The Government of Montenegro is preparing to permanently dispose of around 530 thousand cubic meters of waste containing high concentrations of hazardous substances in the Podgorica Aluminum Plant (KAP) zone. The Government has borrowed money from the World Bank for this work, although it only has a project based on outdated data, which has been strongly criticized by the Capital City and the Environmental Protection Agency (EPA).
This is the document “Remediation of solid waste landfills in the KAP zone” (Environmental and Social Impact Assessment - ESIA), published on the Government website in January this year. It states that around 530 thousand cubic meters of mixed waste could be permanently retained at the KAP site. The document was prepared for the needs of the Ministry of Ecology, Sustainable Development and Northern Development (MERS). The document itself shows that it was prepared by the consulting companies Encon Environmental Consultancy Ltd. Co. from Turkey and E3 Consulting from Montenegro, and that it relies on the findings of an earlier study from 2012.
The Ministry did not respond to the Center for Investigative Reporting of Montenegro (CIN-CG) about how much the consultants were paid for this work. We received a response in which they claim that the ESIA document is in the process of being updated, which includes new data, the results of additional baseline analyses, as well as comments submitted by the Environmental Protection Agency and the Capital City.
"After the completion of the coordination and approval procedure by the World Bank, the document will be publicly published on the Ministry's website," the Ministry said.
In the Ministry headed by Damjan Ćulafić They also announced that "The main project for the remediation of solid waste landfills in the KAP zone was developed by the JV: Safege (France) and SBCC doo (Montenegro)".
"The value of the contract for the development of the Main Remediation Project was 404.640 euros excluding VAT. According to the Main Remediation Project, the estimated value of the remediation works is approximately 12,7 million euros excluding VAT."
According to the ESIA document, which is currently being updated, the waste is planned to be first relocated to three temporary zones within KAP, and then permanently disposed of in two “final landfill cassettes”. This is contaminated land within the former factory grounds. This project does not envisage the remediation of the red mud basin.
Despite numerous objections to the aforementioned ESIA document by the Capital City, on whose territory a future hazardous waste landfill is planned, and the EPA, without whose Environmental Impact Assessment the landfill cannot exist, the Government has already taken out a loan from the World Bank for this purpose.
Just a month and a half after the objections received from the Capital City and the EPA to the document, the Minister of Finance Novica Vuković signed two agreements with the World Bank in Washington in mid-April, totaling 58 million euros. The larger loan, of 40 million euros, is for a waste management sector improvement project, which finances the construction of the Regional Waste Management Center in Nikšić and the remediation of approximately 11 hectares of contaminated land at the former KAP site.
Plan based on outdated data
One of the key objections raised by the EPA, the Capital City, and the Secretariat for Environmental Protection to the draft ESIA document is the fact that the KAP remediation project is largely based on outdated and inconsistent data, without a thorough review after the plant's closure in 2022.
The institutions warn that the project relies on data from various periods from 1990 to 2021, which are often incomplete, methodologically inconsistent, and difficult to compare, which makes it questionable how realistically the document reflects the situation on the ground.
In its responses to CIN-CG, the capital stated that the document must be updated with current data on the condition of the site, with adequate processing of that data and a comprehensive development of alternative solutions. They specifically pointed out that it is necessary to clearly present the existing level of contamination and degradation, the spatial scope of the pollution, a precise categorization of the waste present, and to harmonize the terminology with current regulations in the field of waste management.
EPA particularly challenges the fact that the document assumes that the only solution is to establish permanent waste disposal sites within the KAP area, without seriously considering alternative models for the remediation and treatment of hazardous waste. The opinions state that other options have not been adequately analyzed, nor has a transparent comparative analysis of potential solutions been conducted. The institutions additionally warn against the imprecise use of technical terms and insufficiently clearly defined methodology.
In its comments, the EPA stated that although the project is formally referred to as remediation, the technical description involves excavating existing waste, moving it, and permanently disposing of it in new cassettes lined with geomembranes, bentonite, and clay. They caution that the description of the layers and the method of construction clearly indicate that this is not remediation, but rather the permanent disposal and retention of waste at that location, thereby transferring responsibility to future generations.
