In addition to numerous problems in the implementation of initiated projects for the construction of wastewater treatment plants (WWTP) in several municipalities, one of the key challenges that affects both the health of the population of Montenegro and environmental protection is the inadequate disposal of sewage sludge.
"Waste sludge is created as a result of the wastewater treatment process, in which organic matter, particles and other pollutants are separated from the water and precipitated, forming sludge that must then be properly processed and disposed of," the Royal Capital of Cetinje explained to Center for Investigative Journalism (CIN-CG), in which planning documentation for the wastewater treatment plant is still in the development phase.
Vodovod Nikšić told CIN-CG that "the issue of sludge disposal, which is a by-product of the purification process, has not yet been systematically resolved at the national level. This issue requires coordination and a solution at the state level in order to ensure long-term and sustainable management of this type of waste."
All municipalities that do not yet have a WWTP are discharging wastewater directly into natural recipients - rivers, tributaries or the immediate surroundings, which represents a serious environmental problem.
In Podgorica, a significant amount of treated wastewater is still discharged directly into the Morača River.
"The current situation in the municipality of Bijelo Polje is such that collected municipal wastewater is discharged directly into the Lim River or its tributaries, without prior treatment," DOO Vodovod i kanalizacija Bijelo Polje told CIN-CG.
Coalition 27 points out that the problem is also the lack of a reliable system for measuring the quantity and quality of wastewater, as well as insufficiently developed monitoring of the discharge of treated water.
"The current situation regarding sewage sludge disposal in Montenegro is unacceptable and poses a serious risk to the environment and water resources. The Government needs to adopt a Sewage Sludge Management Plan as soon as possible," the Shadow Report states.
Of the ten wastewater treatment plants currently operational, the sludge disposal situation remains unresolved in most cities.
Even the plants that are operational, such as those in Budva, Tivat and Kotor, have problems with wastewater.
Wastewater analysis
CIN-CG received from the Water Administration (UZV) the results of laboratory analyses of wastewater sampled during 2024. Although we requested an analysis of all wastewater from the plant, we only received results for the Budva WWTP and the joint Tivat-Kotor WWTP..
The document states that during 2024, more than three and a half billion liters of wastewater were discharged from the Kotor-Tivat WWTP..
The quality of wastewater from the joint Tivat-Kotor WWTP in February, May and September was not in compliance with the Law on Municipal Wastewater Management, nor did it meet the requirements prescribed by the Rulebook on the quality and sanitary and technical conditions for the discharge of wastewater.
Excessive phosphorus concentrations were recorded in February and May samples, and the samples visually ranged from yellow to brown in color.
"The results of the analyses indicate that the water treatment and functioning of the WWTP were not at a satisfactory level. It is recommended that measures be taken to reduce the phosphorus content in the outlet water, the concentration of which may pose a danger to the environment - the sea. Increased phosphorus content can cause eutrophication, which impairs water quality, encourages excessive algae growth and reduces oxygen concentration," according to laboratory analyses conducted by the Institute for Hydrometeorology and Seismology (ZHMS) in February and May 2024.
In early September, the water sample was dark brown in color, and the analysis results indicated increased concentrations of BOD5, suspended solids and phosphorus.
BOD5 (Biological Oxygen Demand in Five Days) is the amount of oxygen that microorganisms use to break down organic matter in water over a period of five days. A high BOD5 value means that the water contains a large amount of organic matter (e.g. feces, food scraps, industrial waste), which reduces the concentration of oxygen in the water and can lead to suffocation of the aquatic ecosystem..
Suspended matter is solid particles floating in water (e.g. silt, sand, food scraps, organic waste). It is dangerous because it can mechanically suffocate aquatic organisms and contain pathogenic microorganisms or heavy metals.
When it comes to the WWTP in Budva, in June, July and October, wastewater analysis showed that certain parameters were above the permitted limits. According to analyses by the Institute of Public Health (IJZ), an increased concentration of chemical oxygen demand (COD) was registered in the June sample.
COD shows how many organic and inorganic pollutants in water react with strong oxidizing agents, consuming oxygen. Unlike BOD5, COD also includes toxic chemicals, and is a broader indicator of overall chemical pollution..
