of this Plan.

(*) Exchange rate US$ 1= NS/ 3.25

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

30

{Measures to strengthen the air quality and health monitoring program}

Name of the component:

3. Citizen information system. Justification for the component: The timely notification of the community of risks represents the most effective strategy to protect people’s health, given that it allows the individual to assume self-care, adopt safe behavior and progressively develop healthy lifestyles. For the notification to be effective it must be supported on a real-time information system that offers information on the air quality in the city.

Objectives of the component: To inform and educate the general population and children in particular on the risks associated with pollution to enable self-care, the adoption of safe behavior, and the development of healthy lifestyles.

Expected results: 1. Semiannual reports on the air quality and its health and environmental impacts. 2. Monthly reports predicting the air quality

Schedule: 1. Design of the integrated database on the air quality. 2. Design of information formats. 3. Implementation of the information system. 4. Participatory information to the population. 5. Design of modeling and validation system. 6. Modeling of air quality.

Schedule:

Activities Months

1 2 3 4 5 6 7 8 9 10 11 12 13-24 25-36 37-48 49-60 1 Design of the integrated database.

2 Design of information formats.

3 Implementation of the information system. 4 Information to the population.

5 Design of modeling and validation system.

6 Modeling of air quality. Budgets and responsible institutions.

Activities NS/. (*) Responsible institutions

1 Design of the integrated database. 32 500 CONAM, DIGESA

2 Design of information formats. 16 250 DIGESA, Provincial Municipality

3 Implementation of information system. 65 000 CAM, DIGESA.

4 Information to the population. 48 750 CAM, DIGESA.

5 Design of modeling and validation system. 97 500 DIGESA, Technical Group.

6 Modeling of air quality. 390 000 DIGESA, Technical Group.

Measurement of success: Improvement of perception of the risk by the community and the adoption of safe and healthy behavior. Increase in the social responsibility of the private sector.

Additional comments: The Municipal Environmental Commission and the Local Technical Group are stipulated in Articles 33, 49, and 50, respectively, of Supreme Decree No. 008-2005-PCM, the regulation of the Environmental Management System Framework Act.

(*) Exchange rate US$ 1 = NS/. 3.25

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

31

Annex No. 2

{Measurements to improve air quality and prevent its deterioration}

Name of the component: 4. Program to strengthen comprehensive air quality.

Justification for the component: The decisions taken to improve the air quality require the joint action of the institutions committed to environmental health. Strengthening the institutional capacities, the application of clean technologies and health education are key to the success of the actions.

Objectives of the component: To strengthen the capacities of local authorities especially of the Provincial Municipality for them to be able to lead the change processes requires that the environmental contamination of the Zone be stopped.

Expected results: 1. Strengthen the competent authorities, especially of the Provincial Municipality. 2. Development and technological innovation with an emphasis on modernization of the metallurgical complex. 3. General population made aware based on capacities strengthening programs.

Schedule: 1. Creation of the Municipal Environmental Commission and the Local Air Quality Management Technical Group. 2. Design and development of training and update programs for authorities. 3. Design and development of technical guidebooks and protocols for the control and management of the air quality. 4. Design and development of citizen participation mechanisms.5. Design and implementation of projects and technological innovation. 6. Definition by the company of the scope of the modernization of the metallurgical complex. 7. Design and development of awareness, education, and risk notification programs.8. Design and development of mass campaigns that promote environmental awareness.

Schedule:

Activities Months

1 2 3 4 5 6 7 8 9 10 11 12 13-24 25-36 37-48 49-60 1 Creation of SLGA and CAMCA. 2 Training and updating of authorities.

3 Technical guides and protocols.

4 Citizen participation mechanisms. 5 Technology innovation projects.

6 Definition of modernization of the complex.

7 Awareness, education, and communication. 8 Mass campaigns.

Budgets and responsible institutions. Activities NS/. (*) Responsible institutions

1 Creation of the CAM and Local Technical Group. 7 500 CONAM. Provincial Municipality.

2 Training and updating of authorities. 180 000 CONAM. DIGESA Universities. 3 Technical guides and protocols. 200 000 CAM, CONAM. DIGESA.

4 Citizen participation mechanisms. 100 000 CAM, Provincial Municipality.

5 Technology innovation projects. 975 000 MEM. DOE RUN PERU, DIGESA. 6 Definition of modernization of the complex. - MEM. DOE RUN PERU.

7 Awareness, education, and communication. 287 500 CAM, Provincial Municipality.

8 Mass campaigns. 200 000 CAM, Provincial Municipality.

Measurement of success: Implementation of guidebooks and protocols reported by CAM. Implementation of technological innovations reported by CAM. Increased participation of the population recorded by SLGA, Commitments by DOE RUN PERU to the Ministry of Energy and Mines with respect to its modernization.

Additional comments: For Activity 6 due to the fact that the investment required is borne directly by the company it is not considered as a budget under this PLAN.

(*) Exchange rate US$ 1 = NS/ 3.25

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

32

{Measurements to improve air quality and prevent its deterioration}

Name of the component:

5. Emissions monitoring and control program. Justification for the component: The reduction in emissions, to protect the health and the environment, will be achieved after actions taken both by the generator and by the controller. The Provincial Municipality will conduct the Emissions monitoring system, which will contain starting in 2006 periodic measurements of emission of PTS/PM10/PM2.5, CO and Pb on the motor vehicle fleet, starting in 2007 statement of emissions to fixed area sources, and starting in 2007 control compliance with measures established in the PAMA and commitments complementary to the specific fixed source and macro-emitter (DOE RUN PERU), as well as compliance with the CENTROMIN PERU commitments.