Pollution data
The data on which the January ESIA study, which was used to obtain the loan, is based are analyses of PCB pollution of soil and water, conducted more than three decades ago, from 1990 to 1996. Data on pollutant emissions into the air are from the period 2005-2007. Radiological analyses are from 2006.
Much of the ESIA documentation also relies on studies from 2011 and 2012, conducted for the needs of earlier remediation projects, while more recent data is largely limited to the Center for Ecotoxicological Research (CETI) studies from 2021. After that, only socioeconomic data from 2023 and field visits from 2025 were conducted.
According to CETI analyses from 2021, the KAP site contains approximately 530 thousand cubic meters of heterogeneous waste mixture with extreme concentrations of fluoride, PAH compounds, cyanide, nickel, cadmium, lead, and PCB compounds.
Fluorides were registered in concentrations more than 300 times above the permitted values. PAH compounds, which are considered highly carcinogenic and long-lasting in nature, reached concentrations hundreds of thousands of times above the prescribed limits. Cyanides, nickel, cadmium and lead were also registered in excessive concentrations. Of particular concern is the presence of PCB compounds, the concentrations of which within the factory reached up to 100.000 times higher than the permitted values.
The contamination was not limited to the surface layer of the waste. The ESIA document confirms the migration of pollutants at depths of between five and ten meters in the ground, while data from a 2012 study shows the presence of toxic substances at depths of 15 to 20 meters. This confirms that the pollution has already penetrated into the groundwater and surrounding soil.
Poison reaches Morača and Skadar Lake
The consequences of long-term pollution have also been recorded outside the factory area. Increased concentrations of nickel, mercury, lead and PAH compounds have been registered in the settlements of Botun, Srpska and Mahala. In Botun, some PAH compounds were about 36 times above the permitted values. Pollutants from KAP have also been registered in the sediments of the Morača River, especially downstream of the industrial complex. As an ultimate recipient, Lake Skadar, a UNESCO biosphere reserve, is additionally endangered through the transfer of pollutants to groundwater and the atmosphere.
The data also shows serious air pollution while KAP was operating at full capacity. During the period from 2005 to 2007, KAP emitted between five and 11 thousand tons of various pollutants annually, including sulfur dioxide, carbon monoxide, suspended particles and hydrogen fluoride. The documentation also indicates a rapid increase in the concentration of PAH compounds in the air of Podgorica, directly related to the operation of the factory.
An additional problem is the extreme alkalinity of the red mud at the site. The average pH value was 11,5, while the maximum reached as high as 13,85, which can cause serious soil degradation and further accelerate the spread of heavy metals through the soil and groundwater.
A special remark refers to CETI's research, which is said to be insufficiently detailed to determine with certainty what is at the site and the actual extent of contamination. EPA warns that due to incomplete characterization of waste and materials, it is not possible to properly assess the risks or long-term consequences of the planned remediation.
Although the findings confirm the presence of hazardous waste and long-term pollution, the ESIA study lacks a detailed analysis of the mobility of hazardous substances and a risk assessment. Without a precise determination of the composition of the materials, it is not possible to properly assess alternative solutions or make a transparent comparative analysis of other remediation models, other than permanent disposal of waste at the same location, the Agency concludes.
The planned measures mainly consist of collecting and encapsulating part of the waste in landfill cassettes, while the core problem remains unresolved. Available analyses show that the contamination is not limited to surface waste, but that the soil is deeply contaminated, including layers up to 20 meters deep and groundwater. Despite this, the project does not offer a comprehensive solution for the decontamination of the site, nor does it clearly define how to treat the already existing pollution that has been spreading through the soil and waterways for decades.
Ministry promises to update data
When asked by CIN-CG about the data being outdated, MERS responded that they did not see a problem with it:
"The ESIA document was prepared based on analyses conducted in 2021, which is clearly indicated in the document itself, which is publicly available on the Ministry's website. It is also important to point out that the ESIA in question is an updated version of the 2022 document, prepared by the Environmental Protection Agency. In this context, we note that an Environmental Impact Assessment Study for the rehabilitation of the solid waste landfill in the KAP zone was previously prepared for the location in question, to which the Environmental Protection Agency issued approval on 17 October 2022."