No sewage sludge management plan
The Waste Management Law of 2024 defines sewage sludge as waste generated during the treatment of municipal wastewater in treatment plants and equipment. According to the same law, a Sewage Sludge Management Plan was required.
However, there is still no plan, which poses a serious challenge when it comes to sludge treatment and disposal. The plan should define the collection, treatment and disposal of sludge, with clearly developed procedures at the national and local levels, and ensure compliance with European standards and practices.
According to the Municipal Wastewater Management Plan of Montenegro 2020-2035, the Ministry of Ecology, Sustainable Development and Northern Development is the competent national body for regulation, planning and implementation of policies in the field of sludge management.
However, CIN-CG has not received answers from that government department regarding the extent to which existing and planned WWTPs are taking sludge disposal issues into account.
"Your inquiry has been forwarded to the Ministry of Ecology, Sustainable Development and Northern Development for review and further action in accordance with its jurisdiction," the PR service of the Government of Montenegro told CIN-CG.
The Ministry itself, however, responds that they do not consider themselves competent:
"We inform you that the questions you have asked regarding wastewater plants are not within the jurisdiction of the Ministry of Ecology, Sustainable Development and Northern Development. Accordingly, the Ministry cannot provide an answer to the questions asked."
Eco-team Director Milija Čabarkap points out that sewage sludge management is currently one of the weakest links in the entire system.
"Although there is legislation, it is hardly implemented in practice. Existing plants are faced with various improvised solutions - sludge is stored somewhere on the plant's own location, such as in Podgorica, somewhere it is disposed of in unsanitary landfills, and in some cases it is even exported. Such a practice is unsustainable, expensive and environmentally risky," warns Čabarkapa.
He points out that given the planned expansion of the WWTP network and the increase in the amount of sludge produced, a sustainable, systemic approach to this issue must be urgently established.
"Until a permanent infrastructure for its treatment and disposal is developed, the state and municipalities must devise temporary but safe solutions to avoid serious environmental consequences and inefficient spending of resources."
Temporary solutions for sludge
Given that the sludge treatment line at the Herceg Novi WWTP is not completed, waste material is temporarily stored on site.
"The waste sludge is stored in one working sequential biological reactor (SBR), that is, a tank at the WWTP itself, because the sludge line is not completed," he told CIN-CG. Borivoje Djekic, executive director of DOO Water Supply and Sewerage Herceg Novi.
In the Royal Capital of Cetinje, the project to build a WWTP is only in its initial stages, and there is no WWTP in Bar either. The local government says they do not know when it might be built.
Regarding the sludge that is generated after wastewater treatment, the agreement is that the Government, or rather the competent Ministry, will take over solving this problem for all municipalities in Montenegro, he says. Fikret Kuč, Head of the Department for Development Projects of the Municipality of Rožaje.
Plužine does not have a WWTP either, so wastewater is not treated and sludge is not processed.
In Andrijevica, it is planned to bury the sludge in the pools, with a ten-year deadline for resolving the issue of its disposal.
"The waste sludge that will be generated by the plant's operation is projected at 21,46 tons per year. The landfilling is completed when the basins are filled, followed by a standstill phase and sludge analysis. The plant operator is responsible for its collection and disposal, in accordance with the Waste Management Law," it states. Miloš Mijović, executive director of DOO Vodovod i kanalizacija Andrijevica.
In Kolašin, "waste sludge is currently being treated in reed fields and lagoons for temporary disposal, until the construction of the plant is realized," it states. Mirela Draskovic, Acting Secretary of the Secretariat for Spatial Planning, Communal Affairs and Traffic of the Municipality of Kolašin.
Incinerators envisaged by the Spatial Plan of Montenegro
The Spatial Plan of Montenegro until 2040 envisages the construction of three plants for thermal treatment (incineration) of residual sewage sludge, i.e. incinerators, the implementation of which was planned for the period 2020-2024.
"Montenegro's obligation is to build WWTPs in all local communities, and within them, resolve the issue of sewage sludge disposal. In each municipality, it is necessary to plan sustainable management of the resulting sludge," the document states.