Objectives of the component: Reduce in a scheduled manner emissions of contaminants, progressively reverse the contamination and protect people’s health.

Expected results: 1. Reduction in localized emissions as a result of the implementation of the audit system. 2. Reduction in emissions reported periodically and publicly by DOE RUN PERU. 3. Remediation of areas affected by Centromin Perú

Reduction in emissions (%) Year 1 Year 2 Year 3 Reduction in emissions of particles under 10 microns, PM10 Reduction in emissions of sulfur dioxide, SO2

Reduction in emissions of Lead, Pb.

Cost of reduction in emissions (*) Year 1 Year 2 Year 3 Reduction in emissions of particles under 10 microns, PM10

Reduction in emissions of sulfur dioxide, SO2

Reduction in emissions of Lead, Pb.

Schedule: 1. Design and implementation of the periodic measurement system for the motor vehicle fleet. 2. Design and implementation of the area fixed source emissions declarations other than DRP. 3. Dissemination of the results of the audit by MEM on DOE RUN PERU to confirm commitments for DOE RUN PERU to reduce contaminants

with respect to the metallurgical complex. 4. Dissemination of the results of the audit by MEM on CENTROMIN PERU in relation to the achievement of its environmental commitments. 1. [sic] Inventory and annual report of emissions of contaminants based, if applicable, on the monitoring reported to the competent authorities.

Schedule:

Activities Months

1 2 3 4 5 6 7 8 9 10 11 12 13-24 25-36 37-4849-60

1 Periodic measurements of the motor vehicle fleet.

2 Statement of emissions.

3 Periodic inspections of DOE RUN PERU. 4 Inventory and annual report.

Budgets and responsible institutions.

Activities NS/. (**) Responsible institutions1 Periodic measurements of the motor vehicle fleet. 650 000 Provincial Municipality.

2 Statement of emissions. 250 000 Provincial Municipality. 3 Periodic inspections of DOE RUN PERU. 237 500 MEM, Provincial Municipality.

4 Inventory and annual report. 487 500 CAM.

Measurement of success: Better air quality and reduction in the concentrations of critical contaminants, SO2, PM10 and Pb.

Additional comments: The investment by DOE RUN PERU to control emissions of critical contaminants and to modernize the plant is significant. The Provincial Municipality in coordination with the Sectorial MEM authority will develop mechanisms to ensure that those investments are made, as scheduled, according to the commitments assumed by the company. Likewise the remediation actions of the areas affected by fumes constitute a priority action to be undertaken within the basin. (*) Only the costs borne under this Plan, which are related to control actions, are included. (**) Exchange rate US$ 1= NS/ 3.25

Action Plan for the Improvement of the Air Quality and the Health of La Oroya approved unanimously by the Zonal Air GESTA for information purposes and public consultation pursuant to SD 074-2001-PCM and RP 022-2002-CONAM/PCD. It contains deliberations by the Air GESTA; also the provisions of Directorial Order 157-2006-MEM/AAM). {Braces} indicate that the content

is under technical evaluation.

33

{Measurements to improve air quality and prevent its deterioration}

Name of the component:

6. Cleanup, remediation, and atmospheric basin planning program. Justification for the component:

The atmospheric basin requires medium- and long-term planning to be able to provide health and environmental sustainability to all the actions that are taken to improve the air quality. The organization and planning program for the basin will be a responsibility of the provincial municipality supported by the Municipal Environmental Commission and it will consist as a priority of undertaking projects for the better development and growth of the city.

Objectives of the component: Plan the development of the city and improve and sustain the air quality that is achieved after adopting the environmental contamination control measures.

Expected results: 1. Cleanup and remediation of the basin. 2. Road organization and planning of the basin.

Schedule: 1. Design and implementation of the city’s vacuum cleaning system.

2. {Design of the principal remediation projects.} 3. Design and approval of the road plan and organization of the city. 4. Feasibility study of beltways. 5. Design of projects to increase green areas and the ecological belt of the city. 6. Design of the comprehensive management program for solid waste under the scope of the plan. 7. Design and development of the Local Health Education Project. 8. Development of the profile and urban planning project for the basin.

Schedule:

Activities Months

1 2 3 4 5 6 7 8 9 10 11 12 13-24 25-36 37-48 49-601 Cleanup system

2 {Design of remediation projects}

3 Road plan and organization of the city. 4 Feasibility of beltways.

5 Green areas and ecology belt projects

6 Design of waste management project. 7 Local Health Education Project

8 Basin urban planning plan.

Budgets and responsible institutions.

Activities NS/. (*) Responsible institutions 1 Cleanup system 900 000 Provincial Municipality. EPS-RS. 2 Design of remediation projects 500 000 CONAM. Universities.

3 Road plan and organization of the city. 975 000 Provincial Municipality.

4 Feasibility of beltways. 162 500 MTC, Provincial Municipality. 5 Green areas and ecology belt projects 113 750 Provincial Municipality.

6 Design of waste management project. 48 750 Provincial Municipality.

7 Local Health Education Project 1 950 000 MINSA, MINED, Provincial Municipality 8 Basin urban planning plan. 162 500 Provincial Municipality.

Measurement of success: less exposure of people to the critical contaminants emitted and deposited before.

Additional comments: The Local Health Education Project, is the only case that includes the principal costs for its execution, in the other cases the costs only include the projects. (*) Exchange rate US$ 1 = NS/. 3.25