MERS told CIN-CG that in order to ensure the accuracy and reliability of data, a new Study is planned. The agreement on the development of the new Study was reached at a meeting with the Environmental Protection Agency on February 16, 2026.
"This process is directly related to the implementation of new analyses, which will enable a more precise understanding of the current situation at the site and adequate improvement of existing documents," MERS told CIN-CG.
They explain that the draft ESIA document clearly states that new, more detailed analyses are planned. To this end, CETI was hired from the grant funds allocated by the World Bank for the preparation of the “Waste Management Reform” project to conduct new baseline analyses at the site. The contract was signed on March 4, 2026, and the report was submitted on May 12, 2026, so the data will be incorporated into both documents (ESIA and EIA).
"When it comes to alternative solutions, certain variants have already been considered and presented in the draft ESIA document, while their additional elaboration and detailed explanation will be included in the final version of the document, which is currently being prepared. Also, all comments from the Environmental Protection Agency and the Capital City have been duly received and carefully considered, and will, together with the results of new analyses, be adequately integrated into the final document," MERS told CIN-CG. In relation to CIN-CG's question about the possible relocation of waste and the search for a new location, the Ministry responded that they believe that the proposed remediation solution at the existing location is feasible:
"The main project has been revised in accordance with the legal procedure, and, as we have already stated, the Environmental Protection Agency previously issued approval for the solution in question through the environmental impact assessment procedure."
Previous World Bank project that did not complete the rehabilitation of KAP
This is the World Bank's second attempt to finance the rehabilitation of KAP. The previous project, the Industrial Waste Management and Cleanup Project, worth approximately $68,9 million, came into effect on November 17, 2014, with a completion date of June 30, 2019.
The project was supposed to remediate five ecological black spots in Montenegro: the Bijela shipyard, the Gradac mine tailings dump, the coal ash landfill in Pljevlja (Maljevac), and two locations in the KAP zone. Some of the ecological black spots have been remediated.
However, in 2018, the part of the loan intended for works at the KAP site was cancelled, as Montenegro failed to prepare technical documentation and environmental assessments on time. The rehabilitation of KAP was then reduced to financing only technical preparation and design, while the rehabilitation works were transferred to a new World Bank project.
The minister claims one thing, the World Bank document another.
The World Bank's Project Information Document (PID) published on 29 April 2025 states that Montenegro currently lacks a landfill for the permanent disposal or treatment of hazardous waste, forcing waste producers to either export or temporarily store it. The same document states that as part of the project preparation, they are considering the option of converting the solid waste landfill at the KAP site, including the potential establishment of a permanent site for the safe and sustainable disposal or treatment of hazardous waste. This would, it is stated, meet the long-term needs of hazardous waste management, while at the same time reducing environmental risks.
There is a direct contradiction between this project and what Montenegrin officials are saying. Minister Damjan Ćulafić stated on March 28, 2026 that the remediation of contaminated land at KAP begins a systematic solution to a decades-old environmental problem and reduces risks to the health of citizens and the environment.
"I would like to remind you that by amending the State Waste Management Plan, we have ruled out the possibility of future disposal of hazardous waste in the KAP zone, thereby taking a concrete and decisive step towards improving the environment in Zeta. The ban on waste disposal at that location, along with the remediation of the existing landfill, means that we are permanently solving this inherited problem, which is the result of absolute negligence for the environment, and thus for health," said Ćulafić.
The minister's statements directly contradict the content of the official World Bank document. What the minister calls “remediation”, the document describes as permanent encapsulation and on-site disposal, with the storage of additional waste from the Bijela shipyard at the site of the former giant of the Montenegrin metallurgical industry. While the minister claims that the possibility of future hazardous waste disposal in the KAP zone is excluded, the World Bank document explicitly states the opposite.
Montenegro has borrowed twice to rehabilitate KAP, and both times the foundation was not ready. The first World Bank project failed precisely because the documentation was not in order.
Almost a decade later, history is repeating itself: the loan was signed at a time when the objections of the Capital City and the EPA were on the table, and the documentation from the study was being disputed.
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