According to the same plan, three regional incinerators are planned. One plant is planned in Podgorica, which includes Cetinje, Danilovgrad, Tuzi and Zeta, the second in Nikšić with Pljevlja, Žabljak, Plužine and Šavnik, the third in Bijelo Polje with the cities of the Northern region excluding Pljevlja.
"Plants built to burn sewage sludge, either directly or as sludge residue after its previous processing, can produce energy and hot water," the Spatial Plan states.
CIN-CG has already written about the possible health and environmental risks of the planned incinerator in Podgorica as part of a story about the protests of the villagers of Botuni against the construction of the plant in this village.
Health risks
Several international reports from relevant organizations warn of the harmful consequences for human health and the environment caused by untreated sewage sludge.
“Sewage sludge contains pathogenic microorganisms - bacteria, viruses and parasites. Without adequate treatment and safe disposal, there is a risk of contamination of water and soil, which can cause diseases such as diarrhea, hepatitis A, typhoid and parasitic infections,” states the 2018 WHO Guidelines on Sanitation and Health.
According to the United Nations Environment Programme (UNEP), sewage sludge can contain heavy metals such as lead, mercury and cadmium, as well as pharmaceutical residues and other chemicals. Long-term exposure to these substances can lead to chronic diseases, including cancer, as well as liver and kidney damage.
Regarding the environment, inadequately treated sludge contains toxic substances that accumulate in the soil, reducing its fertility and endangering plants and microorganisms, according to the European Environment Agency (EEA, Sludge Management and Environmental Impact).
Nutrients from sludge, such as nitrogen and phosphorus, enter the water and cause excessive algae growth, which leads to a decrease in oxygen in the water and threatens fish and other aquatic life (UNEP).
Also, improper sludge storage can emit harmful gases such as methane, ammonia, and sulfur dioxide, which cause respiratory irritation and worsen asthma and other lung diseases, according to the report "Wastewater and Health Risks" by the Centers for Disease Control and Prevention (CDC).
SAI recommendations largely unimplemented
The Shadow Report states that implementation of legal obligations and institutional coordination remain problematic. The Ministry of Ecology, Sustainable Development and Northern Development must be more proactive in informing local and state authorities about the obligation to submit water permits for wastewater discharges by 31 January of the current year, in order to establish accurate records, in accordance with the Law on Municipal Wastewater Management.
In addition to the irregular submission of reports, the quality of the submitted data is also highlighted as a chronic problem. A working group coordinated by Monstat, which would include all relevant institutions with the aim of unifying data on the operation of the facilities, has not yet been formed.
The State Audit Institution (SAI) recommended that working teams be formed for each facility, which would analyze the current situation, identify key challenges, and propose specific measures to improve the operation of the facilities. This recommendation was not implemented, nor was the Ministry's planned tender for the development of a software solution and the procurement of equipment for establishing an information system for monitoring the operation of wastewater treatment plants announced in 2024.
In order to improve the management of the wastewater system in Montenegro, the SAI issued 122 recommendations for 22 audited entities. The recommendations were issued in September 2022, and by the beginning of this year, most of them had not been implemented.
Export to Albania, then to Podgorica
Sewage sludge from three coastal municipalities - Kotor, Tivat and Budva - will arrive in Podgorica from May 2024. Previously, it was exported to Albania, but that arrangement was terminated.
Stefan Čobanović, the executive director of the WWTP for the municipalities of Kotor and Tivat, explains to CIN-CG that this is non-hazardous waste. The sludge that was exported is dehydrated at the plant itself using appropriate machines, he says, with the addition of polymer flocculants and slaked lime, which produces dehydrated sludge whose dryness varies between 30 and 40 percent of dry matter.
From May last year to July this year, 2.900 tons of sludge were delivered to Podgorica from three coastal municipalities.
The chief engineer of the Podgorica Landfill, Ratko Pavićević, told CIN-CG that this amount is not large compared to the 120.000 tons of waste collected annually at this landfill, plus 40.000 tons of bulky and plant waste.
"We would not have taken over that sludge if the Center for Ecotoxicological Research (CETI) had not previously conducted analyses. It is not hazardous waste, we do not accept any hazardous waste," claims Pavićević, adding that there was interest in storing sludge from Nikšić and some other municipalities at the Podgorica landfill.
"We refused because the sludge was not processed, so it could be dangerous, and we did not accept it even though we had the opportunity to make money from it."
"We take hydrated sludge from coastal municipalities on site, so that we don't end up in a situation where something else is loaded there - our trucks, our containers, and we take everything ourselves," Aleksandar Božović, director of the Podgorica Landfill, tells CIN-CG.
"According to the integrated work permit issued by the Environmental Protection Agency, we have a regulation that allows us to accept up to six percent of municipal, hydrated sludge at the landfill, in relation to the total amount of waste. Which means that we could accept two and a half times that much in a year," says Božović, adding that they could also take over sludge from other municipalities, but that they do not have systems to process and hydrate the sludge so that it could be stored at the landfill.
Three coastal municipalities previously exported waste to Albania through the Podgorica-based company Montelea.
Čobanović claims that the company he heads did not have any business cooperation with the state of Albania, but rather a public tender was announced in Tivat for the transport and disposal of sludge, to which only the company Montelea from Podgorica responded.
"The contract was terminated at the beginning of March 2024 because the aforementioned company stopped fulfilling its contractual obligations for reasons unknown to us. After that, cooperation never resumed," says Čobanović.
Unlike them, the Budva Wastewater Company has a different experience of cooperating with the Montelea company, with whom they had a contract during 2023 "for urgent resolution of the problem with sludge removal."
“But those contracts were concluded for a certain period of time and they were fully executed,” Acting Executive Director Svetlana Dragović told CIN-CG.
According to unofficial information from CIN-CG, processed sludge from the Montenegrin coast was sold as compost in Albania. CIN-CG journalists saw this sludge, which looked like soil, at a Podgorica landfill. We tried to get answers from the Montelea company about how the sludge was exported to Albania and whether the claims that it was resold there are true, but they did not arrive.
"Our Society does not have any information about the possible further use, as well as the method of final disposal of sewage sludge in another country, nor are we responsible for that," Čobanović told us.
Budva paid the Montelea company 70 euros excluding VAT, or 84 euros including transportation, for the export of a ton of sludge.
The plant for Kotor and Tivat exported sludge to Albania through this company at a price of 66 euros excluding VAT. Storage in Podgorica, Deponija, is now paying 70 euros excluding VAT.
Sludge is not used in agriculture in Montenegro.
According to the Law on Waste Management, treated sludge can be used for various purposes: in agriculture, in green areas and parks, for land reclamation purposes, including the afforestation of bare land, in landfills as a cover layer, for the preparation of land for special purposes, for energy production by incineration and/or co-incineration, as well as for the rehabilitation of unregulated landfills and other similar areas that need to be brought into use.
However, the Ministry of Agriculture, Forestry and Water Management does not foresee the possibility of using treated sewage sludge in agriculture, although Directive 86/278 EEC refers to the application of treated sewage sludge in agriculture, as stated in the thematic analysis of Coalition 27 published in November 2023 under the title "The problem of sewage sludge in Montenegro".
Directive 86/278 EEC allows the use of treated sewage sludge in agriculture in many European countries, but this is not the practice in Montenegro.
Although the Law on Waste Management recognizes the possibility of using processed sludge in agriculture, this activity is not regulated by the Law on Agriculture and Rural Development. The law does not recognize sewage sludge as a fertilizer or soil improver. Therefore, this aspect is not considered in the national sludge management plans.
The Municipal Wastewater Management Plan of Montenegro states that the use of sewage sludge in agriculture is not recognized by national legislation regulating the use of fertilizers for plant growth, and therefore this type of use is not considered in the Sludge Management Plan.
The Law on Waste Management also defines the conditions under which treated sludge can be used, including in agriculture, but with strict restrictions and prohibitions in certain cases. For example, Article 75 of this law prohibits the use of treated sludge on lands subject to leaching into surface waters, on shallow or skeletal soils, as well as in areas of protected natural resources or zones of sanitary protection of drinking water sources. There are also prohibitions regarding the use of sludge on pastures and in the production of plants for animal feed, if sufficient time has not passed between the application of sludge and grazing or harvesting.
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